For facilities recovering wastes off site within the industry group in 1999, the primary metals, solvents, and other recovery practices are high temperature metals recovery/ secondary smelting, fractionation/ distillation, and acid regeneration, respectively. Residuals from these management practices that are derived from a listed waste or have a hazardous characteristic are managed as hazardous. High temperature metals recovery/ secondary smelting, fractionation/ distillation, and acid regeneration residuals are assumed to be managed by hazardous waste landfill disposal with stabilization, energy recovery, and chemical precipitation with off site stabilization and landfill disposal of precipitates and sewer discharge of neutralized wastewater, respectively. 5 2 If hazardous wastes are excluded from RCRA Subtitle C jurisdiction if recovered additional facilities may determine that recovering their waste is more economical than treatment or disposal. Three groups of waste are evaluated for their potential new recovery practices. The first group of plants are those that reported a quantity of waste recovered in 1997 but not in 1999. 1997 Biennial Report data were used to identify the plants that recovered hazardous wastes in 1997. Based on an analysis of market price changes between 1997 and 1999, it is assumed that 100 percent of the 1997 waste streams which went to recycling ( but did not in 1999) would again be sent to recycling as a result of the change in regulatory status for these wastes ( see Appendix E). Some of the limitations with this assumption is that the plant may have closed, discontinued the process generating the waste, modified the process such that the waste was no longer generated, or the waste was a one time generation event ( e. g., spill cleanup or remediation activity). For facilities that recovered wastes on site or off site in 1997, the assumed baseline management practices in 1999 for metal bearing, solvent and acidic wastes are off site commercial hazardous waste landfill, off site energy recovery, and on site neutralization, respectively. Residuals from these management practices are minimal or non hazardous. Off site landfill residual ( leachate) management costs would be included in the commercial landfill price. Off site energy recovery residual management costs would be included in the commercial energy recovery ( e. g., cement kiln) price. Acid neutralization residuals would be discharged to a POTW which has a relatively small cost.

The second group of plants are those that recovered wastes off site outside their industry group in 1999. If economically feasible, some of these plants may construct on site recovery facilities to recover metal, solvent and acid values from their wastes. The primary ( baseline) off site metals, solvents, and other recovery practices are high temperature metals recovery/ secondary smelting, fractionation/ distillation, and acid regeneration, respectively. Residuals from these management practices that are derived from a listed waste or have a hazardous characteristic are managed as hazardous. High temperature metals recovery/ secondary smelting, fractionation/ distillation, and acid regeneration residuals are assumed to be managed by hazardous waste landfill disposal with stabilization, energy recovery, and chemical precipitation with off site stabilization and landfill disposal of precipitates and sewer discharge of neutralized wastewater, respectively. A breakeven cost analysis was conducted to determine which plants would construct on site recovery facilities.

The third group of plants are those that disposed wastes on site or off site in 1999. If economically feasible, some of these plants may construct on site recovery facilities to recover metal, solvent and acid values from their wastes. Table 5 1 presents the specific waste types that were evaluated and their respective baseline management practices and residual management practices. A break even cost analysis was conducted to determine which plants would construct on site recovery facilities. 5 3 Table 5 1. Baseline Management Practices for List of Disposed Waste Types Analyzed for Potential On Site Recovery Waste Types SIC Codes Waste Forms Baseline Management ( Residual Management)

Organic Liquids ( from Industrial Organic Chemicals, Paints and Allied Products, Pharmaceutical Preparations, and Plastics Materials and Resins Industries) 2869 2851 2834 2821 Liquid Form Codes ( B101 B119, B201 B219) Off site Fuel Blending Emission Control Dust ( from Steel Works Industry) 3312 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) Off site Stabilization and Subtitle D Landfill ( Envirosource delisting technology)

Metal Containing Liquids ( from Printed Circuit Board Industry) 3672 Liquid Form Codes ( B101 B119, B201 B219) On site or Off site Chemical Precipitation Electroplating Wastewater Treatment Sludges ( from Printed Circuit Board Industry) 3672 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) Off site Stabilization and Landfill Spent Carbon ( from Industrial Organic Chemicals and Petroleum Refining Industries) 2869 2911 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) Off site Incineration or Carbon Regeneration1 Spent Catalyst ( from Petroleum Refining Industry) 2911 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) Off site Stabilization and Landfill Spent Aluminum Potliner ( from Aluminum Industry) 3334 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) Off site Incineration Spent Pickle Liquor ( from Steel Works Industry) 3312 Liquid Form Codes ( B101 B119, B201 B219) On site or Off site Chemical Precipitation 1 Facilities reporting Other Treatment ( M125) waste stream management in the 1999 BRS were assumed to use off site regeneration of carbon as the disposal method. All other facilities were assumed to use incineration as the baseline management method. 5 4 Current RCRA administrative requirements for the baseline large quantity generators ( LQGs) identified through the Biennial Report System are listed in Table 5 2. A summary of potential cost impacts for each administrative requirement, pre and post rule, are included in the table from any changes in generator status that may result from the exclusion from the Definition of Solid Waste.

In addition, transfer costs may be reduced with the reduction in hazardous waste generation taxes and fees paid by generators who reclaim their wastes. These costs do not count as social cost savings because they are a redistribution ( transfer) of wealth. However, they do influence a generators's ( firm's) decision to reclaim their waste. See Appendix F for an analysis of current state hazardous waste generator taxes and fees.

Table 5 2. RCRA Administrative Requirements for Generators RCRA Generator Requirement Generator Status Cost Impacts LQG (> 13.2 tons/ yr) SQG ( 1.3  13.2 tons/ yr) CESQG (< 1.3 tons/ yr)

EPA ID Number Required Required Not required Assumed no cost savings because generators already have incurred costs for obtaining EPA ID number.

RCRA Personnel Training Required ( 40 CFR 262.34) Basic training required ( 40 CFR 262.34) Not required Cost savings incurred if generator becomes a small or conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste.

Recordkeeping Required for manifests, exception report, and biennial report. Required for manifests and exception reports. Not required Cost savings incurred if recovered waste not defined as a hazardous waste or if generator becomes a small or conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste.

Exception Report Required within 45 days of hazardous waste being accepted by initial transporter Required within 60 days of hazardous waste being accepted by initial transporter Not Required Cost savings incurred if generator becomes a small or conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste.

Biennial Report Required Not required Not required Cost savings incurred if generator becomes a small or conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste. Table 5 2. RCRA Administrative Requirements for Generators RCRA Generator Requirement Generator Status Cost Impacts LQG (> 13.2 tons/ yr) SQG ( 1.3  13.2 tons/ yr) CESQG (< 1.3 tons/ yr)

5 5 Accumulation Time Limits 90 days 180 days [ or 270 days if transported more than 200 miles] None Cost savings incurred if generator becomes a small or conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste.

Storage Requirements for Accumulated Hazardous Waste Full compliance with management of containers or tanks Basic requirements with technical standards for containers or tanks None Assumed no cost savings if generator status changes because facilities already have incurred costs.

Use Manifests Required Required, unless the waste is reclaimed under a contractual agreement Not required Cost savings incurred if recovered waste not defined as a hazardous waste or if generator becomes a small ( with contract agreement) or conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste.

Contingency Plan Required Not required Not required Cost savings incurred if generator becomes a conditionally exempt small quantity generator with exclusion from the Definition of Solid Waste.

LQG = Large quantity generator SQG = Small quantity generator CESQG = Conditionally exempt small quantity generator 5.3 Post Regulatory Cost Components Under post regulatory conditions, facilities that recovered wastes on site and off site ( within the same industry group) for the 1999 site list have the same recovery management practices as those for the baseline scenario, however, residual management may change. If wastes are no longer " listed" as hazardous if they are recovered either on site or off site within the same industry group ( 4 digit NAICS), residuals from the recovery processes will no longer be hazardous under the " Derived from Rule" unless they exhibit a hazardous characteristic. For high temperature metals recovery/ secondary smelting, hazardous residual management is assumed to be disposed in a 5 6 Subtitle C landfill with stabilization. The management of these residuals will shift from Subtitle C to Subtitle D landfill if they do not test characteristically hazardous. Non hazardous residual management is assumed to be Subtitle D landfilling. For fractionation/ distillation, hazardous and non hazardous residual management is assumed to be fuel blending. For acid regeneration, hazardous residual management is assumed to be chemical precipitation. The management of these residuals will shift from Subtitle C to Subtitle D disposal if they do not test characteristically hazardous. Non hazardous residual management is assumed to be sewer discharge to a local publically owned treatment works ( POTW). It is assumed as a rough approximation that 5 percent, 15 percent, and 25 percent of the residual quantity is nonhazardous post rule, for secondary smelting, distillation, and acid regeneration, respectively. These percentages are based on an analysis of the frequency and quantity of wastes currently classified as characteristic only waste ( i. e., single or multiple D code wastes) entering on site recovery processes in 1999. These percentages reflect the portion of the waste entering recovery processes that are not characteristically hazardous ( i. e., single or multiple D code wastes), but, listed hazardous waste which will become nonhazardous post rule.

For facilities that recovered wastes on site and off site in 1997 but not in 1999, the postregulatory management practices for metal bearing, solvent and acidic wastes are high temperature metals recovery/ secondary smelting, fractionation/ distillation, and acid regeneration, respectively, based on recovery practices reported in 1997. The residual management assumptions are the same as those presented above.

For facilities that recovered wastes off site outside their industry group in 1999, the postregulatory recovery management practices for metal bearing, solvent and acidic wastes are ONSITE high temperature metals recovery/ secondary smelting, fractionation/ distillation, and acid regeneration, respectively, if economically feasible. A break even cost analysis was conducted to determine which plants would construct on site recovery facilities. Otherwise there is no change from the baseline management practice. The residual management assumptions are the same as those presented above for on site recovery systems.

For facilities of selected waste types that disposed wastes off site in 1999, the post regulatory ON SITE recovery management practices and residual management practices are presented in Table 5 3, if economically feasible. A break even cost analysis was conducted to determine which plants would construct on site recovery facilities. If it is not economically feasible to construct an on site recovery system there is no change from the baseline management practice. 5 7 Table 5 3. Post Regulatory Management Practices for List of Disposed Waste Types Analyzed for Potential On Site Recovery Waste Types SIC Codes Waste Forms Post Regulatory Management ( Residual Management)

Organic Liquids ( from Industrial Organic Chemicals, Paints and Allied Products, Pharmaceutical Preparations, and Plastics Materials and Resins Industries) 2869 2851 2834 2821 Liquid Form Codes ( B101 B119, B201 B219) On site Fractionation/ Distillation Emission Control Dust ( from Steel Works Industry) 3312 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) On site Smelting Metal Containing Liquids ( from Printed Circuit Board Industry) 3672 Liquid Form Codes ( B101 B119, B201 B219) On site Ion Exchange Electroplating Wastewater Treatment Sludges ( from Printed Circuit Board Industry) 3672 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) On site Smelting Spent Carbon ( from Industrial Organic Chemicals and Petroleum Refining Industries) 2869 2911 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) On site Carbon Regeneration: " Roasting"

Spent Catalyst ( from Petroleum Refining Industry) 2911 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) On site Smelting Spent Aluminum Potliner ( from Aluminum Industry) 3334 Solid Form Codes ( B301 B319, B401 B409) Sludge Form Codes ( B501 B519, B601 B609) On site Fluoride Recovery using Vortec technology Spent Pickle Liquor ( from Steel Works Industry) 3312 Liquid Form Codes ( B101 B119, B201 B219) On site Acid Regeneration 5 8 Potential cost savings from changes in RCRA administrative requirements because of reduced manifest, recordkeeping, and generator status ( i. e., SQG and CESQG) requirements are listed in Table 5 2.

An additional one time costs will be incurred by each generator for completing a notification of RCRA exclusion for their waste.

There is a distributional affect on transfer costs. If wastes are no longer " listed" as hazardous if they are recovered either on site or off site within the same Industry Group ( 4 digit NAICS), state hazardous waste generation taxes and fees may no longer apply. These reductions in costs are not social cost savings but do impact a generator's decision to reclaim its wastes. State hazardous waste taxes and fees are presented in Appendix F.

5.4 Annualization Methodology of Before Tax Compliance Costs Under Executive Order 12866, EPA must determine whether a regulation constitutes a " significant regulatory action." One of the criteria for defining a significant regulatory action, as defined under the Executive Order, is if the rule has an annual effect on the economy of $ 100 million or more. To determine whether the proposed exclusion from the Definition of Solid Waste is a significant regulatory action under this criteria, all costs are annualized on a before tax basis assuming a seven percent real discount rate. The savings attributable to corporate tax deductions or depreciation on capital expenditures for equipment are not considered in calculating before tax costs.

A plant specific annualized before tax cost analysis was conducted for each plant affected by the proposed rulemaking. Annual before tax baseline, compliance, and incremental compliance costs were estimated for each plant. Before tax incremental compliance costs were used because they represent a resource or social cost of the rulemaking, measured before any business expense tax deductions that are available to affected companies. In reformulating the social costs of compliance, a discount rate ( real rate of return) of seven percent was used, assuming either a 10 year or 14 year borrowing period.

The following formula was used to determine the before tax annualized costs:

Annual Before Tax Costs = ( Capital Costs)( CRF n)+ ( Annual O& M Costs)

Where: CRF n = Capital recovery factor ( i. e., the amount of each future annuity payment required to accumulate a given present value) based on a 7 percent real rate of return ( i) and a 10 year borrowing period ( n) as follows:

( 1 + i) n( i) = 0.14238 when n = 10 ( 1 + i) n 1 0.11435 when n = 14 5 9 Costs for contingency planning, initial waste characterization, and the notification of exclusion are one time costs. These costs will be incurred the first year, but not subsequent years.

5.5 Example Cost Calculations Using the waste quantity/ recovery technology inputs, unit costs, and annualized cost functions described in the following subsections, cost impacts/ savings were calculated on a per plant basis. All the plant specific cost impact/ savings calculations are summed over all plants identified as potentially impacted by the proposed rule to determine the total cost impact/ savings from the rule. Cost determinants are the plant's quantity of hazardous waste recovered on site or off site within the same Industry Group ( 4 digit NAICS code), recovery management method, and the total quantity of hazardous waste generated to determine RCRA administrative requirements that vary depending on generator status ( i. e., large, small, or conditionally exempt).

Example cost calculations are presented for the following six plant categories: 1) plants that recovered hazardous waste on site in 1999, 2) plants that recovered hazardous waste on site in 1997 but not in 1999, 3) plants that recovered waste off site in 1999 within the same industry group, 4) plants that recovered waste off site in 1997 within the same industry group, 5) plants that recovered waste off site in other industry groups, and 6) plants that disposed potentially recoverable wastes on site or of   site in 1999. The type of waste being recovered ( metal bearing, solvent, or acid), the year the waste was recovered and the location ( on or off site) determined the cost calculation methodology. Table 5 4 references the appendices at the end of this analysis that present an example calculation demonstrating how the costs were calculated for each plant for that plant category and waste type. Given resource constraints, example cost calculations are not presented in the appendices for all the waste types within the off site recovery in other industry group plant category and on site and off site disposal plant category where a break even cost analysis was conducted to determine economic feasibility for constructing an on site recovery system. Four examples are presented demonstrating how the break even cost analysis calculations were conducted Table 5 4. Example Cost Calculation Reference List by Plant Category Plant Category Waste Type Baseline ( Pre Rule) Management Post Rule Management No. of Plants* Quantity ( tons) Example Cost Calculation Reference On site Recovery 1999 On site Recovery Plants metalbearing waste On site Metal Recovery On site Metal Recovery 175 409,315 Appendix G spent solvents On site Solvent Recovery On site Solvent Recovery 640 160,139 Appendix H Table 5 4. Example Cost Calculation Reference List by Plant Category Plant Category Waste Type Baseline ( Pre Rule) Management Post Rule Management No. of Plants* Quantity ( tons) Example Cost Calculation Reference 5 10 spent acid On site Acid ( Other) Recovery On site Acid ( Other) Recovery 74 249,904 Appendix I 1997 On site Recovery Plants metalbearing waste Off site Hazardous Landfill On site Metal Recovery 33 2,854 Appendix J spent solvent Off site Energy Recovery On site Solvent Recovery 189 8,451 Appendix K spent acid On site Acid Neutralization On site Acid ( Other) Recovery 34 16,312 Appendix L Off site Recovery Within Industry Group ( 4 Digit NAICS Code)

1999 Off site Recovery Plants Within Industry Group metalbearing waste Off site Metal Recovery Off site Metal Recovery 160 25,618 Appendix M spent solvent Off site Solvent Recovery Off site Solvent Recovery 76 28,635 Appendix N spent acid Off site Acid ( Other) Recovery Off site Acid ( Other) Recovery 22 5,183 Appendix O 1997 Off site Recovery Plants Within Industry Group metalbearing waste Off site Hazardous Landfill Off site Metal Recovery 27 229 Appendix P spent solvent Off site Energy Recovery Off site Solvent Recovery 10 4,031 Appendix Q spent acid On site Acid Neutralization Off site Acid ( Other) Recovery 9 245 Appendix R Table 5 4. Example Cost Calculation Reference List by Plant Category Plant Category Waste Type Baseline ( Pre Rule) Management Post Rule Management No. of Plants* Quantity ( tons) Example Cost Calculation Reference 5 11 Shifting from Off site Recovery Outside Industry Group to On site Recovery 1999 Off Site Recovery Plants Outside Industry Group metalbearing waste Off site Metals Recovery On site Metals Recovery 1,244 583,440 Did not prepare an example cost calculation.

spent solvent Off site Energy Recovery On Site Energy Recovery 763 101,778 Appendix S spent acid Off site Acid ( Other) Recovery On Site Acid Recovery 276 69,667 Appendix T Shifting from Disposal to On site Recovery 1999 On Site or Off Site Disposal Plants K061  electric arc furnace dust Off site Stabilization and Subtitle D Landfill ( Envirosource delisting technology) On site Smelting 30 273,208 Appendix U Metal Containing Liquids ( from Printed Circuit Board Industry) On site or Offsite Chemical Precipitation On site Ion Exchange Metals Recovery using MR3 System technology 252 155,354 Did not prepare an example cost calculation.

Spent Catalyst ( from Petroleum Refining Industry) Off site Stabilization and Landfill On site Smelting 75 11,001 Did not prepare an example cost calculation.

K088  spent aluminum potliner Off site Incineration On site Fluoride Recovery using Vortec technology 21 72,547 Appendix V Table 5 4. Example Cost Calculation Reference List by Plant Category Plant Category Waste Type Baseline ( Pre Rule) Management Post Rule Management No. of Plants* Quantity ( tons) Example Cost Calculation Reference 5 12 K062  spent pickle liquor On site or Offsite Chemical Precipitation On site Acid Regeneration 35 269,329 Did not prepare an example cost calculation.

* Some plants are counted more than once because they recover a combination of metal, solvent and/ or other wastes.

5.6 Unit Cost and Cost Function Estimates Metal Recycling ( Secondary Smelting) Costs Offsite Metal Recovery Recycling cost estimates were taken from a previous Agency rulemaking titled Regulatory Impact Analysis of the Final Rule for a 180 Day Accumulation Time for F006 Wastewater Treatment Sludges, November 10, 1999 ( F006 180 Day Accumulation Rule). In that analysis 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. Table 5 5 presents the estimate from the above report for the metal recycling/ recovery 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 Table 5 5 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.

No minimum charge is assumed for transfers of bulk shipments within the same Industry Group ( 4 digit NAICS). 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. Normally, one would assume that a commercial off site facility will have a minimum charge for accepting small quantities of waste for recovery. 11 The estimates of average recycling costs were confirmed by industry contacts ( Jarvis, 1999, Personal Communication, Eritech, North Carolina; Anonymous, 1999, Personal Communication, Sun Glo Pating, Florida ).

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

13 Jarvis, 1999, Personal Communication, Eritech, North Carolina; and Anonymous, 1999, Personal Communication, Dearborn Brass, Texas.

5 13 In the F006 180 Day Accumulation Rule report, 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). 11 In some cases, when the metal value is very high, the charges can be somewhat lower. 12 Minimum charges are at least sometimes avoided when the recycler actually picks up the F006 directly from the generator. 13 Residuals generation from metals recovery were estimated using 1999 BRS data. Waste streams at selected recovery facilities were reviewed by comments, disposal system type, and origin to determine the likely waste streams generated from the recovery operations. Approximately 32 percent of the metals recovery mass was identified as residuals in the 1999 BRS data ( see Appendix W). 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. For metals recovery, approximately 95 percent of the residual waste volume and frequency of waste streams are estimated to be characteristically hazardous with the remaining 5 percent containing listed hazardous wastes which will become nonhazardous post rule.

For purposes of this rule making, a unit cost of $ 316 per ton ( 2002$) was assumed for commercial metals recovery. This unit cost was used as a proxy to estimate the unit cost to recover metals onsite for those who conducted the practice on site in 1997, assuming a 15% profit factor ( i. e., direct cost to recover waste is $ 268 per ton in 2002 dollars). The commercial unit cost is assumed to include all capital and annual expenditures necessary for the metals recovery system. It is assumed that these facilities already have invested a significant amount of capital into recovery units that exist on site ( but were not used in 1999). Metal salvage value was considered separate from the recovery unit cost. 5 14 Table 5 5. Estimated F006 Off site Metals Recycling Costs ( 1993$)

Generator Type No. of Data Points Transport Recycling Average Unit Cost ($/ lb) (+/ st. dev.) Minimum Median Maximum Unit Cost ($/ lb) Average Unit Cost ($/ lb) (+/ st. dev.) Minimum Median Maximum Unit Cost ($/ lb)

Small LQG  small shipment (< 13.2 t/ yr)* 31 0.49 +/ 0.50 0.11 0.27 2.07 0.02 +/ 0.56  1.77 0.07 0.76 Small LQG  large shipment ( 13.2  < 60 t/ yr) 36 0.11 +/ 0.08 0.02 0.08 0.39 0.20 +/ 0.21  0.14 0.18 1.04 Large LQG ( 60 t/ yr or greater) 20 0.06 +/ 0.05 0.02 0.02 0.16 0.17 +/ 0.15 0.01 0.14 0.61 Total 87 0.15 +/ 0.18 0.02 0.09 1.04 0.22 +/ 0.27  0.74 0.18 0.9 * Assumes all facilities are LQGs and ship four 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 (+/ 0.25) and average recycling unit cost is $ 0.26/ lb (+/ 0.36). 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 EPA'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 $ 732.33 per shipment as a minimum cost. Assumed $ 2.64/ each supersack 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. 14MR3 Systems Inc., http:// www. mr3systems. com 5 15 Recovery from Metals Containing Liquids For recovery of metals from metals containing liquids, cost for an ion exchange process for MR3 Systems Inc. 14 recovery process was estimated ( Table 5 6). Company literature provided capital and operation costs of $ 4 million and $ 2 million, respectively, for a 50,000 ton per year facility. The data was scaled using a 0.54 factor for capital and 0.7 factor for operation and maintenance. Capital costs were annualized over 14 years at 7 percent using a capital recovery factor ( CRF) of 0.11435.

Table 5 6. Estimated On site Metal Recovery Costs for Metal Containing Liquids ( 2002$)

Cost Element Annual Expenditure ($/ ton)

Capital Expenditure ( Annualized) 1 $ 1,095* ( Recovered Waste Quantity)^ 0.54 Operation and Maintenance $ 1,027*( Recovered Waste Quantity)^ 0.70 1 Annualized over 14 years at 7 percent interest rate using a CRF of 0.11435.

Primary Electric Arc Furnace Dust Metals Recovery and Stabilization Technologies In 1980, the United States Environmental Protection Agency ( EPA) classified emission control dust and sludge from the primary production of steel in electric arc furnaces as listed hazardous waste K061 ( 40 CFR 261.32), due to the fact that it contains toxic levels of metals such as zinc, iron, lead, cadmium and chromium. Currently, the EPA requires that electric arc furnace ( EAF) dust be disposed of by one of two approved methods: high temperature metals recovery ( HTMR) or stabilization.

HTMR   Horsehead Resources Development Co.: Horsehead Resource Development Co. recycles 330,000 tons of EAF dust per year with a process known as High Temperature Metals Recovery ( HTMR), using a Waelz reduction kiln. The Waelz kiln process is used to enrich the EAF dust to a product with greater than 45% zinc. The zinc oxide material is mixed with reducing agents, such as lime and coke, and heated in the kiln to a point where zinc vapor is formed. The zinc fumes are then carried off with the offgases and collected in dustbags to be sold. Horsehead operates Waelz reduction kilns in Palmerton, PA; Calumet, IL; and Rockwood, TN. In 1988, the EPA stated that this process is the best demonstrated control technology for treating EAF dust.

Stabilization  Envirosource Technologies: Envirosource describes its stabilization technology on its website as follows: " Super Detox ® is a technologically advanced stabilization process which involves a series of complex chemical and physical reactions including oxidation/ reduction; 5 16 metals insolubilization; silicate polymerization and substitution; pozzolonic bonding and solidification which chemically change the metals to their least soluble state and physically immobilize them. The stabilized material, which meets the regulatory standards and exhibits low permeability and high strength properties, can then be treated as a non hazardous material. This patented process, which was developed specifically to treat EAF dust by Bethlehem Steel Corporation, has been perfected and extensively tested by Envirosource during ten years of research and commercial application. The first Super Detox plant was installed eight years ago at Northwestern Steel and Wire Co. in Sterling, Illinois. In June of 1995, the EPA granted a unique multi site delisting for Super Detox. The EPA delisting validates the environmental soundness of the technology and marks the recognition by the regulators of the need for alternatives to HTMR processes such as the Waelz Kiln."

HTMR Technologies Several companies are currently developing or provide HTMR technologies for recovering metals from EAF dust, through laboratory and pilot plant tests. The following paragraphs provide brief descriptions of some of these technologies:

Midrex Direct Reduction Corporation/ Kobe Steel, Ltd.: Midrex's FASTMET process converts steel mill wastes and/ or iron ore fines into metallic direct reduced iron ( DRI) in a rotary hearth furnace ( RHF) using carbon as the reductant. The DRI can be hot briquetted, discharged as hot DRI into transfer containers, cooled if cold DRI is required, or directly charged to a melter for the production of FASTIRON. Midrex's process for the production of FASTIRON is called FASTMELT. In the FASTMELT process, zinc recovery can be accomplished by designing the RHF in a way that minimizes the amount of iron being carried over to the offgas system. The offgas can then be sent through a baghouse, where high zinc content dust ( 70 90%) is produced for sale to zinc processors. The first commercial FASTMET plant was constructed, commissioned and turned over to the client for commercial operation at Nippon Steel's Hirohata Works in Himeji, Hyogo Prefecture, Japan in 2000.

Nucor: Nucor is the nation's largest EAF steel producer, and according to Nucor's vice president of technology, "[ Nucor has] gone with two different processes [ for EAF dust recycling] because there is no process that has really stepped up and demonstrated itself as being clearly the choice for recycling or recovering the constituents in arc furnace dust". The two EAF dust recycling processes that Nucor has employed are currently in the evaluation and comparison stage. Inorganic Recycling Corp has been contracted to recycle 25,000 tons of dust annually at Nucor's flat rolled mill in Hickman, AR. The dust is melted with other ingredients to create ceramic grit that is sold to distributors as a sandblasting abrasive. Nucor has contracted AllMet Technologies to recycle 30,000 tons of dust annually at its Nucor Yamato structurals mill in Blytheville, AR. AllMet blends dust and mill scale to increase the iron content. This mix is briquetted with carbon and fed to a rotary hearth furnace ( RHF), where zinc, lead and cadmium are oxidized and fumed off. Final products include prime western zinc and chloride that can be sold as flux materials to secondary aluminum processors. 5 17 AmeriSteel: AmeriSteel's dust processing facility in Jackson, TN produces DRI and recycles the zinc oxide. At the plant, the EAF dust is blended with coal and put into an RHF, where the crude zinc oxide is separated from the iron. The zinc oxide is captured in a baghouse to be sold, and the remaining iron rich material goes to the mill's melt shop, where it accounts for 1 1 ½ percent of the charge.

Phoenix Environmental Ltd.: Phoenix Environmental Ltd.' s process will convert byproducts from steel and bearing manufacturing, such as EAF dust, metal grindings and scale, into magnetite. The magnetite will be sold as a raw material to manufacturers of blasting media, shingle granules, pigments and colorants for paint and concrete, and filler additives for plastic. During the process, the byproducts will be melted in a reactor with an oxygen enriched atmosphere, and the resulting molten iron oxide will become magnetite. The facility will also recover zinc and lead for resale. Phoenix Environmental Ltd. plans to build a byproduct recycling plant at Timken Co,' s Faircrest steel plant in Canton, OH.

Frame Engineering Co./ Richland Moulded Brick: Richland Moulded Brick in Mansfield, OH began making bricks from EAF dust in early 1998, and can currently recycle 12,000 tons of EAF dust annually. Steel mills are currently paying Richland an average of $ 100/ ton to take their EAF dust. At the plant, the dust and coke are mixed with water, and the mixture is poured into wooden molds. The mixture is then heated for at least 3 days at 1900 º F. Twenty percent of the mixture is driven off as volatile compounds, including zinc, lead, and cadmium. The remaining 80% of the mixture is left for brick. The zinc and lead are recovered and sold to zinc processors. The process typically produces 2,000 tons of zinc oxide annually.

Kawasaki Steel Corp of Japan   Chiba Works Pilot Plant: At Kawasaki Steel Corp's Chiba Works pilot plant, a 5 meter tall dust recycling furnace is used. Coke is loaded through the top of the furnace, and oxygen is blown into the furnace through upper and lower tuyeres. The oxygen combusts in the burning coke to form two ultra high heating zones. A dust injection blower, which is alongside the upper tuyere, sends the EAF dust to the upper heating zone where the dust is superheated at 3000 º C and melted instantly. The molten dust filters down through the layers of burning coke and drops into the lower heating zone for compensative heating. As it travels between heating zones, the molten dust   which is now molten zinc oxide   separates into zinc vapor, molten iron, and molten slag. The molten iron and slag sink to the bottom of the furnace, where the molten iron is then tapped through a skimmer. During this time, the zinc gas and the exhaust gas rise to the top of the furnace. A wet type gas recovery system near the top of the furnace captures the zinc vapor.

HIsmelt Corporation: The HIsmelt process smelts iron ore and coal in a water cooled refractory lined vertical vessel. The resulting hot metal is then used as feed stock for Electric Arc Furnaces or Blast Furnaces. The technology has been implemented at several USA and Australian facilities at production rates of 0.5 to 1.5 million tons per annum. The smelter has been proven effective for accepting a range of iron feed stock including high phosphorus iron ore fines and 1 Bates, Peter and Coad, Andrew, " HIsmelt, The Future in Ironmaking Technology", 4th European Coke & Ironmaking Congress, Paris, June 2000. http:// www. hismelt. com 2 " MR3 Systems Announces Execution of Land Lease for MR3 Taiwan Metals Processing Plant   Reports On Empire Gold Project Progress" SEMISEEKNEWS, January 28, 2003, http:// www. semiseeknews. com/ press_ release4465. htm 5 18 steel plant wastes ( reverts). Steel plant wastes include blast furnace sludges, millscale, and casthouse dust. The HIsmelt process consists of injecting ground ferrous material and coal into a molten iron bath by a nitrogen carrier gas. The contact with the iron bath drives off the carbon ( as carbon monoxide) and hydrogen. The carbon monoxide and hydrogen is post combusted with oxygen by an oxygen enriched hot air blast ( 1200 C). The heated metal is continuously tapped from the hearth; the slag is batch tapped1.

No additional handling of reverts was required for use in the HIsmelt process. For reverts containing lead and zinc ( which include EAF dust), the majority of the zinc and lead partitioned into the dust collected from the process. The dust could be recycled into the smelt reduction vessel to concentrate zinc to a saleable product. No information regarding the direct applicability of the concentration of zinc dust was documented and was only proposed as a potential additional commercial option.

Ion Exchange Technology for Electric Arc Furnace Dust Metals Recovery At least one company has been identified that is currently developing an ion exchange technology that can recover metals from EAF dust.

MR3 Systems Inc.: MR3 Systems Inc. has developed a specialty ion exchange media to remove metals from an aqueous solution. Other companies ( such as US Filter) also provide ion exchange media suitable for reclaiming metals from an aqueous solution; however, MR3 Systems Inc. was the only manufacture, which included a method for bringing metal bearing solids into an aqueous state to pass through the ion exchange media. The separated metals are processed individual into a saleable product ( e. g., zinc sulfate [ ZnSO4. H2] for fertilizer). MR3 Systems Inc. have conducted benchtop tests for the recovery of zinc from electric arc furnace dust ( K061) and operated two metal recovery facilities. A zinc recovery facility from zinc ash was operated in Butte, Montana, facility ( now closed) and an ongoing project at the Grace Gold Mine Complex in Empire, Colorado. The technology is also being used to process metal wastes generated from the electroplating, metal finishing, and printed circuit board industries2. 3Bates, Peter, and Muir, Adrian, Hismelt Low Cost Iron Making", Gorham Conference June 2000, Commercializing New Hot Metal Process  Beyond the Blast Furnace, http:// www. hismelt. com 4Toon, John, " The Cost of Cleaning the Air: Study Shows Permit Application Costs Lower Than Expected   With Key Benefits to Industry", Georgia Tech Research News, September 21, 1999.

5 19 Selected Electric Arc Furnace Dust Metals Recovery Technology The HIsmelt technology was used to represent the current technology commercially available to recover metals from EAF ( K061) wastes. Other HTMR technologies, while potentially applicable, were limited by their current stage of the process development and availability of published cost examples. The HIsmelt technology has published costs for several US and abroad facilities. Though the HIsmelt technology is not specific to the recovery of metal from EAF and was developed as a more cost effective means of smelting iron ore, the technology does lend itself to the recovery of metals from EAF. As developed for large scale iron fabrication, the cost economics for the facilities are generally for larger scale facilities. Future technologies in development as discussed above may mature to a level and be feasible for smaller scale generators, with improved cost economies and size requirements.

The ion exchange system produced by MR3 Systems was not utilized as an EAF recovery method, though the process is less expensive than the HTMR process reviewed. The ion exchange technology is not a method currently approved under Universal Treatment Standards by EPA for treatment of EAF. Limited information regarding the suspension/ leaching of solids into an aqueous form is publicly available. Traditional use of an ion exchange system is for wastes already in aqueous form. Though the MR3 system was not used in this analysis, future development of the system may enable broader us of the ion exchange systems for EAF. An ion exchange system would have the advantages of smaller space requirements, unit expandability, limited or no residuals, and automated systems.

Metal Containing Solids For construction of on site metal recovery systems for solid wastes containing metals ( e. g., EAF), a smelting process used in steel manufacturing was used as a proxy. The smelting process assumed is described as HIsmelt3, a process developed as an lower cost alternative to a traditional blast furnace. Air permitting costs were added to construction and operation and maintenance costs. An air permit is assumed to be renewed every 5 years at a estimated cost of $ 68,8764 ( 2002$); therefore, the application costs were capitalized over five years using a capital recovery factor of 0.24389 assuming a 7 percent interest rate. Additional air monitoring costs for compliance with the permit are estimated at 10% of the original permit application cost ($ 6,888 per year) ( see Table 5 7 for cost equations). 5 20 Table 5 7. Estimated On site Metal Recovery Costs ( 2002$)

Cost Element 1 Annual Expenditure ($/ ton) 3 Capital Expenditure ( Annualized) 2 $ 6,744* ( Recovered Waste Quantity)^ 0.59 + $ 16,798 Operation and Maintenance $ 1,934*( Recovered Waste Quantity)^ 0.78 + $ 6,888 1 Costs inflated from 1999 dollars to 2002 dollars. 2 Annualized over 14 years at 7 percent interest rate using a capital recovery factor ( CRF) of 0.11435. 3 Includes air permit expenditures.

Solvent Recovery ( Distillation) Costs Solvent recycling costs estimates were taken from a U. S. Army Corp of Engineers Public Works Technical Bulletin 200 01 04, dated August 31, 1999 ( USACE Tech Bulletin). The systems reviewed were batch distillation with vacuum systems. Two system capacities, 15 gallons and 55 gallons, are estimated. The capital costs for batch systems including timers, thermal controls, and transfer pumps, are $ 13,283 and $ 25,468, respectively. A one time installation cost is estimated on a per system basis of $ 583. Annual costs include annual labor of 2 hours per batch, power use, water use, and materials. Each system was assumed to run from 2 to 5 batches per week, with a through put of 3.3 to 120 tons of solvent recoverable waste per year. Larger systems are composed of multiple batch units in 15 and 55 gallon increments. Smaller systems would be composed of a 15 gallon batch unit, with fewer batches per year.

Capital costs were annualized using a 10 year life for the equipment at a 7 percent real rate of return. Costs are assumed to be the same for recovery at off site (" sister") facilities owned by the same company within the same industry group.

Residuals generation from solvent recovery were estimated using 1999 BRS data. Waste streams at selected recovery facilities were reviewed by comments, disposal system type, and origin to determine the likely waste streams generated from the recovery operations. Approximately 33 percent of the solvents recovery mass was identified as residuals in the 1999 BRS data ( see Appendix W). The hazardous fraction of the residuals were determined by reviewing the waste codes for the waste streams reporting solvent reclamation. Waste streams reporting characteristic codes were assumed to have residuals that would be characteristically hazardous waste. For solvent recovery, approximately 85 percent of the residual waste volume is estimated to be characteristically hazardous with the remaining 15 percent containing listed hazardous wastes which will become nonhazardous post rule. 5Toon, John, " The Cost of Cleaning the Air: Study Shows Permit Application Costs Lower Than Expected   With Key Benefits to Industry", GeorgiaTech Research News, September 21, 1999.

5 21 Air permitting costs were added to construction and operation and maintenance costs. An air permit is assumed to be renewed every 5 years at a estimated cost of $ 68,8765 ( 2002$); therefore, the application costs were capitalized using a capital recovery factor of 0.24389 using a 7 percent interest rate. Additional air monitoring costs for compliance with the permit are estimated at 10% of the original permit application cost ($ 6,888 per year).

Commercial off site solvent recovery costs were developed using U. S. Army Corp of Engineers Public Works Technical Bulletin 200 01 04, dated August 31, 1999 ( USACE Tech Bulletin). Recovery costs include handling and transportation of the solvent waste stream. The estimate is a service contract with one recovery facility for annual management of 1,000 gallons at a cost of $ 4.23 per gallon.

Table 5 8. Estimated Solvent Distillation On site Recovery Costs ( 2002$)

Cost Element 1 Annual Expenditure ($/ ton) 3 Capital Expenditure ( Annualized) 2 $ 44.62* ( Recovered Waste Quantity) + $ 18,456 Operation and Maintenance $ 5,519*( Recovered Waste Quantity)^ 0.45 + $ 6,888 1 Costs inflated from 1999 dollars to 2002 dollars. 2 Annualized over 10 years at 7 percent interest rate using a capital recovery factor ( CRF) of 0.14238. 3 Includes air permit expenditures.

Acid Regeneration Estimates of on site acid recovery system costs were taken from the Pilot of the Pollution Prevention Technology Application Analysis Template Utilizing Acid Recovery System prepared by Zero Discharge Technologies, Inc for the USEPA  New England, dated October 1999. A capital cost of roughly $ 17,500 to $ 31,800 for recovery systems sized at 20 and 65 gallons per day ( gpd) were utilized for this estimate. 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. 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.

Capital costs were annualized using a 10 year life for the equipment at a 7 percent real rate of return. Costs are assumed to be the same for recovery at off site (" sister") facilities owned by the same company within the same industry group. 5 22 Residuals generation from acid regeneration were estimated using 1999 BRS data. Waste streams at selected recovery facilities were reviewed by comments, disposal system type, and origin to determine the likely waste streams generated from the recovery operations. Approximately 26 percent of the acid regeneration mass was identified as residuals in the 1999 BRS data. The hazardous fraction of the residuals were determined by reviewing the waste codes for the waste streams reporting solvent reclamation. Waste streams reporting characteristic codes were assumed to have residuals that would be characteristically hazardous waste. For acid regeneration, approximately 75 percent of the residual waste volume is estimated to be characteristically hazardous with the remaining 25 percent containing listed hazardous waste subsequently becoming nonhazardous post rule.

Commercial off site 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  New England, dated October 1999. Commercial off site acid recovery was estimated using the system capital cost and operation and maintenance costs curves with an additional 30 percent for commercial profit. A range of facility sizes for offsite recovery facilities was estimated using 1999 BRS data. Acid recovery facilities were identified using the offsite EPA 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 $ 170 per ton. 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 $ 154 tons per year. Commercial off site recovery unit costs do not include transportation and handling.

Table 5 9. Estimated Acid Regeneration On site Recovery Costs ( 2002$)

Cost Element 1 Annual Expenditure ($/ ton)

Capital Expenditure ( Annualized) 2 $ 79.50* ( Recovered Waste Quantity) + $ 1,804 Operation and Maintenance $ 29.07* ( Recovered Waste Quantity) + $ 1,320 1 Costs inflated from 1999 dollars to 2002 dollars. 2 Annualized over 10 years at 7 percent interest rate using a CRF of 0.14238.

Landfill Costs 2000 unit costs reported in Environmental Cost Handling Operations and Solutions ( ECHOS), Environmental Remediation Cost Data Unit Price, 4th Annual Edition, published by R. S. Means and Delta Technologies Group, Inc., 2001 were used to estimate Subtitle C and Subtitle D commercial landfill disposal costs. The cost reported in ECHOS was $ 304 per ton for bulk hazardous waste with stabilization. These costs were inflated to 2002 dollars ($ 320 per ton) for this estimate. Non hazardous disposal was reported as $ 111 per ton in bulk quantities. The January 2002 Landfill Cost Data from the Hazardous Waste Resource Center reports an average 6 Based on a survey of landfill prices conducted between October 2001 and January 2002. 7 Telephone communication with Mr. Earl Finnder, U. S. Filter, October 2001. 8 Bagsarian, Tom Ed. " Cashing in on steelmaking byproducts", New Steel March 1999, http:// www. newsteel. com/ features/ NS9903f2. htm 9 MR3 Systems Inc., http:// www. mr3systems. com 5 23 cost of $ 159 per ton for bulk hazardous waste disposal with treatment at a commercial landfill. 6 Earl Finnder of U. S. Filter estimated that electroplaters pay approximately $ 260 to $ 300 per ton for Subtitle C landfill disposal. 7 The ECHOS unit cost was used as an average disposal cost for hazardous waste. The ECHOS disposal cost for Hazardous and non hazardous wastes is presented as a 30 city average of major cities across the United States. The landfill disposal costs assumed under baseline are presented below. ECHOS also lists the following minimum charge for bulk shipments to commercial landfill with stabilization of $ 2,246. 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.

Electric arc furnace emission control dust ( EAF)  K061 waste is disposed by at an Envirosource using a stabilization technology called Super Detox ® . The technology is further described above under the Metal Recycling ( Secondary Smelting) Costs heading. Estimates for disposal of EAF range from $ 100 to $ 1758 to $ 150 to $ 2009 per ton. A mid point ($ 150 per ton) was selected for the disposal cost and inflated to 2002 dollars ($ 153.42 per ton) from 1999 dollars for this estimate.

Table 5 10. Subtitle C and D Landfill Unit Costs ( 2002$) Cost Element 1 ($/ ton) Subtitle C Landfill with Stabilization $ 320/ ton $ 2,246 minimum charge Subtitle D Landfill $ 111/ ton ECD Disposal ( Super Detox ® ) $ 153.42/ ton 1 Costs inflated from 1999 dollars to 2002 dollars.

Acid Neutralization Costs Acid neutralization costs were developed from the Remedial Action Cost Engineering and Requirements ( RACER) cost estimating software; costs in this software are based on the 2001 Environmental Cost Handling Options and Solutions ( ECHOS) cost database. Systems estimated ranged from 10 to 50 gallons per minute ( gpm), with a throughput of 5,890 to 29,430 tons per year. Capital costs ranged from $ 42,700 to $ 110,500, with annual operation costs ranging from $ 28,700 to $ 83,600 per year. No residual was assumed to be generated; all wastewater is disposed into the wastewater sewer to the POTW.

Capital costs were annualized using a 10 year life for the equipment at a 7 percent real rate of return. 10 EPA's Common Sense Initiative Report indicates a 15 tons per truck load size and ECHOS 2001 indicates a maximum truck load size of 18 tons. RACER indicates a tanker truck capacity of 5,000 gallons.

5 24 Table 5 11. Estimated On site Acid Neutralization Costs ( 2002$)

Annual Expenditure ($/ ton)

Capital Expenditure ( Annualized) 1 $ 0.41*( Waste Stream Quantity) + $ 3,233 Operation and Maintenance $ 2.85*( Waste Stream Quantity + $ 15,600 1 Annualized over 10 years at 7 percent interest rate using a CRF of 0.14238.

Unit costs for commercial off site acid disposal unit cost were estimated using RACER cost estimating software. RACER lists costs for disposing of liquid wastes ranging from $ 1.50 to $ 3.50 per gallon ($ 2002). A unit cost of $ 1.50 per gallon was used for commercial off site disposal. For loads less than 60 percent full, an added charge of 15 percent of the unit cost was added ($ 1.50 * 1.15 = $ 1.73 per gallon) to account for minimum charges.

Loading/ Handling Cost for loading/ handling waste streams and residuals disposed off site were estimated based on costs reported in RACER 2002. 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 rolloff 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 unit costs are estimated to be $ 2.57 per ton, $ 26.23 per ton, and $ 40.94 per ton, respectively.

Transportation Costs Hazardous waste transportation costs ( excluding manifesting costs which are estimated separately) were estimated based on unit costs reported in ECHOS 2001 and RACER cost estimating software for van trailers and tanker trucks ( Table 5 12). Costs are based on distance and maximum truck load size of 18 tons for van trailers and 5,000 gallons for tanker trucks. 10 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 product recovery 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 ECHOS minimum shipment fee of $ 714 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 ($ 714/ 100 miles = $ 7.14/ mile). 5 25 Transportation costs are presented below. Tables 5 13A and 5 13B presents how shipping distances vary when shipping to Subtitle C landfills ( 338 mile average) compared to product recovery facilities ( 521 mile average). The distances presented reflect estimates for shipments of F006 wastes from the EPA draft report, Evaluation of Cost and Economic Impacts of F006 Recycling Rulemaking Options from December 2001 for landfill and metals recovery facilities were utilized as a proxy for the transportation distances within the same Industry Group ( 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 ECHOS 2001. Costs are based on distance and maximum load size of 18 tons. Due to the relatively close transportation distances estimated for Subtitle D landfills, a unit cost of $ 2.16 per mile ($ 0.12 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 product recovery, 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.

Table 5 12. Transportation Unit Costs ( 2002$) 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 $ 2.50/ ton $ 713/ shipment $ 2.60/ mile $ 2.36/ mile $ 2.15/ mile $ 2.05/ mile $ 2.01/ mile $ 1.94/ mile $ 1.94/ mile $ 1.94/ mile $ 1.90/ mile $ 2.16/ mile $ 40.94/ ton $ 1,032/ shipment $ 3.69/ mile $ 3.19/ mile $ 3.26/ mile $ 3.35/ mile $ 3.15/ mile $ 3.08/ mile $ 3.05/ mile $ 3.02/ mile $ 2.99/ mile POTW discharge Weighted transportation costs are presented in Tables 5 13A and 5 13B. The weighted average transportation unit cost to Subtitle C landfill is $ 3.73/ mile and the weighted average distance is 338 miles. The weighted average transportation unit cost to a recovery facility is $ 6.20/ mile and the weighted average distance is 521 miles. The assumed average transportation unit cost to a Subtitle D landfill is $ 2.16/ mile and an average distance of 50 miles. The assumed average transportation unit cost to a fuel blending facility is $ 2.94/ mile and an average distance of 577 miles. The assumed average transportation unit cost to an acid recovery/ acid neutralization is $ 3.50/ mile and an average distance of 405 miles. The assumed average transportation unit cost to 5 26 a catalyst recovery facility is $ 3.73/ mile and an average distance of 338 miles. The assumed average transportation unit cost to an incinerator is $ 3.73/ mile and an average distance of 1,000 miles. The estimates for metals recovery distances from facilities identified in the EPA, Evaluation of Cost and Economic Impacts of F006 Recycling Rulemaking Options from December 2001 were used to model product recovery and Subtitle C landfill distances.

Transportation distances for fuel blending, and acid recovery/ acid neutralization were determined after review of 1999 BRS 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 the state, the transportation distribution was skewed to the 250 and 350 mile ranges. For waste streams with facilities tending to ship outside the state, the transportation distribution was skewed to distances between 450 and 650 miles. A 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 BRS data, no incineration managed waste streams were shipped within the state.

Table 5 13A. Weighted Average Transportation Unit Costs to Subtitle C Landfills for SIC 3471 Generators ( 2002$)

Percentile (%) Distance to Landfill or Stabilization for Top 95 Percent of Waste Shipped ( miles, n = 75) Average Distance per 10th Percentile ( miles) Weighted Distance to Subtitle C Landfill ( miles) Unit Price ($/ mile) Weighted Unit Price ($/ mile)

0 38

10 129 83.5 8.35 $ 8.55 $ 0.855 20 147 138 13.8 $ 5.17 $ 0.517 30 166 156.5 15.65 $ 4.56 $ 0.456 40 175 170.5 17.05 $ 4.19 $ 0.419 50 234 204.5 20.45 $ 2.60 $ 0.260 60 283 258.5 25.85 $ 2.60 $ 0.260 70 348 315.5 31.55 $ 2.36 $ 0.236 80 434 391 39.1 $ 2.36 $ 0.236 90 636 535 53.5 $ 2.05 $ 0.205 100 1627 1,131.5 113.15 $ 1.90 $ 0.190 Table 5 13A. Weighted Average Transportation Unit Costs to Subtitle C Landfills for SIC 3471 Generators ( 2002$)

Percentile (%) Distance to Landfill or Stabilization for Top 95 Percent of Waste Shipped ( miles, n = 75) Average Distance per 10th Percentile ( miles) Weighted Distance to Subtitle C Landfill ( miles) Unit Price ($/ mile) Weighted Unit Price ($/ mile)

5 27 Total 338.45 $ 3.63 ($ 3.73) 1 1 Costs inflated from 2000 dollars to 2002 dollars.

Table 5 13B. Weighted Average Transportation Unit Costs to Metals Recovery ( Secondary Smelting) for SIC 3471 Generators1 ( 2002$)

Percentile (%) Distance to Metals Recovery Facilities for Top 95 Percent of Waste Shipped ( miles, n = 51) Average Distance per 10th Percentile ( miles) Weighted Distance to Metals Recovery ( miles) Unit Price ($/ mile) Weighted Unit Price ($/ mile)

0 7

10 32 19.5 1.95 $ 36.62 $ 3.662 20 193 112.5 11.25 $ 6.35 $ 0.635 30 231 212 21.2 $ 2.60 $ 0.260 40 329 280 28.0 $ 2.60 $ 0.260 50 372 350.5 35.05 $ 2.36 $ 0.236 60 481 427 42.7 $ 2.15 $ 0.215 70 567 524 52.4 $ 2.05 $ 0.205 80 846 706.5 70.65 $ 1.94 $ 0.194 90 1,253 1,049.5 104.95 $ 1.90 $ 0.190 100 1,802 1,527.5 152.75 $ 1.90 $ 0.190 Total 520.9 $ 6.05 ($ 6.20) 2 1 These values were used as a proxy for same Industry Group ( 4 digit NAICS) product recovery distances and transportation unit costs. 2 Costs inflated from 2000 dollars to 2002 dollars. 5 28 Manifesting Costs 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 obtained from the Hazardous Waste Manifest Cost Benefit Analysis, prepared by Logistics Management Institute in October 2000. Costs were inflated to 2002 dollars. The manifesting cost incurred by the generator per manifest was determined to be $ 89.31 for small quantity generators and $ 136.91 for large quantity generators. An average cost of $ 113.11 ($ 116.05 inflated to 2002$) per manifest was assumed to be incurred by the generator. The transporter is assumed to incur $ 117.35 ($ 120.40 inflated to 2002$) in manifesting costs per shipment. The transporter and generator costs were combined to estimate a total manifesting cost per shipment of $ 236 ( 2002$).

Costs also have been estimated for shipping papers under a reclamation agreement. Costs to prepare, carry, and retain shipping papers were obtained from the Hazardous Waste Manifest Cost Benefit Analysis. The cost for the generator to complete the shipping papers for each load is estimated to be $ 26.50, based on assumed effort of 0.5 hours by a technical staff member at $ 53 per hour. The cost for the generator to maintain a copy of the reclamation agreement is $ 2.70 per year. Assuming an average of 4 shipments per transporter per year, the cost per shipment for the generator to retain the reclamation agreement is approximately $ 0.68 per shipment. The cost for the transporter to record and carry the shipping papers and reclamation agreement is estimated at $ 58.53 per shipment. An additional $ 4.59 was assumed to be incurred by the transporter to retain the records for each generator. Assuming an average of 4 shipments per generator for each transporter a year, the cost per shipment for the transporter to retain the records for each generator is approximately $ 1.15. The transporter and generator costs were combined to estimate a total cost to prepare, carry and retain shipping papers of $ 86.86 per shipment ($ 89.26 inflated to 2002$). All pre rule scenario shipments were assumed to require hazardous waste manifests ( including same NAICS recovery transportation shipments). Post rule shipments are all assumed to require non hazardous manifesting, 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).

Training Training includes costs for manifesting and hazardous materials handling training. These costs are assumed to be incurred for all large and small quantity generators. Facilities classified as conditionally exempt small quantity generators 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. Conditionally exempt small quantity generators were excluded from hazardous materials handling training as described in 40 CFR 262.16 Subpart B. The hazardous materials handling training requirements for small and large quantity generators include on the job training for emergency response requirements and inspection of the facilities emergency response equipment. 5 29 Manifest training is estimated to cost $ 1,828 per year ( 2002$). Training costs include an estimated 8 hours per year each for a process technician and a manager. Each year, 3 hours is devoted to review/ refresher of the training, 1 hour for administrative requirements associated with the training ( updating records, refresher/ new class scheduling, etc.), and annual turn over for the position occurring once every two years resulting in 4 hours per year devoted to training. A manual/ class training is estimated to cost $ 125 based on current pricing for the training services from on line providers.

Hazardous materials handling training is estimated to cost $ 2,191 per year for small quantity generators ( 2002$) and $ 9,974 per year for large quantity generators ( 2002$). Training costs for small quantity generators include an estimated 8 hours per year each for a process technician and a manager. Training costs for large quantity generators include an estimated 8 hours per year each for four process technicians, a manager, and a branch manager. Each year, 3 hours is devoted for review or refresher training, 1 hour for administrative requirements associated with the training ( updating records, refresher/ new class scheduling, etc.), and annual turn over for the position occurring once every two years resulting in 4 hours per year devoted to training. All training is assumed to be on the job and provided by the managers.

Contingency Planning Costs This cost covers the requirements as stated in 40 CFR 264 Subpart D relating to the development of a contingency plan. The estimated basis was taken from the Estimating Costs for the Economic Benefits of RCRA Noncompliance, prepared for the Office of Regulatory Enforcement, USEPA, dated September 1994. The labor rates were updated to 2001 using RACER costs estimating software. Facilities generating more than 1,000 kilograms per month of hazardous waste ( i. e., Large Quantity Generators) are required to prepare and maintain a contingency plan. The cost includes labor for a drafter ( 3 hours), process technician ( 11 hours), an engineer ( 16 hours), and a manager ( 3 hours), for a total expense of $ 2,800 ( 2002$). This cost is incurred once. Costs incurred from updating the contingency plan is included in the BRS/ General Administrative Duties Cost.

Table 5 14. Estimated Contingency Planning Costs ( 2002$)

Labor Class: Labor Rate ($/ hour) Estimated Utilization ( hrs) Labor Cost 1 Drafter $ 78.36 3 $ 235.08 Process Technician $ 61.02 11 $ 671.22 Engineer $ 89.61 16 $ 1,433.76 Manager $ 151.89 3 $ 455.67 Total 33 $ 2,795.73 1 Costs inflated to 2002$. 11 MR3 Systems Inc., http:// www. mr3systms. com/ pages/ corp2. html 12London Metals Exchange, http:// www. lme. co. uk/ data_ prices/ monthly_ prices. asp, dated July 19th, 2003 13London Metals Exchange, http:// www. lme. co. uk/ data_ prices/ monthly_ prices. asp, dated July 19th, 2003 14 Coplan, Myron J, C. E., " Comments on the Relative Cost of Fluoride from NAF and FSA", http:// www. dartmouth. edu/~ rmasters/ AHABS/ costof. html 15 http:// www. micronmetals. com/ molybdenum_ disulfide. htm 5 30 Salvage ( Recovered Product) Value of Recovery Products Salvage value of recovered products was estimated based on cost savings ( i. e., reduced quantity of solvent or acid purchase) or a secondary sale ( i. e., sale of recovered metals). A salvage value/ revenue is estimated using the commercial market value of the product ( solvent, acid, granular activated carbon, fluoride, catalyst, or metal). The metal salvage value ( unless otherwise indicated) is based on $ 5,300/ ton, which is the three year average price for chromium, nickel and copper the three most recycled metals. This assumes that of the metal going to recycling, it is split evenly among the three metals. The salvage value for EAF metals is based on zinc recovery. 11 The market value for zinc was estimated using the London Metals Exchange price of $ 714.8/ ton. 12 The salvage value for metal containing liquids is based on copper recovery. The printed circuit board industry ( SIC 3672) is the primary generator of metals containing liquid wastes. The printed circuit board industry uses copper in the etching and plating process; therefore, copper is assumed to be the primary metal recovered from the metals containing liquid wastes. The market value for copper was estimated using the London Metals Exchange price of $ 1,552.60/ ton. 13 The salvage value for solvent was estimated using the average price as reported in the USACE Tech Bulletin of mineral spirits at $ 2.25/ gallon and 1,1,1 trichloroethane at $ 11.33/ gallon. The salvage value for acid and granular activated carbon ( GAC) was estimated with RACER cost estimating software. For acids, sulfuric acid was used as a proxy. Sulfuric acid is estimated to cost $ 331/ ton ( 2002$). GAC is estimated to cost $ 3,845 per ton. The salvage value of fluoride, using sodium fluoride as a proxy, was estimated from an online document at Dartmouth University Comments on the Relative Cost of Fluoride from NAF and FSA. Sodium fluoride is estimated to cost $ 1,240 per ton14 ( 2002$). The salvage value of catalysts was estimated from an online quote15. Molybdenum disulfide was used as a proxy for catalysts reported recovered in the 1999 BRS. Molybdenum disulfide was identified as a catalyst in the comments of disposed quantities of spent catalyst from the petroleum refining industry ( SIC 2911) with waste codes of K171 or K172. Molybdenum disulfide is estimated to cost $ 26,600 per ton ( 2002$).

The recovered products were assumed to be less than " pure". Through the recovery process, a loss of effectiveness for the solvents and acids is expected. For metals recovery, the quality loss is represented by a reduction in purity of the metal. A factor of 90 percent is applied to the above listed commercial cost associated with the product to represent this loss.

The mass recovered varies depending on the type of recovery waste streams. Using select 1999 BRS facility data, the residual mass fractions of solvents and acids recovered from solvent and acid waste streams was estimated. Assuming there are minimal lost products by spillage or 16Bagsarian, Tom Ed. " Cashing in on steelmaking byproducts", New Steel March 1999, http:// www. newsteel. com/ features/ NS9903f2. htm 5 31 evaporation, the mass of the original waste stream ( recovery waste stream) minus the reported residuals waste stream ( i. e., still bottoms, sludge, and wastewater) is the mass of the recovered product. The residual mass fraction is described in the respective recovery technology section. Based on the estimated residual waste mass fraction, the product mass fraction is estimated at 67 percent and 74 percent for solvent and acid product recovery, respectively ( see Appendix W). The product mass fraction is highly dependant on the facility process and recovery technology and may vary greatly from this estimate. The mass fraction recovered from spent catalyst ( waste codes K171 and K172), spent granular activated carbon, fluoride from spent aluminum potliner ( waste code K088), and metals from liquids containing metals were estimated using engineering judgement as to the concentration of the recoverable product from the waste stream, likelihood of destruction during the recovery process and potential of the recovered product to retain useable characteristics. The product mass fractions estimated for spent catalyst ( waste codes K171 and K172), spent granular activated carbon, fluoride from spent aluminum potliner ( waste code K088), electric arc furnace control dust ( ECD) ( waste code K061), and metals from liquids containing metals are 5 percent ( i. e., 5 percent of catalyst is reusable), 90 percent ( i. e., 90 percent of carbon is reusable), 2 percent recovered fluoride values, 15 percent recovered zinc, and 0.02 percent recovered copper.

The mass fraction of metals recovered during smelting/ high temperature metals recovery was estimated using F006 180 Day Accumulation Rule assumptions regarding the quality of the sludge produced from SIC 3471 facilities with the exception of EAF. A mass conservation approach was not utilized for smelting/ high temperature recovery due to the assumed volatilization of the water in the sludge wastes. The metals mass fraction is estimated at 20 percent for wastes currently being recovered. The metals mass fraction is estimated to be five percent for wastes currently being disposed assuming they have lower metals content. A five percent metals concentration is the approximate break even point between the cost of landfill verses metals recovery. Zinc concentration in EAF ranges from 15 to 30 percent16. The zinc concentration is dependant on the grade of iron ore processed and coal used in the smelting process. The other major constituents of EAF include lead and iron. Additional revenue may be generated from the recovery of iron in the HTMR process. The potential revenue from reclaiming the iron in EAF was not estimated for this estimate, given the majority of the recovery technologies for EAF are used to accumulate zinc oxide.

BRS/ General Administrative Duties Cost Biennial reporting as well as other generator recordkeeping and reporting is required for all LQGs. Similar, but less stringent, administrative requirements apply on an annual basis for SQGs. In addition to reporting requirements for hazardous waste generating facilities, review of contingency plans and other miscellaneous actions are also necessary. These costs are assumed to be direct labor costs for one manager with a labor rate of $ 152 per hour. For a CESQG facility 5 32 BRS/ general administrative duties labor is estimated at 4 hours at a cost of $ 608 per year, a SQG facility is estimated at 8 hours at a cost of $ 1,216 per year, and a LQG is estimated at 16 hours at a cost of $ 2,430 per year ( 2002$).

Initial Characterization/ Waste Characterization Cost The estimated cost was taken from the Estimating Costs for the Economic Benefits of RCRA Noncompliance, prepared for the Office of Regulatory Enforcement, USEPA, dated September 1994. The labor rates and analytical costs were updated to 2001 using RACER cost estimating software. The collection of cost includes labor for a field technician ( 10.5 hours), an engineer ( 11 hours), and a manager ( 2 hours). Three samples are collected per waste stream, estimated at $ 1,410 per sample, for a total expense including labor of $ 6,160 per waste stream ( 2002$). This cost is incurred once.

One Time Notification of Exclusion Costs were estimated for generators to complete a notification of RCRA exclusion for their recovered waste( s). Labor rates were obtained from the RACER cost estimating software. The one time notification is assumed to be composed of 6 hours of a staff engineer and 2 hours clerical and cost $ 638.78, including mark ups ( 2002$).

Part B Permit Renewal Costs Savings to within industry off site reclaimers are expected to result from no longer needing to renew their RCRA permits. The maximum duration that a RCRA permit is valid is 10 years; therefore, a TSD facility is required to renew the Part B portion of the permit application a minimum of once every 10 years. The Part B application is composed of the a general facility section and the technology specific section for storage and/ or disposal of the hazardous waste. Facilities reclaiming metals, solvents, or acids on site may not require a TSD permit under the proposed rule making, as these wastes would not be considered solid wastes. Therefore, the facility would not be a RCRA TSD. The facilities effected by the proposed rule making would not need to resubmit the Part B application to renew the TSD permit.

Estimated costs for preparing and renewing the Part B application were presented in the Estimating Costs for the Economic Benefits of RCRA Noncompliance, prepared for the Office of Regulatory Enforcement, USEPA, dated September 1994. The general facility portion of the Part B application estimated cost was $ 43,693 ($ 49,249 inflated to 2002 dollars). The technology specific requirements estimated costs were $ 9,371 ($ 10,562 inflated to 2002 dollars) for container systems and $ 8,780 ($ 9,896 inflated to 2002 dollars) for tank systems.

It is assumed the majority of the Part B application information has already been accumulated in the initial preparation. The update of the Part B application is estimated to cost 25 to 50 percent the original preparation cost. All TSD facilities would be required to submit the general facility 5 33 portion of the Part B application. In general, it is assumed that TSD 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. The estimated savings through not renewing the TSD permit ranges from $ 14,953 to $ 29,906 every 10 years for metal reclaiming facilities. For facilities reclaiming solvents or acids, the estimated savings ranges from $ 14,786 to $ 29,573 every 10 years.

Spent Aluminum Potliner ( K088) Cost Estimates Baseline waste management unit costs are presented in Table 5 15. Following the promulgation of the current K088 land disposal treatment standards in October of 1997 management shifted to three facilities. Two off site facilities include the Reynolds' thermal treatment plant in Gum Springs, Arkansas, and Chem Waste Management's on site storage facility in Gilliam County, Oregon ( near the City of Arlington). One facility, Ormet Primary Aluminum Corporation, Hannibal, Ohio, has installed the Vortec vitrification technology which has been proven to treat to the new land disposal restriction standard the EPA is considering. All text and unit cost estimates contained in this section were taken or edited from the following report: U. S. EPA, Economic Assessment of the Revised LDR Treatment Standards for Spent Aluminum Potliner ( K088), prepared by DPRA Incorporated, March 1, 2000. In the analysis all unit costs were inflated from 1999 dollars to 2002 dollars.

The Vortec process is a direct fired vitrification system that destroys cyanide and other organic compounds contained in K088 waste, while recovering the fluoride values for use. K088 waste is mixed with sand and limestone and vitrified to form a glass like residue or frit. The treatment process does not immobilize the fluoride in the glass matrix, but, it effectively partitions the fluoride into the baghouse dust for reuse.

The process unit performing this vitrification process is referred to as a combustion melting system ( CMS) and consists of a Counter Rotating Vortec ( CRV) Reactor, a cyclone melter and a separator/ reservoir. The finely crushed K088 waste, sand and limestone mixture are preheated in a rapid suspension heating system before physical and chemical melting, which occurs within the cyclone reactor. The reactor is a refractory lined, carbon steel, water cooled vessel. Natural gas and preheated air are used to achieve temperatures of approximately 2,400 F in the reactor. Materials begin to melt in the reactor and flow downward to the cyclone melter. Melting of the waste and other additives, as well as combustion of the cyanide and other organic compounds, is completed in this vessel and the resultant molten glass is separated from the gas. The separated gas is used to preheat the air entering the reactor, and is then sent to a primary baghouse to remove particulate matter, primarily sodium fluoride. The exhaust from the baghouse is then transferred into the potroom " secondary" dry scrubber system ( a baghouse air pollution device using alumina to dry scrub fluoride from aluminum reduction pot exhaust gas) where gaseous fluoride is removed and additional particulate removal occurs. The material from the primary and secondary baghouse systems are fluoride enriched alumina material is collected for reuse ( e. g., charged back into aluminum pots if feasible or sold as a substitute for fluorospar). The molten 17 Personal communication between Elaine Eby, U. S. EPA, and John Reggi, Ormet, December 6, 1999.

5 34 glass is dropped into a water quench tank where it solidifies into a glass like residue or frit which is sold as a product ( e. g., industrial grade glass). This process is referred to as K088 vitrification.

Currently, only the Ormet facility in Ohio operates a 50 ton per day Vortec system. The baghouse dust containing fluoride is sold to the steel industry as a substitute for fluorospar. The frit, a granular glass like material, that they generate is presently sold as a grinding and polishing material to a machinery shop. 17 Ormet generates approximately 6,500 short tons of frit annually.

TABLE 5 15. K088 BASELINE MANAGEMENT AND ANALYTICAL UNIT COSTS Baseline Management Method Baseline Unit Cost ( 1999 $/ ton)

Off Site Thermal Treatment ( Reynolds, Gum Springs, Arkansas) $ 200  $ 500 1 Off Site Storage ( Chem Waste Management, Gilliam County, Oregon) $ 245 2 treatment = $ 80 disposal = $ 80 storage = $ 85 1 Federal Register, Volume 63, Number 185, September 24, 1998, pp. 51260; 1994 price quote. Price quote still valid based on communication between Linda Barr, U. S. EPA, Office of Solid Waste and Reynolds in 1999. 2 Federal Register, Volume 63, Number 185, September 24, 1998, pp. 51260; 1998 price quote.

Table 5 16 presents the estimated compliance management unit costs. Crusher and hammer mill unit costs were developed by scaling vendor cost estimates received from Nordberg, Inc. assuming a 7 percent interest rate on borrowed capital, a 7 percent discount rate ( consistent with OMB Circular No. A 94, October, 1992), 10 year equipment life, 20 year plant life, and a 30 percent profit margin. The Vortec technology is the only proven technology that can meet possible the new Land Disposal Treatment standards the Agency has been considering. So, it is assumed that facilities will install this technology.

One 36 ton per day plant using the Vortec technology has been constructed in Paducah, Kentucky, in 1996 for the DOE at a cost $ 11.6 million. Assuming operating costs of between $ 150  $ 300/ ton similar to the NHW vitrification system, a 7 percent interest rate on borrowed capital, a 7 percent discount rate, 20 year equipment life, 20 year plant life, 3 percent annual inflation, 30 percent profit margin, an initial licensing fee of $ 200,000 and an annual licensing fee equivalent to 10% of annual cost savings ( assumed to be annual quantity of waste times $ 300/ ton to treat waste) over a 10 year period, the unit commercial ( off site) price would range between $ 483/ ton and $ 693/ ton ( excluding permitting) for a 36 ton per day Vortec system, including a jaw crusher, impact mill and hammer mill. 5 35 For comparison purposes, it is assumed that vitrification and incineration vendors have similar cost structures to the Vortec technology if costs for additional crushers and mills are added to account for the cost of reducing the K088 blocks of waste ( e. g., potentially up to 3 feet in length) to sizes that can be fed into the Vortec technology. Therefore, published commercial prices for vitrification ($ 300/ ton) and incineration ($ 650/ ton) were used as potential price ceilings for the Vortec technology in the market when new capacity is constructed. Estimates of commercial crushing ($ 18/ ton to $ 26/ ton depending on equipment size) and milling ($ 30/ ton to $ 43/ ton depending on equipment size) prices are added to the vitrification and incineration prices to determine the total compliance management unit cost. Assuming two crushing units, one hammer mill, and a vitrification unit, commercial prices range from $ 366/ ton to $ 395/ ton, excluding transportation. Similarly, assuming two crushing units, one hammer mill, and an incineration unit, commercial prices range from $ 716/ ton to $ 745/ ton, excluding transportation.

TABLE 5 16. K088 COMPLIANCE MANAGEMENT UNIT COSTS Compliance Management Method Compliance Unit Cost ( 1999 $/ ton)

Crushers ( assume one of each unit)( estimated commercial price): 1  30" x 42" jaw crusher ( 150 hp motor) 1 1  78" x 40" impact mill ( 150 hp motor) 1 Same unit price per unit: 5 5,000 tpy = $ 26/ ton/ unit 10,000 tpy = $ 24/ ton/ unit 30,000 tpy = $ 21/ ton/ unit 55,000 tpy = $ 19/ ton/ unit 85,000 tpy = $ 18/ ton/ unit Hammer Mill ( 10,000 tons/ year; + 200 mesh to 1" initial size) Price per unit: 5 5,000 tpy = $ 43/ ton 10,000 tpy = $ 39/ ton 30,000 tpy = $ 34/ ton 55,000 tpy = $ 31/ ton 85,000 tpy = $ 30/ ton Off site Vitrification ( ground solid)

ECHOS ( in situ soil vitrification) 7 NHW Vitrification System ( 3,000 tons/ year) 2 Capital Costs ($ 1,000,000) Operating Costs ($ 150/ ton  $ 300/ ton) GeoMelt Vitrification 4 assume $ 300/ ton $ 300/ ton $ 240  $ 430/ ton 3 $ 370  $ 420/ ton Off site Incineration ( ground solid) $ 650/ ton 6 to $ 1,300/ ton 7 On site Vortec Technology ( estimated cost for noncommercial crusher, impact mill and hammer mill added into unit cost): Capital: $ 11,600,000 for 36 ton of soil/ day facility ($ 1996) 8 License Agreement: $ 5 to $ 10 million/ municipal ash facility, size unspecified 9 Price per unit ( example sizes): 10 1,000 tpy = $ 499/ ton 3,000 tpy = $ 409/ ton 5,000 tpy = $ 414/ ton 7,000 tpy = $ 437/ ton 10,000 tpy = $ 485/ ton TABLE 5 16. K088 COMPLIANCE MANAGEMENT UNIT COSTS Compliance Management Method Compliance Unit Cost ( 1999 $/ ton)

5 36 Incinerator RCRA/ MACT Permit ( assumed similar to the cost of permitting the Vortec process): Initial Permit Renewal of Permit ( every 10 years) $ 350,000/ facility 11 $ 130,000/ facility/ 10 years 11 1 Reynolds Metals Company Spent Potliner Treatment Plant, http:// www. rmc. com/ gbu/ metals/ gum_ spr. html. 2 NHW Home Page, http:// www. qn. net/~ nhw/ nhwtoc. html. 3 Annualized capital cost were estimated using a capital recovery factor based on a 7 percent real interest rate on borrowed capital, a 7 percent real discount rate, a 20 year operating life, and assuming a 30 percent profit margin. 4 GeoMelt Comparison with Alternative Technology Types, http:// www. geomelt. com/ geomeltnf_ comparison_ with_ alternat. htm. 5 EPA derived cost based on scaling of vendor quotes from Nordberg. Inc.. Assumed a plant life of 20 years ( equipment life of 10 years) and a 30 percent profit margin for commercial operation. 6 Per communication with author of Environmental Cost Handling Options and Solutions ( ECHOS), Environmental Remediation Cost Data Unit Price, 5th Annual Edition, published by R. S. Means, 1999, average unit cost of $ 1,300/ ton is skewed given conservative unit price quotes received from commercial incinerators. $ 650/ ton is more reasonable unit price estimate if outliers removed from average. 7 Environmental Cost Handling Options and Solutions ( ECHOS), Environmental Remediation Cost Data Unit Price, 5th Annual Edition, published by R. S. Means, 1999. 8 Vortec, http:// www. vortec cms. com/ paducah. htm 9 " Montgomery County Green Technology News Clips", Louis S. Hansen, Philadelphia Inquirer, July 22, 1996; http:// www. ehb. state. pa. us/ dep/ counties/ Montgomery/ Green_ Technology_ News. htm. Vortec licensed its technology to Japan's Mitsubishi Kasei Engineering Co. for treatment of municipal incinerator ash with the agreement bringing Vortec between $ 5 and $ 10 million for each plant built. 10 One 36 tons of soil per day plant has been constructed in Paducah, Kentucky, in 1996 for the DOE at a cost $ 11.6 million. EPA scaled capital costs using a scaling factor of 0.6. EPA assumed operating costs at the high end of the $ 150  $ 300/ ton range estimated for the NHW vitrification system. EPA scaled operating costs using a scaling factor of 0.9. EPA assumed a 7 percent real interest rate on borrowed capital, a 7 percent discount rate, 20 year equipment life, 20 year plant life, and 3 percent annual inflation. EPA assumed an initial licensing fee of $ 200,000 and an annual licensing fee equivalent to 10% of annual cost savings ( assumed to be annual quantity of waste times $ 300/ ton to treat waste) over a 10 year period. Estimate includes 40 percent excess capacity for Vortec Combustion Melting System. Cost estimates for a crusher, impact mill, and hammer mill are included. 11 EPA, Office of Solid Waste, Cost and Economic Impact Analysis of Listing Hazardous Wastes from the Petroleum Refining Industry, prepared by DPRA Incorporated, September 21, 1995. The 1992 cost estimates were inflated to 1999 dollars assuming a 4 percent annual rate of inflation. 5 37 Commercial Incineration Incineration unit costs were estimated using RACER cost estimating software. RACER reports incineration costs of $ 827.38 per cubic yard of bulk material. A unit weight of 1.5 tons per cubic yards was assumed, resulting in an unit cost of $ 552 per ton. The incineration unit cost includes management and disposal of residuals. For loads less than 60 percent full, an added charge of 15 percent of the unit cost was added ($ 827.38 * 1.15 = $ 951.49 per cubic yard) to account for minimum charges.

Energy Recovery ( Fuel Blending)

Energy recovery costs were reviewed from several sources. The U. S. Environmental Protection Agency Office of Solid Waste, Economics, Methods and Risk Analysis Division Unit Cost Compendium ( UCC) reported offsite utility co burning costs of $ 149/ ton ($ 142 escalated to 2002$) and offsite cement kiln costs of $ 497/ ton ($ 473 escalated to 2002$). Solvent disposal costs ( assumed to be a energy recovery process) from the USACE Tech Bulletin reported a cost of $ 173/ ton ($ 160 escalated to 2002$). An offsite energy recovery cost of $ 292/ ton was estimated as a reasonable approximation of the differing types of energy recovery facilities. The unit cost is a processing fee (" tipping") and does not include transportation, handling, or any other costs.

Chemical Precipitation Chemical precipitation costs were estimated using the UCC. Systems estimated ranged from 5 to 100 gallons per minute ( gpm), with a throughput of 2,445 to 58,960 tons per year. Pickle liquor was used as a proxy for waste characteristics in estimating costs for the system. The estimated costs do no include residual management. Capital costs were annualized using a 10 year life for the equipment at a 7 percent real rate of return.

Table 5 17. Estimated On site Chemical Precipitation Costs ( 2002$)

Annual Expenditure ($/ ton)

Capital Expenditure ( Annualized) 1 $ 32.37*( Waste Stream Quantity) + $ 33,553 Operation and Maintenance $ 204.83*( Waste Stream Quantity) + $ 21,766 1 Annualized over 10 years at 7 percent interest rate using a CRF of 0.14238.

Carbon Regeneration Off site carbon regeneration (" roasting") costs were estimated using RACER cost estimating software. RACER reports a unit cost of $ 0.85 per pound for masses less than 2,000 pounds, and $ 0.39 per pound for masses greater than 2,000 pounds. 5 38 On site carbon regeneration costs were estimated using off site unit costs. Profit, estimated at 15 percent, was subtracted from the unit cost. A scale factor of 0.83 is used to represent economies of scale. A range of facility sizes for off site carbon regeneration facilities was estimated using 1999 BRS data. Carbon regeneration facilities were identified using the offsite EPA ID ( receiver) of waste streams with the reported management system of " other recovery" ( M125). The average carbon regeneration facility size is 100 tons per year, with the largest receiver facility accepting 493 tons in 1999. A facility size of 100 tons per year is estimated to have an carbon regeneration cost of $ 655 per ton.

5.7 Summary of Breakeven Analysis A comparison of base line management practices with the on site compliance management option for offsite disposal facilities and off site recovery facilities with different NAICS is presented in Table 5 18. The breakeven analysis reflects the effect of the salvage value of the recovered products. In general, products with high salvage value reduced the facility size required for a cost savings from constructing an on site recovery process.

The breakeven analysis considered all elements of the waste disposal or recovery process, including residual/ waste stream disposal, recovery costs, waste characterization, manifesting, loading, transportation, salvage revenue, training, BRS and general administrative duties, contingency planning, and generation taxes. However, the generator size was assumed to remain constant. Additional cost benefit will be generated with the reduction in generator status in the post rule environment ( i. e., generator status drop from LQG to SQG or CESQG). These cost savings will include reductions in hazardous materials training, BRS and general administrative duties, contingency planning, and generation taxes.

Recovery of spent carbon is shown to be profitable at all size facilities in the proposed rule making, as are many catalyst recovery facilities. However, profitability of spent carbon recovery processes may be the result of economic pressures such as an abundance of spent carbon recovery facilities or manufacturing of activated carbon is more expensive than recovering spent activated carbon. 5 39 Table 5 18. Breakeven Point ( tons/ year) Where On Site Recovery is More Economical than Offsite or On site Disposal ( 2002$)

Waste Type Baseline Management Compliance Management Breakeven ( tons/ year)

Off site Disposal Wastes Organic Liquids ( from Industrial Organic Chemicals, Paints and Allied Products, Pharmaceutical Preparations, and Plastics Materials and Resins Industries) Off site Fuel Blending On site Fractionation/ Distillation 47 Emission Control Dust ( from Steel Works Industry) Stabilization and Subtitle D Landfill On site Smelting 47,067 Metal Containing Liquids ( from Printed Circuit Board Industry) Off site Chemical Precipitation On site Ion Exchange 125 ( 79 for onsite

Electroplating Wastewater Treatment Sludges ( from Printed Circuit Board Industry) Stabilization and Landfill On site Smelting 3,443 Spent Carbon ( from Industrial Organic Chemicals and Petroleum Refining Industries) Off site Incineration or Carbon Regeneration1 On site Carbon Regeneration: " Roasting" 0 Spent Catalyst ( from Petroleum Refining Industry) Stabilization and Landfill On site Smelting 11 Spent Aluminum Potliner ( from Aluminum Industry) Off site Incineration On site Fluoride Recovery using Vortec technology 347 Spent Pickle Liquor ( from Steel Works Industry) Off site Chemical Precipitation On site Acid Regeneration 4,311 ( 0 for on site)

Offsite Recovery at NON same NAICS Facilities Metal Recovery Wastes Off site Smelting On site Smelting 21,587 Solvent Recovery Wastes Off site Solvent Recovery On site Fractionation/ Distillation 125 Acid Recovery Wastes Off site Acid Regeneration On site Acid Regeneration 36 1 Costs inflated to 2002$. 5 40 5.8 Summary of Potential Cost Savings Based on the above unit costs estimates of total costs and recovered values were estimated for the baseline scenario ( pre rule) and post regulatory scenario ( post rule). Incremental cost savings ( post rule costs minus pre rule costs) were estimated for the total number of plants currently recovering wastes in 1999 or recovered wastes in 1997. The total number of large quantity generators ( plants) currently identified that may receive benefits from this rule are 1,374. These plants reclaim metal, solvent and other values from 910,000 tons of waste. The sum of the prerule costs, post rule costs, and incremental cost savings for all plants that either recovered wastes on site or off site within the same industry group ( 4 digit NAICS code) in 1999 and 1997 are presented in Table 5 19 by individual unit cost item.

The potential incremental annual cost savings range from $ 13.6 million if only 1999 plants benefit to $ 34.5 million if the plants that recovered wastes in 1997 and not in 1999 switch back to recovery are included. This total increases by $ 63 million to $ 97.5 million if plants that recovered wastes off site at facilities outside the same industry group elect to construct on site recovery facilities because of potential cost savings ( Table 5 20 and 5 23). All these wastes have proven recovery value.

In addition, disposed quantities for eight waste types with high recovery potential were evaluated to determine if it was economically viable to construct on site recovery systems. Up to $ 266 million ( excluding incremental state tax savings) in potential incremental cost savings ( Tables 5 21 and 5 22) for roughly 708 out of 1,844 facilities ( 38 percent) has been estimated if the quality of the waste is sufficient for recovery. However, a significant limitation is that it is unknown if all eight of these wastes are of sufficient quality for recovery. Five of the eight wastes types have been identified as likely having sufficient constituent mix/ concentration quality for recovery. Emission control dust ( K061) from the steel works industry has a past history of being recovered for zinc values prior to the delisting of the significantly cheaper Envirosource stabilization technology. Most of the metal containing liquids from the printed circuit board industry were reported being disposed either on site or off site by chemical precipitation and included in this group of waste. Upon further inspection of the Biennial Report data, the copper containing sludge precipitated from this treatment process often goes on to metals recovery. This waste is of sufficient quality for recovery. Spent aluminum potliner ( K088) from the aluminum industry has a proven technology for recovering fluoride values. The Vortec technology has been implemented at least at two sites and licensing agreements can be arranged for construction at other sites. The Vortec technology meets universal treatment standards for potliner waste. Spent catalyst ( K171/ K172) from the petroleum refining industry is believed to be recoverable based on communications with reclaimers. Spent pickle liquor ( K062) from the steel works industry also is believed to have sufficient quality for recovery of acid values. Assuming these five wastes are of sufficient quality for recovery an additional $ 81 million in potential costs savings may be incurred because it will be more economical for facilities to construct on site recovery facilities ( Table 5 24). The remaining three wastes are not assumed to be of sufficient quality for recovery in this analysis. A breakdown of the potential cost savings by waste type are presented in Table 5 21 and Table 5 22. The total cost savings estimate increases to $ 178 million if plants that disposed these five wastes elect to construct on site recovery facilities because of potential cost savings. 5 41 For the 1999 on site recovery plants, the total estimated annual cost savings is $ 11 million. This total includes one time ( first year) contingency planning cost savings of $ 0.8 million that likely are sunk and one time notification of exclusion costs of $ 0.5 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 5.3 million in residual hazardous waste landfill cost savings  $ 3.0 million in new non hazardous waste landfill costs + $ 2.3 million in nonhazardous transportation cost savings = $ 4.6 million in cost savings). The second largest annual cost savings is from a reduction in hazardous materials training costs ($ 2.8 million in cost savings). The third largest annual cost savings is from a reduction in waste characterization testing costs ($ 2.1 million).

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

For those 1999 plants that recovered wastes off site within the same industry group ( 4 digit NAICS), the total estimated annual cost savings is $ 2.7 million. This total includes one time ( first year) contingency planning cost savings of $ 0.1 million that likely are sunk and one time notification of exclusion costs of $ 0.2 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 0.7 million in residual hazardous waste landfill cost savings  $ 0.5 million in post rule nonhazardous waste landfill costs + $ 0.2 million in nonhazardous transportation cost savings = $ 0.4 million in cost savings). The second largest annual cost savings is from a reduction in hazardous materials training costs ($ 0.4 million). The third largest annual cost savings is from a reduction in waste characterization testing costs ($ 0.2 million).

For those 1997 plants that recovered wastes off site within the same industry group, the total estimated annual cost savings is $ 4.7 million. This total includes one time ( first year) contingency planning cost savings of $ 0.02 million that likely are not sunk because the plants are switching management technologies and one time notification of exclusion costs of $ 0.03 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 1.6 million in pre rule hazardous waste management costs  $ 0.5 million in post rule residual hazardous waste landfill costs  $ 0.05 million in post rule non hazardous waste landfill costs  $ 0.9 million in post rule recovery system costs + $ 0.4 million in post rule nonhazardous transportation cost savings  $ 0.4 million in post rule off site recovery transport costs + $ 4.4 million in value from the recovered products = $ 4.4 million in cost 5 42 savings). The second largest annual cost savings is from a reduction in waste characterization testing costs ($ 0.3 million).

For those 1999 plants that recovered wastes off site outside their industry group, the total estimated annual cost savings is $ 63 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 19.5 million in residual hazardous waste landfill costs  $ 1.7 million in post rule non hazardous residual landfill costs + $ 64.6 million in on site recovery process savings + $ 2.0 million in hazardous transportation cost savings = $ 45.4 million in cost savings). The second largest annual cost savings is from a reduction in waste characterization testing costs ($ 15.3 million). The third largest annual cost savings is from a reduction in manifest costs ($ 2.4 million).

For those 1999 plants that disposed the five waste types identified with sufficient quality for recovery either on site or off site, the total estimated annual cost savings is $ 80.1 million. This total includes one time ( first year) contingency planning cost savings of $ 0.14 million that likely are sunk and one time notification of exclusion costs of $ 0.14 million. The greatest annual savings result from a portion of the residual quantity generated by the recovery processes being classified as nonhazardous ($ 84.5 million in pre rule hazardous waste management costs $ 13.7 million in residual hazardous waste landfill cost savings  $ 3.5 million in post rule non hazardous waste landfill costs + $ 13.2 million in nonhazardous transportation cost savings  $ 98.6 million in post rule recovery system costs + $ 73.0 million in value from the recovered products = $ 54.9 million in cost savings). The second largest annual cost savings is from a reduction in waste characterization testing costs ($ 22.9 million). The third largest annual cost savings is from a reduction in manifest costs ($ 3.5 million). 5 43 Table 5 19. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

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

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

Residual Non

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

onsite Acid Neutralization) $ 0 $ 0 $ 0 $ 4,257,000 $ 0 ($ 4,257,000) ($ 4,257,000)

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

Manifesting $ 3,701,000 $ 3,383,000 ($ 318,000) $ 500,000 $ 243,000 ($ 257,000) ($ 575,000) Table 5 19. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

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

5 44 Loading $ 4,371,000 $ 4,371,000 $ 0 $ 71,000 $ 224,000 $ 153,000 $ 153,000 Waste Transportation $ 23,184,000 $ 20,903,000 ($ 2,281,000) $ 3,749,000 $ 1,734,000 ($ 2,015,000) ($ 4,296,000)

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

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

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

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

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

Initial Characterization $ 7,066,000 $ 7,066,000 $ 0 $ 1,805,000 $ 1,805,000 $ 0 $ 0 One Time Notification of Exclusion $ 0 $ 542,000 $ 542,000 $ 0 $ 162,000 $ 162,000 $ 704,000 Table 5 19. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

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

5 45 On site Recovery Subtotal ($ 306,983,000) ($ 317,945,000) ($ 10,962,000) $ 17,601,000 $ 1,450,000 ($ 16,151,000) ($ 27,113,000)

Off site Recovery Within the Same Industry Group ( 4 Digit NAICS Code)

Residual Hazardous Landfill Disposal $ 6,389,000 $ 5,675,000 ($ 714,000) $ 0 $ 540,000 $ 540,000 ($ 174,000)

Residual Non

Hazardous Landfill Disposal $ 0 $ 481,000 $ 481,000 $ 0 $ 50,000 $ 50,000 $ 531,000 Pre Rule Management ( Hazardous Landfill, Energy Recovery,

Onsite Acid Neutralization) $ 0 $ 0 $ 0 $ 1,605,000 $ 0 ($ 1,605,000) ($ 1,605,000)

Pre Rule and Post Rule Metal/ Solvent/ Acid Recovery Cost $ 12,117,000 $ 12,117,000 $ 0 $ 0 $ 928,000 $ 928,000 $ 928,000 Table 5 19. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

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

5 46 Waste Characterization Testing $ 2,677,000 $ 2,510,000 ($ 167,000) $ 571,000 $ 320,000 ($ 251,000) ($ 418,000)

Manifesting $ 761,000 $ 665,000 ($ 96,000) $ 88,000 $ 70,000 ($ 18,000) ($ 114,000)

Loading $ 1,387,000 $ 1,573,000 $ 186,000 $ 12,000 $ 154,000 $ 142,000 $ 328,000 Waste Transportation $ 2,567,000 $ 2,344,000 ($ 223,000) $ 689,000 $ 301,000 ($ 388,000) ($ 611,000)

Recovery Transportation $ 8,585,000 $ 6,898,000 ($ 1,687,000) $ 0 $ 413,000 $ 413,000 ($ 1,274,000)

Salvage Revenue ($ 55,712,000) ($ 55,712,000) $ 0 $ 0 ($ 4,439,000) ($ 4,439,000) ($ 4,439,000)

Hazardous Materials Training $ 2,105,000 $ 1,729,000 ($ 376,000) $ 410,000 $ 360,000 ($ 50,000) ($ 426,000)

Manifest Training $ 437,000 $ 364,000 ($ 73,000) $ 82,000 $ 79,000 ($ 3,000) ($ 76,000)

BRS/ General Administrative Duties $ 549,000 $ 478,000 ($ 71,000) $ 105,000 $ 97,000 ($ 8,000) ($ 79,000)

One Time Contingency Planning $ 582,000 $ 475,000 ($ 107,000) $ 115,000 $ 98,000 ($ 17,000) ($ 124,000) Table 5 19. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item 1999 Plants 1997 Plants Total Costs ($/ yr)

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

5 47 Initial Characterization $ 2,661,000 $ 2,661,000 $ 0 $ 302,000 $ 302,000 $ 0 $ 0 One Time Notification of Exclusion $ 0 $ 159,000 $ 159,000 $ 0 $ 29,000 $ 29,000 $ 188,000 Off site Recovery Subtotal ($ 14,895,000) ($ 17,583,000) ($ 2,688,000) $ 3,979,000 ($ 698,000) ($ 4,677,000) ($ 7,365,000)

Aggregate Cost Total ($ 321,878,000) ($ 335,528,000) ($ 13,650,000) $ 21,580,000 $ 752,000 ($ 20,828,000) ($ 34,478,000)

NOTES: 1.) Numbers in parentheses, "( )", represent negative costs that reflect revenues or cost savings.

2.) Incremental facility level state tax costs for firms are estimated to be ($ 372,000) [$ 470,000 pre rule and $ 98,000 post rule] for 1999 on site recovery facilities and ($ 165,000) [$ 191,000 pre rule and $ 26,000 post rule] for 1997 on site recovery facilities. For off site recovery facilities, they are ($ 16,000 )

[$ 20,000 pre rule and $ 4,000 post rule] for 1999 off site recovery facilities and ($ 0) [$ 282 pre rule and $ 38 post rule] for 1997 off site recovery facilities.

Total facility level state tax costs are ($ 553,000).

3.) Incremental generation ( per ton) state tax costs for firms are estimated to be ($ 1,552,000) [$ 3,364,000 pre rule and $ 1,812,000 post rule] for 1999 onsite recovery facilities and ($ 29,000) [$ 393,000 pre rule and $ 364,000 post rule] for 1997 on site recovery facilities. For off site recovery facilities, they are ($ 7,000 ) [$ 1,495,000 pre rule and $ 1,488,000 post rule] for 1999 off site recovery facilities and ($ 9,000) [$ 17,000 pre rule and $ 8,000 post rule] for 1997 off site recovery facilities. Total generation ( per ton) state tax costs are ($ 1,597,000). 5 48 Table 5 20. Summary of Potential Incremental Cost Savings from Conducting On Site Recovery Instead of Recovering in Other Industry Groups 4 Digit NAICS Code ( Industry Group) No. Facilities with Potential Savings Quantity ( tons) Incremental Savings ( 2002 $)*

3241 Petroleum & Coal Products Mfg. 5 out of 112 8,229 out of 28,547 $ 272,513 3251 Basic Chemical Manufacturing 14 out of 227 15,917 out of 22,515 $ 9,293,753 3252 Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments Manufacturing 10 out of 99 25,803 out of 32,446 $ 18,709,701 3254 Pharmaceutical & Medicine Mfg. 14 out of 111 12,140 out of 15,447 $ 6,643,330 3255 Paint, Coating & Adhesive Mfg. 49 out of 156 21,549 out of 23,181 $ 12,117,532 3312 Steel Product Manufacturing from Purchased Steel 6 out of 119 136,518 out of 471,434 $ 5,012,838 3314 Non Ferrous Metal ( except Aluminum) Production and Processing 6 out of 83 18,826 out of 29,046 $ 1,219,361 3328 Coating, Engraving, Heat Treating and Allied Activities 1 out of 417 116 out of 25,069 $ 19,920 3344 Semiconductor and Other Electronic Component Mftg. 4 out of 382 1,174 out of 56,589 $ 527,843 3359 Other Electrical Equipment and Component Manufacturing 1 out of 67 71 out of 32,543 $ 8,670 3362 Motor Vehicle Body and Trailer Manufacturing 32 out of 74 17,400 out of 18,069 $ 9,518,978 Total 142 out of 1,847 257,743 out of 754,886 $ 63,346,441 * Includes $ 171,808 in incremental state tax savings. Does not include costs for one time notification of exclusion. 5 49 Table 5 21. Summary of Potential Incremental Cost Savings from Conducting On Site Recovery Instead of Off site Disposal by Waste Type Waste Types SIC Codes Waste Forms No. Facilities Quantity ( tons) Incremental Cost Savings ( 2002 $)*

Organic Liquids ( Industrial Organic Chemicals, Paints & Allied Products,

Pharmaceutical Preparations, &

Plastics Materials & Resins Industries) 2869 2851 2834 2821 Liquid Form Codes ( B101 B119, B201 B219) 389 ( out of 1,189) 190,003 ( out of 219,929) $ 174,599,586 Electric Arc Furnace Emission Control Dust ( K061  Steel Works Industry) 3312 Solid Form Codes ( B301 B319, B401 B409)

Sludge Form Codes ( B501 B519, B601 B609) 1 ( out of 30) 48,235 ( out of 273,208) $ 103,181 Metal Containing Liquids ( Printed Circuit Board Industry) 3672 Liquid Form Codes ( B101 B119, B201 B219) 102 ( out of 173) 18,795 ( out of 21,842) $ 2,884,000 Electroplating Wastewater Treatment Sludges ( Printed Circuit Board Industry) 3672 Solid Form Codes ( B301 B319, B401 B409)

Sludge Form Codes ( B501 B519, B601 B609) 0 ( out of 129) 0 ( out of 7,095) $ 0 Spent Carbon ( Industrial Organic Chemicals & Petroleum Refining Industries) 2869 2911 Solid Form Codes ( B301 B319, B401 B409)

Sludge Form Codes ( B501 B519, B601 B609) 109 ( out of 109) 2,376 ( out of 2,376) $ 10,839,402 Spent Catalyst ( Petroleum Refining Industry) 2911 Solid Form Codes ( B301 B319, B401 B409)

Sludge Form Codes ( B501 B519, B601 B609) 57 ( out of 75) 10,843 ( out of 11,001) $ 7,089,685 Spent Aluminum Potliner ( K088

Aluminum Industry) 3334 Solid Form Codes ( B301 B319, B401 B409)

Sludge Form Codes ( B501 B519, B601 B609) 19 ( out of 21) 71,698 ( out of 72,547) $ 31,712,523 Spent Pickle Liquor ( K062  Steel Works Industry) 3312 Liquid Form Codes ( B101 B119, B201 B219) 4 ( out of 32) 72,938 ( out of 88,128) $ 14,360,111 Total 681 ( out of 1,758)** 414,914 ( out of 696,126) $ 241,602,376 Table 5 21. Summary of Potential Incremental Cost Savings from Conducting On Site Recovery Instead of Off site Disposal by Waste Type Waste Types SIC Codes Waste Forms No. Facilities Quantity ( tons) Incremental Cost Savings ( 2002 $)*

5 50 * Includes $ 6,933,750 in incremental state tax savings. Does not include costs for one time notification of exclusion.

** The total number of unique plants is 1,585. Based on the above numbers, 173 plants dispose more than one of the eight waste types.

Table 5 22. Summary of Potential Incremental Cost Savings from Conducting On Site Recovery Instead of On site Disposal by Waste Type Waste Types SIC Codes Waste Forms No. Facilities Quantity ( tons) Incremental Cost Savings ( 2002 $)*

Metal Containing Liquids ( Printed Circuit Board Industry) 3672 Liquid Form Codes ( B101 B119, B201

B219) 20 ( out of 79) 313 ( out of 133,512) $ 254,000 Spent Pickle Liquor ( Steel Works Industry) 3312 Liquid Form Codes ( B101 B119, B201

B219) 7 ( out of 7) 181,171 ( out of 181,171) $ 24,411,861 Total 27 ( out of 86) 181,484 ( out of 314,683) $ 24,667,863 * Includes $ 2,266,653 in incremental state tax savings. Does not include costs for one time notification of exclusion. 5 51 Table 5 23. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item Off Site Recovery in Other Industry Groups ( Different NAICS)

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

Residual Hazardous Landfill Disposal $ 0 $ 19,483,000 $ 19,483,000 Residual Non Hazardous Landfill Disposal $ 0 $ 1,652,000 $ 1,652,000 Pre Rule Management ( Hazardous Landfill, Energy Recovery, on site Acid Neutralization) $ 0 $ 0 $ 0 Pre Rule and Post Rule Metal/ Solvent/ Acid Recovery $ 129,989,000 $ 65,432,000 ($ 64,557,000)

Waste Characterization Testing $ 22,103,000 $ 6,838,000 ($ 15,265,000)

Manifesting $ 3,405,000 $ 1,053,000 ($ 2,352,000)

Loading $ 305,000 $ 1,382,000 $ 1,077,000 Waste Transportation $ 8,552,000 $ 6,549,000 ($ 2,003,000)

Recovery Transportation $ 0 $ 0 $ 0 Salvage Revenue ($ 218,311,000) ($ 218,311,000) $ 0 Hazardous Materials Training $ 1,381,000 $ 653,000 ($ 728,000)

Manifest Training $ 258,000 $ 126,000 ($ 132,000)

BRS/ General Administrative Duties $ 343,000 $ 204,000 ($ 139,000)

One Time Contingency Planning $ 394,000 $ 185,000 ($ 209,000)

Initial Characterization $ 1,682,000 $ 1,682,000 $ 0 One Time Notification of Exclusion $ 0 $ 90,000 $ 90,000 Recovery Total ($ 49,899,000) ($ 112,982,000) ($ 63,083,000)

NOTES: 1.) Numbers in parentheses, "( )", represent negative costs that reflect revenues or cost savings. 2.) Total incremental state tax costs are ($ 172,000). 5 52 Table 5 24. Summary of Pre and Post Rule Costs and Incremental Costs Cost Item Disposal Wastes ( K061, K062, K088, Metal Containing Liquids, K171/ K172)

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

Residual Hazardous Landfill Disposal $ 0 $ 13,742,000 $ 13,742,000 Residual Non Hazardous Landfill Disposal $ 0 $ 3,487,500 $ 3,487,500 Pre Rule Management ( Hazardous Landfill, Energy Recovery, on site Acid Neutralization) $ 84,541,000 $ 0 ($ 84,541,000)

Pre Rule and Post Rule Metal/ Solvent/ Acid Recovery $ 0 $ 98,595,000 $ 98,595,000 Waste Characterization Testing $ 33,713,000 $ 10,820,000 ($ 22,893,000)

Manifesting $ 5,193,000 $ 1,666,000 ($ 3,527,000)

Loading $ 336,000 $ 2,098,000 $ 1,762,000 Waste Transportation $ 19,060,000 $ 5,857,000 ($ 13,203,000)

Recovery Transportation $ 0 $ 0 $ 0 Salvage Revenue $ 0 ($ 73,026,000) ($ 73,026,000)

Hazardous Materials Training $ 1,950,000 $ 1,565,000 ($ 385,000)

Manifest Training $ 371,000 $ 330,000 ($ 41,000)

BRS/ General Administrative Duties $ 487,000 $ 421,000 ($ 66,000)

One Time Contingency Planning $ 573,000 $ 431,000 ($ 142,000)

Initial Characterization $ 2,033,000 $ 2,033,000 $ 0 One Time Notification of Exclusion $ 0 $ 135,000 $ 135,000 Recovery Total $ 148,257,000 $ 68,154,500 ($ 80,102,500)

NOTES: 1.) Numbers in parentheses, "( )", represent negative costs that reflect revenues or cost savings. 2.) Total incremental state tax costs are ($ 4,651,000). 6 1 6.0 ECONOMIC IMPACT ANALYSIS 6.1 Major Industries Impacted In this section the industries which will have some of the greatest impacts are profiled, using 1997 Census of Manufacturers data. The industries profiled, listed below, represent much of the total waste which is affected under the anticipated rule.

° Basic Chemicals ( NAICS 3251) ° Petrochemical ( NAICS 325110) ° Other Basic Organic Chemicals ( NAICS 325199) ° Other Inorganic Chemicals ( NAICS 325188) ° Inorganic Dyes and Pigments ( NAICS 325131) ° Cyclic Crudes and Intermediates ( NAICS 325192)

° Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments ( 3252) ° Plastic Materials and Resins ( NAICS 325211)

° Pharmaceutical and Medicine Manufacturing ( NAICS 3254) ° Pharmaceutical Preparations ( NAICS 325412)

° Nonferrous Metal ( except aluminum) Production and Processing ( NAICS 3314) ° Primary Smelting and Refining of Copper ( NAICS 331411) ° Other Nonferrous Metal Primary Smelting and Refining ( NAICS 331419) ° Secondary Smelting, Refining and Alloying of Copper ( NAICS 331423) ° Other Nonferrous Metal Secondary Smelting, Refining, Alloying Manufacturing ( NAICS 331492)

° Coating, Engraving, Heat Treating, and Allied Activities ( NAICS 3328)

° Plating and Polishing ( NAICS 332813)

° Semiconductor and Other Electronic Component Manufacturing ( NAICS 3344) ° Printed Circuit Board ( NAICS 334412)

6.1.1 Basic Chemical Industry The Basic Chemical Industry includes a broad range of industries. For the purpose of our analysis, we will be focusing on the four major industries: Petrochemical ( NAICS 325110), Other Basic Inorganic Chemical ( NAICS 32518), Other Basic Organic Chemical ( NAICS 32519) and Inorganic Dye and Pigment ( NAICS 325131). 18 U. S. Department of Commerce, US Census Bureau, 1997 Economic Census: Bridge Between NAICS and SIC.

6 2 <IP_ADDRESS> Petrochemical Industry Profile The petrochemical manufacturers are listed under the NAICS code 325110 ( SIC 2865 and 2869). This industry is a part of the chemical manufacturing industry ( NAICS 325) and comprises establishments primarily engaged in ( 1) manufacturing acrylic, and ( 2) manufacturing cyclic aromatic hydrocarbons. 18 <IP_ADDRESS>.1 Production and Shipment Values Table 6 1 provides a summary of the estimated U. S. total value of shipments of petrochemicals for 1997.

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

1997 20,534,750 Source: 1997 Census of Manufacturers, USDC.

<IP_ADDRESS>.2 Industry Size and Market Share Data used to characterize this industry are from the 1997 Census of Manufacturers and Census Current Industrial reports. The 1997 Census data indicate that there are 54 facilities located in within the U. S., owned by 42 companies. More than half of the industry, in terms of aggregate value of shipments, is dominated by approximately 11 percent of all facilities. A distribution of facilities by number of employees, and their respective share of the total value of shipments is provided in Table 6 2.