vvEPA
United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5305)
EPA530-R-94-023
Aprfl1994
Analysis of Potential
Cost Savings and the
Potential for Reduced
Environmental Benefits
of the Proposed
Universal Waste Rule
Recycled/Recyclable
Printed with Soy/Canola Ink on paper that
contains at least 50% recycled fiber
-------
-------
TABLE OF CONTENTS
PART I - INTRODUCTION
PAGE
CHAPTER 1 - INTRODUCTION 1-1
1.1 Purpose of Document 1-1
1.2 Introduction 1-2
CHAPTER 2. BACKGROUND 2-1
2.1 Characteristics of Universal Waste 2-1
2.2 Full RCRA Subtitle C Requirements and Universal Waste Issues 2-2
2.2.1 Full RCRA Subtitle C Requirements 2-2
2.2.2 Implementation Issues 2-7
2.4 Wastes/Generators not Subject to the Proposed Part 273 Requirements . . 2-12
PART II - COST ANALYSIS
CHAPTER 3. REGULATED COMMUNITY 3-1
3.1 Sealed Nickel-Cadmium Batteries 3-2
3.1.1 Number of Generators 3-2
3.1.2 Number of Batteries Disposed 3-3
3.1.3 Total Quantity Disposed 3-3
3.2 Vented Nickel-Cadmium Batteries 3-4
3.2.1 Number of Generators 3-4
3.2.2 Number of Batteries Disposed 3-5
3.2.3 Total Quantity Disposed 3-5
3.3 Mercuric-Oxide Batteries 3-6
3.3.1 Conditionally Exempt Small Quantity Generators 3-6
3.3.2 Small Quantity Generators 3-7
3.3.3 Large Quantity Generators 3-7
3.4 Used Mercury-containing Thermostats 3-8
3.4.1 Number of Generators 3-8
3.4.2 Number of Thermostats Disposed 3-10
3.4.3 Total Quantity Disposed 3-11
3.5 Recalled Pesticides 3-11
3.6 Total Generators Covered by the Universal Waste Proposal 3-12
-------
CHAPTER 4. COST ANALYSIS METHODOLOGY 4-1
4.1 Overview of the Cost Analysis Approach 4-1
4.2 Type of Unit Costs and Their Sources 4-2
4.3 Cost Elements for Full RCRA Subtitle C Compliance 4-2
4.3.1 Batteries and Used Thermostats 4-3
4.3.2 Recalled Pesticides 4-8
4.4 Cost Elements for Thermostats and Batteries under the Proposed Part 273
Rule 4-10
4.4.1 Generators Ship Waste to Consolidation Points 4-10
4.4.2 Generators Ship Directly to a Reclamation Facility Via Common
Carrier (Truck) 4-15
4.4.3 Generators Ship Waste Via Parcel Carrier 4-16
4.4.4 Generators of Thermostats Ship Via Parcel Carrier to Honeywell
Corporation 4-20
4.5 Cost Elements for a Pesticide Recall under the Proposed Part 273 Rule . 4-22
CHAPTER 5. RESULTS OF COST ANALYSIS 5-1
5.1 Thermostats and Batteries Savings 5-1
5.2 Pesticide Recall Savings . . : 5-1
5.3 Total Savings 5-7
5.4 Sensitivity Analysis 5-8
5.4.1 Batteries and Thermostats 5-8
5.4.2 Pesticides 5-10
5.5 Major Limitations 5-12
PART m - POTENTIAL FOR REDUCTION IN ENVIRONMENTAL BENEFITS
CHAPTER 6 - ANALYSIS OF POTENTIAL FOR REDUCTION IN
ENVIRONMENTAL BENEFITS 6-1
6.1 Wastes Are Contained and Pose Low Potential for Releases 6-1
6.2 Requirements Provide A Higher Level of Protection For Larger Quantities
of Waste 6-3
6.3 Regulations Limit the Length of Time That Universal Waste Be Stored . . 6-4
6.4 The Proposed Part 273 Requirements Provide Protection 6-5
6.5 Other Authorities and Controls 6-7
6.6 The Proposed Rule Will Facilitate Improved Management of Unregulated
Wastes -6-8
APPENDIX A - Sources for Unit Cost Estimates
n
-------
PART I - INTRODUCTION AND BACKGROUND
CHAPTER 1 - INTRODUCTION
1.1 Purpose of Document
This document has been developed by the U.S. Environmental Protection Agency (EPA)
in support of a proposal to modify the Resource Conservation and Recovery Act (RCRA)
Subtitle C regulations governing management of hazardous waste. The proposal, known as the
Universal Wastes proposal, was published in the Federal Register on February 11, 1993 (58 FR
8102) under the title Hazardous Waste Management System: Modification of the Hazardous
Waste Recycling Regulatory Program. The proposed changes and the rationale for making these
changes are described in detail in the Federal Register notice. The proposed changes are also
summarized in Chapter 2 of this document.
In the preamble to the proposed Universal Wastes rule (58 FR 8126) the Agency
committed to:
o "analyze the costs of the current regulatory requirements for generators and collection
facilities and of the requirements [proposed]";
o "analyze whether there are significant reduced environmental benefits from the
modifications being proposed"; and
o notice the analysis for comment prior to promulgating a final rule.
This document, which has been noticed for comment in the Federal Register (59 FR
31568), presents these analyses. Part II discusses and compares the costs of the existing Subtitle
C regulations and of the proposed changes to these regulations. Part III discusses whether the
proposed changes will significantly reduce the environmental benefits provided by the current
Subtitle C regulations.
Three types of universal hazardous waste are included in the analyses in this document:
o Hazardous waste batteries, for which specific regulatory language was proposed
(including nickel-cadmium and mercuric oxide batteries);
o Suspended and/or canceled pesticides that are recalled, for which specific regulatory
language was proposed; and
o Hazardous waste mercury-containing thermostats, for which appropriate regulatory
requirements were discussed in some detail in the preamble to the proposal.
1-1
-------
1-2
1.2 Introduction
There are several hazardous wastes that are generated in relatively small quantities by
a large and diverse set of businesses that EPA believes will be better controlled by more tailored
standards than is provided in the current hazardous waste rules. Examples of these wastes
include nickel-cadmium and mercuric oxide batteries and mercury-containing thermostats that
businesses want to discard. The vast number of generators of these "universal wastes" makes
implementation of the hazardous waste program difficult for EPA and the states. It is also clear
that generators of these universal wastes are having difficulties in properly handling these types
of wastes under the full RCRA Subtitle C requirements.
To improve management of these universal wastes, the Agency proposed the Universal
Waste Rule. The proposed regulatory changes would establish new requirements for several
types of batteries and recalled pesticides.1 In the preamble of the proposed rule, EPA discusses
how thermostats could also be regulated hi the future in the same way batteries are in the
proposal. The proposed rule also provides a process for persons to petition EPA to place
additional wastes under similar regulatory controls to those covered hi the proposal. Although
EPA must decide in the final rule which wastes will be subject to Part 273, for purposes of
analysis, we assumed batteries, suspended and/or cancelled pesticides that are recalled, and
thermostats would be subject to the proposed reduced requirements under Part 273.
The proposed Universal Waste Rule (40 CFR Part 273) would tailor the regulatory
controls placed on the hazardous wastes that the rule covers. Part 273 would allow generators
of the covered universal wastes to ship them without a RCRA Subtitle C manifest and without
using RCRA-regulated hazardous waste transporters. Additionally, generators would also not
have to prepare biennial reports, contingency plans, and Land Disposal Restriction notifications
and would have simpler training requirements for employees. The proposed Part 273 rule would
also increase the tune period that generators could accumulate these wastes without obtaining
an EPA storage permit, which could make shipping them off site more economical. Generators
of universal wastes covered by the rule will have several shipment and handling options that they
could use to comply with the Part 273 rule that cost less than meeting the full RCRA Subtitle
C requirements. The alternative collection and shipment practices that the proposed Part 273
rule makes available to generators of these universal wastes include:
1 The batteries that EPA has considered for control under the Part 273 rule proposed
include nickel-cadmium, and mercuric-oxide batteries that are hazardous wastes, because
they fail the toxicity characteristic of RCRA Part 261. In some cases, lithium, and alkaline
batteries may also fail the Part 261 toxicity characteristic and reactivity characteristic,
respectively. Lead-acid batteries that are reclaimed are currently regulated under RCRA
Part 266, which has tailored standards for their control. EPA asked for public comment on
regulating lead-acid batteries under Part 273, but proposed to retain the existing Part 266
regulations.
-------
1-3
o Shipment by common carriers (trucks) to central consolidation points that will have fewer
regulatory requirements than RCRA Subtitle C storage facilities (and the consolidation
points will ship these universal wastes to hazardous waste treatment facilities),
o Direct shipment by common carriers to a hazardous waste treatment facility without a
manifest, and
o Shipment via parcel carriers, such as the United Parcel Service (UPS).
-------
-------
CHAPTER 2. BACKGROUND
In Part II of this analysis, the Agency estimates the cost differences between compliance
with the existing full RCRA Subtitle C requirements and compliance with the proposed Part 273
Universal Wastes regulations for generators of universal wastes. This economic impact analysis
examines the savings that should result from generators handling hazardous wastes batteries and
thermostats under several possible options for complying with the proposed Part 273
requirements, and identifies the least-cost compliance options. This economic impact analysis
also estimates the incremental savings that should result for generators of pesticides (e.g.
farmers, retail outlets) that are hazardous wastes after their recall. EPA expects that generators
of recalled pesticides that are hazardous wastes will send these materials to consolidation points
regulated under the proposed Part 273 Rule rather than RCRA-permitted Subtitle C storage
facilities to await management by the manufacturers of the recalled pesticides.
Part III of this analysis presents a qualitative analysis of whether the proposed changes
to the hazardous waste regulations for universal wastes would significantly reduce the
environmental benefits provided by the current hazardous waste regulations.
In the Universal Wastes rule, EPA proposed to streamline the RCRA Subtitle C
regulatory requirements for certain widespread hazardous wastes that it has designated as
universal wastes. This chapter summarizes the characteristics of universal wastes and describes
the universal wastes addressed in this analysis. This is followed by a description of the current
full RCRA Subtitle C requirements for these universal wastes and associated program
implementation problems. Then the proposed Part 273 regulations are described. Finally,
universal wastes that are not covered in this analysis are discussed.
2.1 Characteristics of Universal Waste and Coverage of Analysis
Universal wastes, as defined by EPA hi the proposed Universal Waste Rule, are
hazardous wastes that have three main characteristics:
o
o
o
They are frequently generated in a wide variety of settings other than the
industrial settings usually associated with hazardous wastes;
They are frequently generated by a vast community, the size of which poses
implementation difficulties for both those who are regulated and the regulatory
agencies charged with implementing the hazardous waste program; and
They may be present in significant volumes hi the municipal solid waste stream.
EPA's Universal Waste Rule proposed streamlined Part 273 requirements for:
Hazardous waste batteries, including nickel-cadmium, mercuric-oxide, and lithium
batteries;
Suspended and/or cancelled hazardous waste pesticides that are recalled.
2-1
-------
2-2
The Agency estimates that these wastes will be considered hazardous because they will fail the
RCRA Part 261 toxicity characteristic, or exhibit the RCRA Part 261 hazardous waste
characteristics of corrosivity or reactivity. In the case of pesticides, they may also appear on
the RCRA Part 261 list of commercial products that are hazardous if discarded. The preamble
of the Part 273 proposal also discussed applying the Part 273 requirements for batteries to
thermostats containing mercury.
In the economic impact analysis, the Agency estimated the savings from reduced RCRA
controls under the proposed Part 273 Rule for nickel-cadmium batteries, mercuric-oxide
batteries, thermostats containing mercury, and recalled pesticides that are hazardous wastes.
EPA did not analyze the savings for lithium batteries because they are produced hi very small
quantities.
2.2 Full RCRA Subtitle C Requirements and Universal Waste Issues
Like other hazardous wastes, universal wastes are currently controlled under the full
RCRA Subtitle C requirements from the point of generation to their final disposal under an
extensive set of hazardous waste regulations. Several types of program implementation issues
have arisen from the use of the full RCRA Subtitle C regulation for these types of wastes.
2.2.1 Full RCRA Subtitle C Requirements
Under the full RCRA Subtitle C requirements, generators of universal wastes are subject
to a number of operational controls, recordkeeping, and other administrative requirements.
These requirements can cumulatively result hi substantial costs to the generator. A listing of the
full RCRA Subtitle C Part 262 requirements for generators producing different monthly volumes
can be found in Exhibit 2-1. In this report, generators of less than 100 kilograms (220 pounds)
per month are referred to as conditionally exempt small quantity generators (CESQGs);
generators of between 100 and 1,000 kilograms of hazardous wastes per month are referred to
as small quantity generators (SQGs); and generators producing over 1,000 kilograms of
hazardous wastes per month are referred to as large quantity generators (LQGs).
Generators of hazardous waste generally must use transporters complying with RCRA
Subtitle C requirements. Under the RCRA Subtitle C Part 263 rales, transporters of hazardous
wastes must obtain an EPA ID number, comply with DOT packaging and placarding regulations,
and meet other requirements. Transporters may not accept hazardous waste unless accompanied
by a manifest. In general, use of a manifest restricts the options available for transport of
wastes to a limited number of hazardous waste transporters that will transport manifested
hazardous waste. A listing of the current RCRA requirements for hazardous waste transporters
can be found hi Exhibit 2-2.
Existing RCRA Subtitle C requirements for hazardous waste recycling, treatment, or
disposal facilities are not altered by the proposed Part 273 Rule. The current RCRA Subtitle
C requirements for facilities that consolidate and store hazardous wastes for greater than 10 days
require that these facilities have an operating permit and meet a set of comprehensive standards
for the proper design, operation, and closure of these facilities under RCRA Subtitle C Part 264.
-------
2-3
Exhibit 2-1
Full RCRA Subtitle C Part 262 Requirements for
Hazardous Waste Generators that Have Differing Monthly Generation Rates
< 100 kilograms/month
100 - 1000 kilograms/month
> 1000 kilograms/month
A. General
- Generators of solid waste must
determine if the waste is
hazardous by 1) determining if
the waste is listed in Subpart D
of Part 261 or, 2) determining
if the waste is identified in
Subpart C of Part 261 by either
testing the waste or through
applying knowledge of the
hazardous characteristics of the
waste
- May not store > 1000 kg at any
time. Otherwise, requirements
for SQGs apply.
- If generating > 1 kg of acutely
hazardous waste per month,
requirements for LQGs apply.
- Must send waste to a hazardous
waste facility, a recycler, or a
facility licensed by the state to
manage municipal or industrial
waste.
A. General
- Generators of solid waste must
determine if the waste is
hazardous by 1) determining if
the waste is listed in Subpart D
of Part 261 or, 2) determining
if the waste is identified in
Subpart C of Part 261 by either
testing the waste or through
applying knowledge of the
hazardous characteristics of the
waste
- Must obtain EPA ID number
- May only send waste to a
permitted Subtitle C treatment,
storage, disposal facility or
Subtitle C recycler
B. The Manifest
- If the waste is transported off
site, the owner/operator must
prepare a manifest
C. Pre-Transport
- Must package, label, and mark
all wastes in accordance with
applicable DOT requirements
- May accumulate waste for up
to 180 days without a permit
providing the waste is managed
in tanks or containers in
accordance with §262.34
- The date the period of
accumulation begins must be
marked on each container and
the tank or container must be
labeled "hazardous waste"
A. General
- Generators of solid waste must
determine if the waste is
hazardous by 1) determining if
the waste is listed in Subpart D
of Part 261 or, 2) determining
if the waste is identified in
Subpart C of Part 261 by either
testing the waste or through
applying knowledge of the
hazardous characteristics of the
waste
- Must obtain EPA ID number
- May only send waste to a
permitted Subtitle C treatment,
storage, disposal facility or
Subtitle C recycler
B. The Manifest
- If the waste is transported off
site, the owner/operator must
prepare a manifest
C. Pre-Transport
- Must package, label, and mark
all wastes in accordance with
applicable DOT requirements
- May accumulate waste for up
to 90 days without a permit
providing the waste is managed
in tanks or containers in
accordance with §262.34
- The date the period of
accumulation begins must be
marked on each container and
the container or tank must be
labeled "hazardous waste"
-------
2-4
Exhibit 2-1 (continued)
Full RCRA Subtitle C Part 262 Requirements for
Hazardous Waste Generators that Have Differing Monthly Generation Rates
< 100 kilograms/month
100 -1000 kilograms/month
> 1000 kilograms/month
- If accumulation of waste
exceeds 180 days (or 270 days
for long distance transport), or
if the total quantity
accumulated >6000 kg, must
obtain a permit
- Must ensure employees are
familiar with proper waste
handling and emergency
procedures
- Must comply with Subpart C
of 265, Preparedness and
Prevention
- Must comply with basic
contingency planning and
emergency procedures of
§262.34(d)(5)
- Must comply with land ban
notification requirements of
§268.7
D. Record keeping
- Must keep a copy of each
signed manifest for at least 3
years
- Must keep records of any tests
or waste analysis used to
determine if a waste is
hazardous for at least 3 years
- Must report to the Regional
Administrator if the generator
has not received a copy of the
manifest signed by the
destination facility within 60
days of the date the waste was
accepted by the initial
transporter
- If accumulation of waste
exceeds 90 days, must obtain a
permit
- Must comply with personnel
training requirements of
§265.16
- Must comply with Subpart C of
265, Preparedness and
Prevention
- Must comply with Subpart D of
265, Contingency Plan and
Emergency Procedures
- Must comply with land ban
notification requirements of
§ 268.7
D. Record keeping
- Must keep a copy of each
signed manifest for at least 3
years
- Must keep records of any tests
or waste analysis used to
determine if a waste is
hazardous for at least 3 years
- Must submit an exception report
to the Regional Administrator if
the generator has not received a
copy of the manifest signed by
the destination facility within 45
days of the date the waste was
accepted by the initial
transporter
- Must submit a biennial report
and keep a copy for at least 3
years
-------
2-5
Exhibit 2-1 (continued)
Full RCRA Subtitle C Part 262 Requirements for
Hazardous Waste Generators that Have Differing Monthly Generation Rates
< 100 kilograms/month
100 - 1000 kilograms/month
> 1000 kilograms/month
E. Exports of hazardous waste
- If the generator intends to
export hazardous waste, must
comply with the export
notification requirements of
262 Subpart E
E. Exports of hazardous waste
- If the generator intends to
export hazardous waste, must
comply with the export
notification requirements of
262 Subpart E
-------
2-6
Exhibit 2-2
Full RCRA Subtitle C Part 263 Requirements for Transporters
A. General
- Must receive an EPA ED number
- Can store the hazardous waste in containers at a transfer facility for up to 10 days without a permit
B. Compliance with the Manifest System and Recordkeeping
- Must not accept hazardous waste unless accompanied by a manifest
- Must sign and date the manifest to acknowledge acceptance of the waste
- Must return a signed copy of the manifest to the. generator before leaving the property
- Must ensure that the manifest accompanies the waste
- When delivering waste to another transporter or destination facility, must obtain the signature of the owner/
operator of the facility and keep one copy of the manifest
- Must deliver the entire quantity to the destination facility listed on the manifest, the alternate facility, or the
next designated transporter
- Must keep a copy of the signed manifest for at least 3 years
C. Hazardous Waste Discharges
- In the event of a discharge of hazardous waste during transportation, the transporter must take appropriate
immediate actions to protect human health and the environment
- If required by 49 CER 171.15, must give notice to the National Response Center and report in writing to the
Director of the Office of Hazardous Materials Regulations, Materials Transportation Bureau, Department of
Transportation
- Must clean up any hazardous waste discharge or take action as required or approved by federal, state, or
local officials
-------
2-7
However, the proposed Part 273 allows universal wastes to go to a new storage facility referred
to as a "consolidation point," which has its own unique regulatory requirements that will be
discussed below.
2.2.2
Implementation Issues
The full RCRA Subtitle C requirements are extensive. Generators of universal wastes
have expressed concerns about how these requirements apply to the types of wastes that they
produce (e.g., batteries), and the expense involved hi managing the relatively small volumes they
generate within these requirements. Businesses that only generate these hazardous wastes have
expressed concerns over the complexity of the regulations.
Universal wastes are also difficult to control from the perspective of disposal facilities.
Due to the nature of these wastes (e.g., indistinguishable from household wastes), operators of
municipal solid waste management facilities cannot distinguish them from those originating from
RCRA-exempt sources such as conditionally exempt small quantity generators or households.
Some municipalities have attempted to keep universal wastes out of municipal solid waste
streams by organizing special collection programs that target hazardous wastes typically
generated by households and small businesses. Additionally, some states have enacted laws that
encourage or requke manufacturers and retailers to become involved hi the collection and proper
disposal of their products after they become wastes. Existing RCRA requirements, however,
may act as an impediment to the implementation of these programs.
Universal wastes, such as hazardous waste batteries, thermostats, and certain recalled
pesticides, are not easy for EPA and States to control through the full RCRA Subtitle C
requirements because a very large number of businesses produce them.
These concerns have led the Agency to believe that it will be more effective to channel
many universal wastes into proper recycling and management programs with controls that are
tailored to both the type of waste produced and the generators that produce them.
2.3 Proposed Part 273 Requirements
The proposed Part 273 rule provides generators, transporters, and storers (consolidation
points) of universal wastes tailored regulatory requirements that have considerable flexibility in
compliance options. EPA estimates that this approach will save money and encourage better
management of these wastes, because the generators will find it easier to comply with the new
requirements of Part 273. Exhibit 2-3 lists the proposed Part 273 requirements for generators
of universal wastes. Exhibits 2-4 and 2-5 list the proposed Part 273 requirements for
transporters and consolidation points, respectively. It should be noted that generators of wastes
may continue to comply with the full RCRA Subtitle C rules, if they elect to do so.
-------
2-8
Exhibit 2-3
Proposed Part 273 Universal Waste Requirements for
Generators of Universal Hazardous Wastes
< 100 kg/month
> 100 kg/month
Hazardous Waste Batteries and Thermostats
Same as CESQG requirements under full RCRA
Subtitle C (Part 273 is optional)
- Must send waste to a consolidation point or a
Subtitle C destination facility (treatment, disposal,
or recycling facility)
- No manifest or hazardous waste transporter
necessary for transport to a consolidation point or
destination facility
- May store wastes for up to 1 year from the date
the item becomes a waste
- Must label wastes with the date they became waste
to demonstrate storage < 1 year (or use alternate
documentation methods)
- May not dilute, dispose of, or treat wastes except
by removing electrolyte from batteries or
responding to releases
- Must immediately contain releases and residues.
If the material resulting from die release is
hazardous waste, the generator must manage it in
accordance with all requirements of Parts 260-272
- If storing > certain quantities of
batteries/thermostats at any time, must send
written notification to the Regional Administrator
- Must ensure employees are familiar with proper
waste handling and emergency procedures
-------
2-9
Exhibit 2-3 (continued)
Proposed Part 273 Universal Waste Requirements for
Generators of Universal Hazardous Wastes
< 100 kg/month
> 100 kg/month
Recalled Pesticides
Same as CESQG requirements under full RCRA
Subtitle C (Part 273 is optional)
- Must send waste to a consolidation point, or a
Subtitle C destination facility (treatment, disposal,
or recycling facility)
- No manifest or hazardous waste transporter
necessary for transport from generator to a
consolidation point or destination facility
- May store wastes for up to 1 year from the date
the pesticide becomes a waste
- Pesticides must be contained in either closed, non-
leaking original packaging materials, original
packaging that has been overpacked, tanks meeting
Subtitle C requirements, or non-leaking transport
vehicles
- May not dilute, dispose of, or treat wastes except
in responding to releases
- Must label container with the date the pesticide
became waste to demonstrate storage < 1 year (or
use alternate documentation methods)
- Must immediately contain releases and residues.
If material resulting from the release is hazardous
waste, the generator must manage it in accordance
with Parts 260-272
- Must ensure employees are familiar with proper
waste handling and emergency procedures
-------
2-10
Exhibit 2-4
Proposed Part 273 Universal Waste Requirements for
Transporters of Universal Wastes
Hazardous Waste Batteries and Thermostats
May store at a transfer facility for < 10 days
May not dilute, dispose of, or treat batteries/thermostats except in responding to releases
May not remove the electrolyte from batteries
May not transport wastes to a place other than a consolidation point, destination facility, or foreign destination
Must manage wastes in a way that minimizes releases
Shipments from a consolidation point to a destination facility must comply with the requirements of part 263
Recalled Pesticides
Must contain pesticides hi either the original packaging materials kept closed and non-leaking, original
materials that have been overpacked hi larger, non-leaking container, tanks, or non-leaking transport
vehicles
May store at a transfer facility for < 10 days
May not dilute, dispose of, or treat pesticides except in responding to releases
May not transport wastes to a place other than a foreign destination, consolidation point, or destination
facility designated by the person conducting the recall
-------
2-11
Exhibit 2-5
Proposed Part 273 Universal Waste Requirements for Consolidation Points
Hazardous Waste Batteries and Thermostats
- May store batteries/thermostats for no longer than 1 year from the date of receipt
- Must be able to demonstrate that the wastes were not stored for more than 1 year from the date received by
labeling individual items or containers with the date received (or use alternative documentation methods)
- May not dilute, dispose of, or treat wastes except in removing electrolyte or responding to releases
- Must manage batteries/thermostats in a way that minimizes releases
- Must immediately contain all releases and residues. If material resulting from the release is hazardous waste,
the owner or operator must manage it in accordance with Parts 260-272
- Must ensure employees are familiar with waste handling and emergency procedures
- If store > certain quantities of batteries/thermostats, must send written notification to Regional Administrator
and get EPA ID number
- If ship wastes to a destination facility, must send written notification to Regional Administrator and get EPA
ID number
- If ship to a destination facility, must comply with the manifesting, packaging, labeling, recordkeeping, and
reporting requirements of Part 262
Recalled Pesticides
- Must contain pesticides in either the original packaging materials kept closed and non-leaking, original
materials that have been overpacked in larger, non-leaking container, tanks, or non-leaking transport vehicles
- May store hazardous waste pesticides for up to 1 year from the date of receipt
- Must label containers or tanks with the date of receipt in order to demonstrate storage < 1 year (or use
alternative documentation methods)
- May not dilute, dispose of, or treating pesticides except in responding to releases
- May not send waste to a place other than a foreign destination, consolidation point, or the destination facility
designated by the person conducting the recall
- Must immediately contain releases and residues. If material resulting from the release is hazardous waste, the
. owner or operator must manage it in accordance with Parts 260-272
- Must ensure employees are familiar with proper waste handling and emergency procedures
-------
2-12
There are eight major changes to the full RCRA Subtitle C requirements that the proposed
Part 273 Rule would provide for universal-wastes. Under the proposed rule, generators do not
need to manifest then: batteries, thermostats, and recalled pesticides when they ship them to a
consolidation point or directly to a hazardous waste treatment facility.2 They do not need to
use a hazardous waste transporter in shipping them off site. Additionally, generators are not
required to prepare a contingency plan, biennial reports, and LDR notifications and are allowed
less stringent training for employees who handle waste. The proposed Universal Waste Rule
would also increase storage time for universal wastes to one year in order to allow greater
accumulation of wastes to facilitate economies of scale for proper management. Under the
proposed rule, consolidation points would have fewer requirements than storage facilities
receiving other types of hazardous wastes stored more than 10 days before shipment.
2.4 Wastes/Generators not Subject to the Proposed Part 273 Requirements
EPA proposed to retain the existing Part 266, Subpart G, regulations governing management
of lead-acid batteries that are reclaimed (the vast majority of lead-acid batteries are reclaimed).
Under Subpart G, lead-acid batteries that are to be reclaimed are generally not subject to
regulation until they reach a reclamation facility. The Agency proposed to allow management
of lead-acid batteries under either the existing Part 266 requirements or the proposed Part 273
requirements. The Agency expects that most lead-acid batteries (auto batteries) would continue
to be managed under Part 266, but that some small, sealed lead-acid batteries that may be
difficult to distinguish from other sealed batteries may be voluntarily managed with these other
batteries under Part 273. Because the volume of small, sealed lead-acid batteries is small, and
because management under Part 273 would be voluntary, these batteries have not been included
in the cost estimate.
Under the Universal Wastes proposal, CESQGs and households that generate universal wastes
would not be required to manage these wastes under the proposed Part 273 requirements, but
could do so if they choose. The option of continuing to manage these wastes under the existing
household waste exemption (40 CFR 261.4(b)(l)) and the CESQG exemption (40 CFR 261.5)
would still remain. Although EPA anticipates that many collection programs managing some
regulated universal wastes will manage these exempt wastes together with regulated waste, the
costs of managing these exempt wastes under the Part 273 requirements are not included hi the
cost estimate because such management would be voluntary.
2 Most batteries and mercury thermostats are required by the Land Disposal Restrictions
program to meet reclamation technology standards (e.g., thermal recovery). The pesticides
are likely to be toxic organics and their generators are likely to have to meet concentration
standards based on incineration.
-------
PART H - COST ANALYSIS
CHAPTERS. REGULATED COMMUNITY
To prepare its estimates of total cost savings from proposed Universal Wastes rule, EPA
estimated the size of the regulated community covered by the proposal and the volume of wastes
these generators produce annually. The Agency developed estimates of the number of generators
and volumes of waste produced for sealed nickel-cadmium (ni-cd) batteries, vented nickel-
cadmium (ni-cd) batteries, mercuric-oxide batteries, mercury-containing thermostats, and recalled
pesticides that are hazardous wastes. Estimating the regulatory savings that could result from
the proposed Part 273 Rule necessitated estimating the generators and waste volumes in each of
the RCRA Subtitle C generator categories (i.e., conditionally exempt small quantity generators,
small quantity generators, and large quantity generators).
To gather information on the number of generators and waste generation rates of batteries
and thermostats, EPA contacted experts hi industry as well as in state governments, many of
whom have been developing programs similar to the Universal Wastes proposal. EPA generally
found that knowledge of generators and volumes of universal wastes tended to be concentrated
in a few individuals whose jobs specifically required that they understand the overall market in
which batteries or thermostats were produced, discarded, and managed as wastes. EPA relied
heavily on the information from these individuals. The Agency primarily used input from
individuals with less comprehensive knowledge for confirmatory purposes.
In documenting this analysis, EPA has generally cited the individuals from whom it
obtained the bulk of its information, even though any single source was typically supported by
three other sources. For sealed ni-cd batteries, EPA's primary sources were the Portable
Rechargeable Battery Association (PRBA) and INMETCO, a recycler of nonferrous metals.3-4
For vented ni-cd batteries, EPA's primary sources were INMETCO and the Cadmium Council.5
EPA could not identify any source on the use of mercuric-oxide batteries across battery types
and applications. For this analysis, the Agency gathered most of the information on mercury
batteries from two reclamation facilities: Bethlehem Apparatus and Mercury Refining. The
production of mercury-containing thermostats in the United States is concentrated among a small
3 PRBA has been developing a manufacturers' take-back system, and therefore Jhad
previously started to gather the type of data EPA required for the current analysis.
4 INMETCO uses waste batteries for its secondary smelting process, and therefore
tracks the sources of primary and secondary cadmium.
5 The Cadmium Council is a trade association that promotes the use of cadmium in
rechargeable batteries. Its members include manufacturers of vented ni-cd batteries, as
well as industrial users.
3-1
-------
3-2
number of manufacturers. For this analysis, EPA relied heavily on information supplied by
Honeywell Corporation.6
EPA was able to draw on work prepared by the Office of Pesticide Programs (OPP) to
estimate the size of the regulated community covered in a pesticide recall (e.g., retailers and
distributors of pesticides) and waste volumes that would be covered by the proposed Part 273
Rule. OPP had conducted an analysis on the size of this regulated community during its
development of Agency procedures for the recall of pesticide products.
EPA's methodology for determining the size of the regulated community and the annual
volume of universal waste generated is explained below for each type of universal waste. The
results of EPA's analysis follow each methodology description. Given that the Agency had to
rely extensively on the judgment of many industry experts and materials often prepared for other
purposes to develop its generator and waste generation estimates, the results are presented as
order-of-magnitude estimates. (In Chapter 5, the Agency examines the cost'implications of the
accuracy of these estimates in a sensitivity analysis of the number of generators covered by the
Universal Waste Proposal.)
3.1 Sealed Nickel-Cadmium Batteries
EPA developed estimates of the number of generators of waste sealed nickel-cadmium
batteries in various size categories, the number of waste batteries these generators produce
annually, and the amount of battery waste (in pounds) these generators produce annually. The
categories of waste generators covered hi the Agency's estimates include CESQGs, SQGs, and
LQGs, although the Agency proposed changes to the regulations applicable to only the last two
groups of generators.
3.1.1 Number of Generators
To determine the number of generators of sealed nickel-cadmium (ni-cd) batteries, EPA
first considered how many of the total number of all hazardous waste generators fall into the
three generator categories: conditionally exempt small quantity generators, small quantity
generators, and large quantity generators. EPA's RCRA Data Summary provides estimates for
the total number of all CESQGs (480,000), SQGs (180,000), and LQGs (20,000) (for a total of
680,000 hazardous waste generators).7 Based on discussions with industry, EPA estimated
percentages of all these hazardous waste generators that generate used ni-cd batteries: 50
percent for conditionally exempt generators, 67 percent for small quantity generators, and 75
6 Honeywell is currently developing its own reverse distribution system for mercury-
containing thermostats.
7 In the RCRA Data Summary estimates of the number of CESQGs and SQGs are
based on EPA's analysis for the Small Quantity Generator Regulatory Impact Analysis.
which was completed in 1986. Estimates of the number of LQGs are based on the results of
EPA's 1989 Biennial Report survey.
-------
:. 3-3
percent for large generators.8 Applying these percentages to the total number of all generators
hi each of these generation categories yields the following estimates of generators of sealed ni-cd
batteries: 240,000 conditionally-exempt small quantity generators, 120,000 small quantity
generators, and 15,000 large quantity generators.9 It appears that generators would be likely
to change batteries biennially.10 Therefore, the Agency assumed that one-half of all generators
have ni-cd batteries to dispose of in any given year. The resulting estimates of the generators
of sealed nickel-cadmium batteries appear hi Exhibit 3-1.
3.1.2 Number of Batteries Disposed
EPA estimated the total number of sealed ni-cd batteries generated by non-households for
disposal by apportioning the total number of ni-cd batteries annually entering the waste stream
(165 million, rounded to 170 million for this analysis)11 among an estimated number of
household generators (60 percent, or 100 million, rounded from 102 million) and non-household
generators (40 percent, or 70 million, rounded from 68 million).12
3.1.3 Total Quantity Disposed
Based on data provided by the battery industry, EPA estimated the total quantity of sealed
ni-cd batteries generated for disposal annually to be 14 million pounds.13 Apply ing the same
percentage allocation used to estimate the number of non-household batteries generated (i.e.,
total generation that was split between 60 percent household and 40 percent non-household use),
the Agency estimated 5.6 million pounds of sealed ni-cd batteries were generated by non-
households. Of this 5.6 million pounds, large quantity generators account for 20 percent by
8 The proportions of generators for each type of RCRA generator are based on personal
communication with Mark Schweers of INMETCO, September 1993. INMETCO is a major
recycler of ni-cd batteries, and estimates are based on knowledge of their client base.
9 EPA found no indication that generation of sealed ni-cd batteries, or any other
universal waste, would cause facilities to change RCRA-generator categories (e.g., from
CESQG to SQG, or SQG to LOG).
10
Personal communication with Mark Schweers of INMETCO, September 1993.
11 Draft "Market Analysis and Projected Used Battery Discards," prepared by the
Portable Rechargeable Battery Association, August 1993, Exhibit 1.
12 The Agency estimated the percentage of batteries generated from households versus
non-households based on an EPA communication to Paul Borst, U.S. EPA, from Panasonic
Industrial Company, May 14, 1992. For the current analysis, EPA confirmed the accuracy
of this estimate with representatives of the Portable Rechargeable Battery Association.
13 Draft "Market Analysis," Portable Rechargeable Battery Association, August 1993.
-------
3-4
weight.14 This means that they generate approximately 1.1 million pounds of sealed ni-cd
batteries. Non-LQGs account for the remaining 80 percent. EPA allocated this remaining
quantity of batteries (4.1 million pounds) by the percentage of sealed ni-cd battery generating
non-LQGs that were CESQGs (67 percent) and SQGs (33 percent) (allocation from section
3.1.1.). All estimates were rounded for presentation in Exhibit 3-1.
Exhibit 3-1
Generators and Annual Quantity of Sealed Nickel-Cadmium Battery Waste
Type of Generator
Conditionally Exempt Small
Quantity Generator
Small Quantity Generator
Large Quantity Generator
Number of
Generators
120,000
60,000
8,000
Annual Number of
Waste Batteries
28,000,000
17,000,000
11,000,000
Annual Quantity of
Waste (1,000
pounds/year)
2,800
1,700
1,100
3.2 Vented Nickel-Cadmium Batteries
EPA developed estimates of the number of waste generators of vented nickel-cadmium
batteries in various size categories, the number of waste batteries generators produce per year,
and the amount of battery waste (in pounds) these generators annually produce. The categories
of waste generators covered hi the Agency's estimates include CESQGs, SQGs, and LQGs,
although the Agency proposed changes to the regulations applicable to only the last two groups
of generators.
3.2.1 Number of Generators
In analyzing the number of generators of vented ni-cd batteries, EPA determined that
virtually all generators of vented ni-cd batteries are large quantity generators.15 EPA found the
universe of LQGs to be 670, based on estimates of the number of generators hi various sectors
of industry, including airlines, railroads, and transit authorities, among others.16 Exhibit 3-2
14 Personal communication with Jeff Bagby of Weinberg, Bergeson, and Neuman,
attorneys representing the Portable Rechargeable Battery Association, August 1993. This
estimate is based on analysis of the sources of sealed ni-cd battery generation.
15
1993.
Personal communication with Hugh Morrow of the Cadmium Council, September,
16 This estimate is based on data provided by Hugh Morrow of the Cadmium Council,
who solicited this information from major producers of vented ni-cd batteries, September,
1993.
-------
3-5
presents the number of LQGs of vented ni-cd batteries and the total volume generated annually.
Small quantity generators of vented ni-cd batteries were excluded from this analysis because of
the small number of generators in the universe (less than five) and the low volume of waste
generated.17
Exhibit 3-2
Generators and Annual Quantity of Vented Nickel-Cadmium Battery Wastes
Type of Generator
Conditionally Exempt Small Quantity
Generator
Small Quantity Generator
Large Quantity Generator
Number of
Generators
less than 5
less than 5
670
Annual Number of
Waste Batteries
< 50
< 50
18,000
Annual Quantity of
Waste (1,000
pounds/year)
< 1
< 1
350
3.2.2 Number of Batteries Disposed
EPA determined the number of batteries and total quantity of waste batteries to be
insignificant for both CESQGs and SQGs, based on consultation with INMETCO.18 Therefore,
the waste generation quantity of batteries for LQGs equaled the total quantity of vented ni-cd
batteries generated annually.
3.2.3 Total Quantity Disposed
EPA developed an estimate of the annual quantity of vented ni-cds disposed based upon
data provided by industry on the usage of vented ni-cd batteries. EPA obtained estimates of the
total power of batteries used by four groups (airlines, transit authorities, railroads, and other
industry) hi terms of million ampere hours per year and the average battery lifespan hi these
industries.19-20 Assuming an equal weight of batteries is taken out of service yearly hi each
of these four industries over the course of the typical lifespan of the batteries, EPA estimated
that 350,000 pounds of vented ni-cd batteries would be generated annually. Because the
production of vented ni-cd batteries is not concentrated among a small set of firms, EPA was
17 Personal communication with Mark Schweers of INMETCO. Mr. Schweers provided
this information based on knowledge of the client base of his company, September, 1993.
18 Ibid.
19 Personal communication with Hugh Morrow of the Cadmium Council, August 1993.
20 EPA estimate is based on a power-to-weight conversion factor of 28 ampere hours
per kilogram, (see Encyclopedia of Chemical Technology, volume 3, p. 987, 4th ed.).
-------
3-6
not able to determine annual production levels. For this analysis, EPA assumed that the market
for vented ni-cd batteries is mature. Under this assumption, waste generation would equal
annual production and both production and waste generation would be stable. -
3.3 Mercuric-Oxide Batteries
The methodology used to estimate the number of generators and total volumes of
mercuric-oxide batteries varied for each generator size category. The approach used for each
generator group is presented below. The total volume of mercury batteries is presented, by
generator size category, in Exhibit 3-3.
Exhibit 3-3
Generators and Annual Quantity of Mercuric-Oxide Battery Waste
Type of Generator
Conditionally Exempt Small
Quantity Generator
Small Quantity Generator
Large Quantity Generator
Number of
Generators
3,600
800
225
Annual Number of
Waste Batteries
3,600
2,600,000
190,000
Annual Quantity of
Waste
(1,000 pounds/year)
< 1
310
190
3.3.1 Conditionally Exempt Small Quantity Generators
Professional photographers are the only significant non-household users of mercury button
cells, and EPA concluded that no other type of mercuric-oxide cell would be generated by
CESQGs.21 EPA determined the number of CESQGs by consulting with the Professional
Photographers Association, which stated that of the 18,000 professional photographers, one hi
five, or 3,600, still use mercuric-oxide batteries.22 EPA assumed an average life of one year
per mercuric-oxide battery,23 with an average weight of 3.6 grams per battery.24 Therefore,
the estimated total weight of the mercury battery wastes generated by CESQGs is less than 1,000
pounds per year.
21 Personal communication with Ray Balfour of Rayovac Corporation, August 1993.
22 Personal communication with Alan Simpson of the Professional Photographers
Association, August 1993.
23
Ibid.
24 Used Dry Cell Batteries, prepared by U.S. EPA, Office of Solid Waste, December
1992, p. 52.
-------
? 3-7
3.3.2 Small Quantity Generators
The number of SQGs generating mercuric-oxide batteries was based on estimates from
the American Hospital Association (AHA).25 The AHA indicated that roughly one tenth of all
hospitals (8,000) still use mercuric-oxide batteries.26 All but approximately three percent of
the hospitals were estimated to be SQGs.27
EPA derived the total number of mercuric-oxide batteries by taking the average number
of mercuric-oxide batteries per hospital (3,2QO?S and multiplying this by the total number of
hospitals that are SQGs (800),29 This resulted in a waste generation rate of 2.6 million
batteries per year. The number of batteries generated annually was then multiplied by the
average weight of an 8.4 volt mercuric-oxide battery (1.9 ounces)30 to derive a total waste
volume of 310,000 pounds for SQGs.
3.3.3 Large Quantity Generators
EPA estimated that there are 225 LQGs that generate mercuric-oxide batteries. This
estimate was based on communications with three sources. A representative of Bethlehem
Apparatus indicated that used mercuric-oxide batteries generated at federal facilities are
generated by 100 contractors who are all LQGs.31 In addition to this, EPA estimates that there
are 200 major railway companies, half of which generate used mercury batteries.32 The total
number of LQGs also includes the 25 LQG hospitals that the American Hospital Association
estimated to exist.33
25 Personal communication with Bob Turk of the American Hospital Association, August
1993.
26 Ibid.
27 Ibid.
28 Estimate based on data in Price, "Managing Mercury Battery Wastes through Source
Substitution," MSW Management. January/February 1992, p. 16.
29 Personal communication with Bob Turk of the American Hospital Association August
1993.
30 Personal communication with Bruce Lawrence of Bethlehem Apparatus, a major
recycler of mercury-containing batteries, August 1993.
31 Ibid.
32 Personal communication with Hugh Morrow of the Cadmium Council, August 1993.
33 Personal communication with Bob Turk of the American Hospital Association.
-------
3-8
Estimates of waste generation quantities for LQGs were obtained by subtracting the
quantities for CESQGs and SQGs from the total generation rates. The total generation rates
were determined through consultation with a mercury battery recycling company.34 Based on
this knowledge, EPA estimated total waste generation quantities of mercuric-oxide batteries to
be 500,000 pounds per year. Accordingly, EPA subtracted the quantities estimated for CESQGs
and SQGs to estimate the total quantity generated by LQGs.
3.4 Used Mercury-containing Thermostats
EPA developed estimates of the number of waste generators of mercury-containing
thermostats in various size categories, the number of mercury-containing thermostats produced
per year, and the amount of battery waste (in pounds) these generators produce annually. The
categories of waste generators covered in the Agency's estimates include CESQGs, SQGs, and
LQGs, although the Agency proposed changes to the regulations applicable to only the last two
groups of generators.
3.4.1 Number of Generators
Exhibit 3-4 presents the number of generators of mercury-containing thermostats and the
annual quantity of thermostat wastes they generate. The primary groups generating mercury-
containing thermostats are:
o Heating, ventilation and air-conditioning (HVAC) contractors;
o Wrecking and demolition firms; and
o Firms using in-house maintenance workers.
Each of these categories is discussed below.
Exhibit 3-4
Generators and Annual Quantity of Mercury-Containing Thermostat Waste
Type of Generators
Conditionally Exempt Small
Quantity Generator
Small Quantity Generator
Large Quantity Generator
TOTAL
Number of
Generators
83,000
13,000
1,400
97,000
Annual Number of
Waste Thermostats
1,200,000
210,000
7,000
1,400,000
Annual Quantity of
Waste
(1,000 pounds/year)
180
32
1
210
34 Personal communication with Bruce Lawrence of Bethlehem Apparatus.
-------
3-9
EPA estimated that there are approximately 50,000 heating, ventilation, and air
conditioning (HVAC) contractors.35 EPA has assumed that nearly all of these are CESQGs,
except for roughly 30 extremely large firms.36
There are 1,200 firms specializing in wrecking and demolition work.37 Based on a
discussion with representatives from the Demolition Contractors of America, EPA estimated that
half of these firms are CESQGs and half are SQGs.38
EPA estimated that five percent (225,000) of the approximately 4.5 million mercury-
containing thermostats generated each year are generated by firms using in-house maintenance
workers and that these workers remove 1 to 500 thermostats per year, with a typical generator
removing 5 per year. Based on these assumptions, EPA estimated that 45,000 generators fall
into this category hi any given year. EPA apportioned the 45,000 facilities by the percentage
of all hazardous waste generators within each class (CESQGs, SQGs, and LQGs). There are
a total of 680,000 generators of hazardous waste with a break down of 480,000 CESQGs,
180,000 SQGs, and 20,000 LQGs. This ratio indicates that 71 percent of the 45,000 firms using
in-house maintenance are CESQGs. This, along with the other two sources of CESQGs,
provided the basis for EPA's estimate of 83,000 CESQGs.
EPA also determined that 26 percent of generators conducting in-house maintenance are
SQGs based on the ratio of SQGs of hazardous waste (180,000), and the total number of
hazardous waste generators (680,000). EPA apportioned 26 percent of the 45,000 facilities
performing in-house thermostat removal to arrive at an estimated 11,700 SQGs conducting in-
house maintenance. For its analysis, EPA rounded this number to 12,000. There were 600
wrecking and demolition firms which EPA assumed to be SQGs, as well as approximately 30
HVAC contractors which EPA also assumed to be SQGs. This resulted hi a total estimate of
12,630 SQGs of mercury-containing thermostats, a number which EPA rounded to 13,000 for
its analysis.
EPA estimated the number of LQGs using the same methodology used to estimate the
number of CESQGs and SQGs. The number of LQGs (20,000) compared to the total number
of hazardous waste generators (670,000) resulted in a 3 percent portion of the 45,000 facilities
performing in-house maintenance, for an estimate of 1,400 LQGs of mercury-containing
thermostats.
35 "Estimates for Generation of Out-of-Service Thermostats," prepared by Nancy Onkka
of Honeywell, September 16, 1993.
36 Ibid.
37 Based on information contained in the 1987 Census of Construction Industries.
Bureau of the Census.
38 Personal communication with Mike Taylor of the Demolition Contractors of America,
September 1993.
-------
3-10
3.4.2 Number of Thermostats Disposed
In estimating the total number of used mercury-containing thermostats, EPA consulted
with representatives from Honeywell to develop an estimate of 4 million to 5 million thermostats
removed from service annually.39 This estimate includes thermostats removed from either
residences or businesses. EPA used the midpoint of this estimate, 4.5 million, for its analysis.
Out of the 4.5 million thermostats removed from service annually, EPA estimated that 75
percent, or roughly 3.4 million, are residential thermostats removed by HVAC contractors.40
EPA estimated that only 35 percent, or roughly 1.2 million, of these 3.4 million thermostats are
retained by the HVAC contractors removing them, with the remainder being left with the
homeowner. Thus, HVAC contractors generate roughly 1.2 million thermostats annually. EPA
determined that firms using in-house maintenance staff are generated mercury-containing
thermostats; the Agency estimated that approximately 5 percent, or 225,000, of the 4.5 million
thermostats removed from service annually are generated by such firms.
To determine how many thermostats are generated by CESQGs, EPA considered two
sources: (1) HVAC contractors that are CESQGs, and (2) in-house maintenance staff at facilities
that are CESQGs. The Agency estimated that the number of thermostats removed from service
in homes and retained by CESQG-HVAC contractors is roughly 1.0 million, which assumes that
nearly all HVAC contractors are SQGs. Of the 225,000 thermostats removed by in-house
maintenance staff, the Agency estimated that 71 percent, or 159,750 (rounded to 160,000 for
EPA's analysis), are generated at facilities that are CESQGs. The resulting total number of
thermostats that EPA estimated are generated by CESQGs is approximately 1.2 million.
EPA estimated that 26 percent, or 58,500 (rounded to 60,000 for EPA's analysis) of the
225,000 thermostats generated by firms using in-house maintenance staff are removed from
service at facilities that are SQGs. EPA determined that 30 HVAC contractors are SQGs also.
Based on knowledge of the industry, EPA assumed that each of the 30 SQG-HVAC contractors
generates 5,000 thermostats annually,41 for a total of 150,000 thermostats generated by SQG-
HVAC contractors per year. The Agency developed its estimate of 210,000 thermostats
generated annually by SQGs by combining the 150,000 thermostats generated by SQG-HVAC
contractors with the roughly 60,000 thermostats generated by in-hose maintenance staff at
facilities that are SQGs.
The only LQGs of thermostats are firms using in-house maintenance staff at facilities that
are LQGs. EPA apportioned three percent of the 225,000 thermostats removed by in-house staff
to facilities that are LQGs, for a total of 6,750 thermostats (rounded to 7,000 for EPA's
analysis).
39 "Estimates," prepared by Nancy Onkka of Honeywell.
40 Ibid.
41 Ibid.
-------
3-11
3.4.3 Total Quantity Disposed
EPA estimated the total quantity for each class of generator by using an average weight
of 0.15 pounds per thermostat.42 This estimate was applied to the total number of thermostats
generated to estimate the total quantity generated, hi pounds per year, for each class of
generator.
3.5 Recalled Pesticides
The Universal Waste Rule would allow generators (i.e., distributors and retail outlets)
of pesticide waste to follow reduced RCRA hazardous waste management requirements hi the
event that the pesticide was a listed or characteristic hazardous waste. It is difficult to predict
the nature and amount of material that will be subject to future recalls as well as whether or not
the recalled material would be hazardous waste under RCRA.
Given the history of pesticide recalls and the plans of the Office of Pesticide Programs,
EPA developed a plausible scenario of when the Agency would recall pesticides that would be
considered hazardous wastes. EPA assumed that a national pesticide recall that covers
50,000,000 pounds of product that would be hazardous waste would occur once every five years.
The material would be hi the possession of 20,000 businesses (generators). Because, on
average, these businesses would generate more than 1,000 kilograms of pesticide waste hi one
month, they are assumed to be large quantity generators. The number of generators existing
each tune a national recall occurred was taken from the Cost Analysis of Hypothetical Pesticide
Recall Actions. U.S. EPA, Office of Pesticide Programs, July 19, 1991. This analysis had
considered the cost implications of national recalls of pesticide products when OPP developed
proposed pesticide recall procedures. These generator and generation estimates are provided in
Exhibit 3-5.
Exhibit 3-5
Generators and Quantity of Waste
in a Typical Pesticide Recall Where
the Material Would Be a Hazardous Waste
Large National Recall
Number of Large
Quantity Generators
20,000
Total Waste Amount
(1,000 pounds/year)
50,000
42
"EPA's Proposed Collection System Regulations for Recycling Hazardous Waste,"
Letter from Margaret Graves, Latham & Watkins (attorneys for Honeywell) to Mike Petruska,
U.S. EPA, Office of Solid Waste, p. 16.
-------
3-12
3.6 Total Generators Covered by the Universal Waste Proposal
EPA estimates that there is considerable overlap between the generators of several of the
universal wastes covered in the economic impact analysis. Applications using sealed ni-cd
batteries, especially portable computers, two-way communication devices, and portable tools,
are increasingly common. Representatives at several trade associations and recyclers that EPA
contacted indicated that nearly all generators of vented ni-cd batteries, mercuric-oxide batteries,
and mercury-containing thermostats would also generate sealed ni-cd batteries.43 Accordingly,
EPA is assuming that the generator universes for vented ni-cd batteries, mercuric-oxide batteries,
and mercury-containing thermostats totally overlap the universe for sealed ni-cd batteries.
Taking this overlap into account, EPA estimates there are about 83,000 large and small quantity
generators of batteries and thermostats covered by the Part 273 Rule proposal that annually
produce 3,683,000 pounds (1,842 tons) of universal waste. Additionally, EPA estimates that
there will be another 20,000 generators of recalled pesticide wastes that will have to meet EPA's
Part 273 rules when recalls periodically occur.
43 Hugh Morrow of the Cadmium Council, Norm England of the Portable Rechargeable
Battery Association, Bruce Lawrence of Bethlehem Apparatus, and Mark Schweers of
INMETCO, October, 1993.
-------
CHAPTER 4. COST ANALYSIS METHODOLOGY
This chapter presents EPA's methodology for estimating the savings that would result
from generators of universal wastes complying with the proposed Part 273 requirements rather
than the full RCRA Subtitle C requirements. Section 4.1 provides an overview of the approach
used in the cost analysis. Section 4.2 presents the generator activities analyzed for the full
RCRA Subtitle C requirements and their unit costs. Section 4.3 presents the generator activities
for each compliance option under the proposed Part 273 Rule and their unit costs.
4.1 Overview of the Cost Analysis Approach
For this Economic Impact Analysis, EPA estimated the incremental cost differences
between compliance with the full RCRA Subtitle C requirements and the proposed Part 273 Rule
for generators of universal wastes. The universal wastes examined for this analysis include:
o Vented nickel-cadmium batteries,
o Sealed nickel-cadmium batteries,
o Mercuric-oxide batteries,
o Used mercury-containing thermostats, and
o Recalled pesticides that are hazardous wastes.
For each of these types of hazardous waste, the Agency identified and estimated the costs
of all the requirements that should result in an incremental cost difference between the existing
full RCRA Subtitle C regulations and the proposed Part 273 Rule. EPA reviewed how wastes
would move through the RCRA system from the generator to the final treatment facility (referred
to as the "destination" facility in the proposed Part 273 Rule) hi order to identify the areas where
compliance costs would differ from the full RCRA Subtitle C requirement costs.
The Agency considered the annual compliance costs that would result from four different
compliance options under the proposed Part 273 Rule for generators of each type of hazardous
waste battery and thermostats covered in this analysis. For each type of waste generator, the
Agency identified the least-cost method of compliance with Part 273 hi order to determine the
savings that would result from generators no longer complying with the full RCRA
requirements.44 Because the nature, size, and frequency of pesticide recalls will vary, the
Agency consulted with the Office of Pesticide Programs (OPP) to develop a likely recall scenario
for estimating the costs of the proposed Part 273 Rule. EPA decided to consider the annualized
incremental cost savings that could result from a national recall of a pesticide that was a
hazardous waste once every five years over a 20-year tune period.
In estimating the baseline costs associated with full RCRA Subtitle C compliance, EPA
assumed that all generators of universal wastes are currently in compliance. Therefore, sunk
44 Due to the difference in volumes handled by the different generator types, the least-
cost method was not the same for every type of hazardous waste battery and thermostat
generator.
4-1
-------
4-2
costs, such as obtaining an EPA ID number, were not considered in this analysis. Only the
costs of compliance activities which were expected to vary between the full RCRA Subtitle C
requirements and the proposed Part 273 requirements were included in this analysis. Therefore,
the compliance costs presented hi this analysis for the full RCRA Subtitle C requirements and
the proposed Part 273 Rule are partial compliance costs that enable estimation of the incremental
cost savings from the Part 273 proposal, rather than total compliance costs of each set of rules.
For the analysis of pesticide recalls, the Agency annualized the costs over a 20-year period using
a 7 percent discount rate. All costs presented in this analysis are reported as 1992 dollars.45
EPA recognized that some generators generate several types of wastes covered by the
Universal Waste proposal. This most frequently occurred for generators of different types of
ni-cd batteries. It was also apparent that the costs covered hi the analysis were largely variable
costs associated with the individual wastes. Given these facts, EPA constructed the analysis to
focus on variable cost differences between generators handling different universal wastes under
the proposed Part 273 Rule and the full RCRA Subtitle C requirements. This led to a separate
analysis of each type of universal waste covered hi the economic impact analysis and the
generators that produce it.
The focus of EPA's analysis was the savings that the proposed Universal Waste Rule
would provide the regulated community when compared to the full federal RCRA Subtitle C
requirements. Current state requirements, plans, and expected response to the proposed Part 273
Rule were not factored into the economic impact analysis.
4.2 Type of Unit Costs and Their Sources
The unit costs used hi the analysis of battery and thermostat wastes are annual recurring
costs. The unit costs for pesticide recalls are the cost of generators shipping wastes to
consolidation facilities and the development and/or use of a facility over a one-year period each
tune a recall occurs.
EPA obtained unit costs for both sets of requirements from personal communications with
industry experts, existing EPA documents, and specially developed estimates for this analysis.
The specific unit costs used hi the analysis of each compliance option are presented hi the section
that discusses that particular compliance option. The sources of the unit costs are presented in
Appendix A.
4.3 Cost Elements for Full RCRA Subtitle C Compliance
The costs of the full RCRA Subtitle C requirements that EPA used for this analysis are
based on the future costs to generators complying with existing RCRA hazardous waste
requirements. Within that set of expected future costs, EPA examined only the cost of those
45 This was done by inflating the costs in earlier years through the use of Gross
Domestic Product deflators and reporting the current cost (or service price) estimates as
1992 dollars that were obtained from commercial treatment facilities, transporters, and other
sources.
-------
4-3
activities that are likely to differ between the full RCRA Subtitle C and Part 273 requirements,
due to either differing requirements, or the existence of different economies of scale. Sunk costs
that result from generators' past actions to comply with RCRA Subtitle C were not considered
in this analysis. Furthermore, EPA assumed that generators of batteries, thermostats, and
recalled pesticides that will be hazardous wastes already comply with all of the full RCRA
Subtitle C requirements.
4.3.1 Batteries and Used Thermostats
Because the shipping, storage, and packaging requirements discussed for used thermostats
are the same as those proposed for batteries, the Agency examined the economic impacts of the
special collection rule on these two waste types in one analysis. All costs were divided into one
of three categories: on-site costs, shipping costs, or reclamation costs. Reclamation costs
(rather than disposal costs) are incurred by generators of batteries and thermostats because under
RCRA's Land Disposal Restrictions (LDRs), generators are required to treat their waste to Best
Demonstrated Available Technology (BOAT) levels. The BOAT is mercury retorting for
mercury-containing batteries and thermostats (i.e., high mercury D009 wastes) and thermal
recovery for nickel-cadmium batteries (i.e., D006 wastes).
The cost elements comprising the on-site cost portion of the analysis under full RCRA
Subtitle C requirements included:
o
o
o
o
o
o
Employee training;
Maintenance costs for a contingency plan;
Packaging of wastes in accordance with Department of Transportation (DOT)
specifications for hazardous waste;
Filing biennial reports;
Manifest completion and recordkeeping per shipment; and
LDR Notification.
Training costs included an annual refresher course for employees that was assumed to
be taught to an average of four employees by a professional trainer for $300 per course. The
initial establishment of a training program and training of employees was assumed to already
have occurred and is a sunk cost. Training of the four employees was assumed to take two
hours each at a loaded labor rate of $27 per employee hour. Additionally, one hour of a plant
manager's tune at $60 per hour (loaded) was required per generator, as well as one half hour
of clerical time for recordkeeping required under Part 262. The loaded rate for a clerical
person's time was estimated at $20 per hour. Exhibit 4-1 provides the total annual training cost
per generator and the other full RCRA Subtitle C unit costs of compliance described below.
-------
4-4
Exhibit 4-1
On-Site Unit Costs of Full RCRA Subtitle C Requirements by Generator Type
(in 1992 dollars)
On-Site RCRA Requirement
Training Update
Contingency Plan Update
Packaging & Labeling Shipments
Biennial Report (annualized)
Manifest Completion and Recordkeeping
Land Ban Notification
Annual Costs Per:
Small Quantity Generator
$308
$200
$13.50 per shipment
2 shipments per year
N/A
$36 per shipment
2 shipments per year
$7.88 per shipment
2 shipments per year
Large Quantity Generator
$586
$200
$13.50 per shipment
4 shipments per year
$428
$36 per shipment
4 shipments per year
$7.88 per shipment
4 shipments per year
Maintenance costs for a contingency plan included the costs of updating and maintaining
the plan and were attributed to both small quantity generators and large quantity generators. The
costs of developing the initial plan were considered sunk costs for a facility in compliance and
were therefore not included hi the analysis.
The costs attributed to packaging wastes hi accordance with DOT specifications included
the labor and materials costs per shipment. Costs of reading and understanding DOT regulations
were considered sunk costs. LQGs, who can accumulate wastes for no longer than 90 days
without a RCRA permit, were assumed to make four shipments of waste per year. SQGs were
assumed to ship wastes twice a year due to the increased accumulation time allowed for
generators in this category.
Biennial reporting costs were attributed to LQGs only. Small quantity generators are not
required to submit the biennial report. The costs of the report were spread over two years to
provide annualized unit costs consistent with the cost factors in this analysis. The Biennial
report was assumed to take 9.5 hours per year to complete by a plant engineer, or equivalent
(an engineer's hourly loaded labor rate is $45).
Per shipment manifesting and manifest recordkeeping costs were attributed to SQGs and
LQGs on a per shipment basis. Costs associated with LDR notification were incurred by both
small quantity generators and large quantity generators. LDR notification costs were attributed
on a per shipment basis with SQGs shipping wastes twice a year and LQGs shipping four times
a year.
Export notification was not included as part of the shipping costs under the full RCRA
Subtitle C requirements. EPA contacted industry representatives hi order to estimate the
frequency and likelihood of exportation. According to industry experts, it is no longer
-------
, : 4-5
economically attractive to export these wastes for either disposal or reclamation.46 Exporters
currently are charging a fee to receive batteries and thermostats for export rather than paying
generators for them as they have in the past. Therefore, EPA assumed all generators were
shipping their waste to treatment facilities within the United States.
The sole shipping cost element under the full RCRA Subtitle C requirements was the cost
of transporting the waste from the generator to the reclamation facility. To estimate
transportation costs, the Agency assumed the generator shipping distance to the destination
facility to be 1,500 miles using a hazardous waste carrier. This assumption was based on a large
number of generators throughout the country shipping wastes to a limited number of facilities.
An existing thermal recovery facility that can be used for reclamation of ni-cd batteries is located
in Pennsylvania; an existing pretreatment facility for batteries is located in California; and
existing mercury-retorting facilities reclaiming mercuric-oxide batteries and mercury-containing
thermostats are located in Pennsylvania and New York.47 EPA assumed large quantity
generators would have lower per pound transportation costs than small quantity generators due
to the existence of economies of scale for transportation of full truck loads and shipments that
occur without as many stops. Because per pound hazardous waste transport costs were
unavailable, EPA estimated variations hi hazardous waste transport costs by comparing the
relationship between the long distance hazardous waste transportation costs provided in EPA's
1990 Survey of Selected Hazardous Waste Management Industry to common carrier costs for
long distance shipments when each is carrying a full loaded truck. Comparing the relationship
between costs showed that hazardous waste transporter charges were approximately 1.3 tunes
those of a common carrier. Because partial load costs were not available for hazardous waste
transport and EPA had obtained partial load common carrier costs, common carrier costs were
multiplied by a factor of 1.3 hi order to estimate hazardous waste transport costs. For shipments
of 138 pounds or less, the generator was assigned a transporter fixed minimum charge of
approximately $78. The actual shipping costs for each generator size under the full RCRA
Subtitle C requirements are presented hi Exhibit 4-2.
Notably, the EPA survey of hazardous waste transporter prices included the costs of the
use of transfer facilities to move waste to commercial treatment facilities. Therefore, the costs
of the current reliance on transfer stations is captured in the unit costs hi Exhibit 4-2.
46 Based on conversations with Ann Mossbarger of Sanyo Energy Corporation, Marlene
Booth of INMETCO, and Saskia Mooney of Weinberg, Bergeson, and Neuman
(representing the Portable Rechargeable Battery Association).
47 Existing treatment facilities for mercury retorting are: Bethlehem Apparatus,
Hellertown, Pennsylvania, and Mercury Refining, Schenectady, New York. Existing Ni-cd
thermal recovery facility is: INMETCO, Pittsburgh, Pennsylvania. Existing pretreatment
facility for batteries is: Kinsbursky Brothers, Anaheim, California.
-------
4-6
Exhibit 4-2
Shipping Costs for Full RCRA Subtitle C Requirements
(in 1992 dollars)
Shipment Size1
(hi pounds)
Shipments <200 pounds
Shipments of 388 pounds
Shipments of 522 pounds
Shipments of 844 pounds
Per Generator Unit
Cost
$78. 12 (fixed
minimum)
$130.20
$149.97
$242.48
1 These shipment sizes match up to the average annual wastes
produced by different size generators of batteries and thermostats.
The Agency obtained prices for reclamation through personal communications with
facilities currently treating these wastes.48 Reclamation prices varied depending on the size of
the waste shipment received by the treating facility. The prices (unit costs) for mercury and ni-
cd reclamation are listed by waste shipment ranges in Exhibit 4-3. In general, the Agency
selected the lowest prices quoted by commercial facilities for the analysis, assuming generators
would be price sensitive in meeting EPA's regulatory requirements.
Exhibit 4-3
Full RCRA Subtitle C Requirements
Reclamation Costs for Mercury and Ni-cd Batteries and Thermostats
(hi 1992 dollars)
Material/Shipment Size
Mercury waste shipment < 500 pounds
Mercury waste shipment 500 - 5,000 pounds
Vented ni-cd shipment (any size)
Sealed ni-cd shipment (any size)
Cost per Pound
$2.85
$2.60
$0.26
$0.24
48 Personal communication with: Bruce Lawrence of Bethlehem Apparatus; Alan Wilds
of Mercury Refining; Todd Coy of Kinsbursky Brothers; and Mark Schweers of INMETCO,
September, 1993.
-------
4-7
The cost associated with each cost element were summed to obtain the total costs per
generator for both SQGS and LQGs. Per generator incremental costs for each generator group
under full RCRA Subtitle C compliance are presented in Exhibit 4-4. Per generator costs for
each generator group were then multiplied by the number of generators in each waste and size
category to estimate the total cost of full RCRA Subtitle C compliance per generator group that
are presented hi Chapter 5, Results of Cost Analysis.
Exhibit 4-4
Per Generator Annual Costs for Complying with Full RCRA Subtitle C Requirements
Hazardous Waste Batteries and Thermostats
(in 1992 dollars)1
Universal
Waste
Coverage
liermos&ts
SQGs
LQGs
V t^A W.i"Vi R
LQGs
Average
Annual Waste
Per Generator
(pounds)
Per Generator Annual Costs:
On Site
Shipping
Reclamation
Total Annual
Costs Per
Generator
'
2
1
$623
$1,444
$78.12
$78.12
$5.70
$2.85
$707
$1,525
at8*0e$ "i s
522
$1,444
$149.97
$135.72
$1,730
Sealed M-C3 Batteries" '
SQGs
LQGs
i IsleiOBtl^Oxiae
SQGs
LQGs
28
138
$623
$1,444
$78.12
$78.12
Usuries ^
388
844
$623
$1,444
$130.20
$242.48
$6.72
$33.12
s
$1,105.80
$2,194.40
$708
$1,555
s "
$1,859
$3,881
1 Costs are for the annual future costs of compliance that are different than the costs generators will have under
the proposed Part 273 Rule.
2 There were less than five SQGs with vented ni-cd batteries. They were excluded from the analysis due to
their insignificance in estimating cost savings from the proposed Part 273 Rule.
-------
4-8
4.3.2 Recalled Pesticides
In order for a recalled pesticide to become a hazardous waste, it must first become a
solid waste. In the event of an EPA recall, the recall statement could designate the pesticide
registrant's intention to do one of five things with the recalled product:
o Dispose of the pesticide,
o Burn it for energy use,
o Incinerate it,
o Reformulate it, or
o Reuse or recycle it.
In order for the pesticide to become a solid waste, the registrant or recall notice must
specifically state the intention to burn the pesticide for energy use, dispose of it, or incinerate
the recalled product. If the intent to dispose or burn the pesticide is not specifically stated hi
the recall notice, the pesticide would remain a product being reshipped rather than a solid waste.
EPA predicts that many of the recalled pesticides that become solid wastes will either fail one
of the RCRA hazardous waste characteristic tests and therefore be a hazardous waste, or will
already be listed under the RCRA Subtitle C regulations as hazardous waste.49
In order to develop annual estimates of current compliance costs for the full RCRA
Subtitle C requirements, the Agency estimated the costs of a major pesticide recall with
50,000,000 pounds of a pesticide product once every five years over a 20 year period. EPA
assumed that the registrants of the pesticide would consolidate it in eight different storage
locations prior to its disposal. The pesticide waste would be stored for one year prior to its
ultimate disposal. The storage facilities would have obtained RCRA permits for storage of the
pesticides and would not use these storage areas for other purposes afterwards. The Agency also
assumed that different pesticide registrants (i.e., manufacturers) were subjected to each EPA
recall leading to the permitting of additional waste storage over tune with each recall. Costs
were then discounted and annualized to estimate the yearly costs. EPA assumed that the
pesticide product would become a hazardous waste at the time of the recall notice. The Agency
assumed recalls would occur in years 3, 8, 13, and 18 of the 20-year period.
Costs for the pesticide analysis were disaggregated into on-site and storage costs.
Because the nature of a recall would prevent generators from accumulating waste over time and
taking advantage of economies of scale, disposal costs were assumed to be the same under full
RCRA Subtitle C requirements and the proposed Universal Waste Rule and were therefore
49 Unused pesticides would be discarded commercial chemical products and thus would
be listed under 40 CFR 261.33.
-------
4-9
excluded from the analysis50. On-site generator cost elements for the pesticide analysis
included:
o
o
o
o
o
Training,
Completion of a contingency plan,
Manifest completion and recordkeeping,
Biennial Reporting (annualized), and
LDR notification.
On-site unit costs are presented in Exhibit 4-5.
Exhibit 4-5
On-Site Full RCRA Subtitle C Requirements
Pesticide Analysis Unit Costs
(in 1992 dollars)
On-Site Cost Element
Training
Completion of a contingency plan
Manifest completion and recordkeeping
Biennial Report (annualized)
LDR Notification
Per Generator Unit Cost
$586
$2,000
$36.24
$428
$7.88
The RCRA-permitted storage facilities were assumed to be single story structures with
RCRA permits, insurance, concrete floors, temperature control, sprinkler systems, security, and
secondary containment. Costs for the eight storage facilities were obtained from EPA's Cost
Analysis of Hypothetical Pesticide Recall Actions. Costs for storage were presented in the
aggregate and therefore could not be broken down to the unit cost level. After inflating the costs
to 1992 dollars, the total storage costs are estimated to be $210,334,064 or $26,291,758 per
storage facility.
50Shipping costs were also assumed to be the same for the Subtitle C baseline
requirements and for the proposed Universal Waste Rule, based on the Cost Analysis of
Hypothetical Pesticide Recall Actions. U.S. EPA, Office of Pesticide Programs, July 19,
1991. Although there is some evidence that costs for the shipment of hazardous wastes
may be significantly greater than the cost for the shipment of other hazardous materials,
the difference in costs for waste pesticides could not be established without a carefully
designed survey, which was beyond the scope of this analysis.
-------
4-10
4.4 Cost Elements for Thermostats and Batteries under the Proposed Part 273 Rule
EPA analyzed four separate compliance options for thermostats and batteries under the
proposed Part 273 Rule. The primary differences between each of these options were the
different modes of transport generators would use to ship then: batteries and thermostats to a
consolidation point or reclamation facility. The four options considered are:
o Shipment of wastes by common carriers (trucks) to consolidation points (which then use
hazardous waste transporters to ship wastes to a destination facility);
o Shipping wastes directly to a reclamation facility via common carriers (trucks);
o Shipment of wastes via a parcel carrier (i.e., UPS); and
o For thermostats only, a reverse distribution system where generators ship their used
thermostats to Honeywell Corporation, that then has the mercury-containing component
(ampule) of the thermostat reclaimed by a commercial facility. ,
The assumptions and methodology for each option are presented separately in the
following sections. Although some activities of the proposed rule are identical to activities that
occur under full RCRA Subtitle C, the existence of differences in economies of scale led to
developing different unit costs for compliance with the proposed Part 273. Throughout the
analysis of each option, the Agency consistently assumed that all generators of hazardous waste
batteries and thermostats are shipping their waste to reclamation facilities within the United
States. This assumption was developed after numerous conversations between the Agency and
industry representatives regarding current export practices. Exporters currently are charging a
fee to export batteries and thermostats.51 According to industry experts, it is no longer
economically attractive to export these wastes for either disposal or reclamation.52
4.4.1 Generators Ship Waste to Consolidation Points
For this compliance option, generator costs were considered in four categories: on-site
costs, shipping costs, consolidation costs, and reclamation costs. On-site costs incurred by either
small or large quantity generators under the proposed rule are employee training and the bill of
lading. Employee training for both generator categories (small and large quantity) was assumed
to be comprised of a $200 training course or equivalent in-house work for each generator.
Additionally, generators were assumed to train 4 employees each for 1 hour at a laborer's wage
rate of $27. This resulted in a total per generator training cost of $308. The cost for the bill
of lading is $7.50 per shipment, which breaks down into a conservative estimate of six minutes
51 Based on conversation with Marlene Booth of INMETCO, October, 1993.
52
Based on conversations with Ann Mossbarger of Sanyo Energy Corporation, Marlene
Booth of INMETCO, and Saskia Mooney of Weinberg, Bergeson, and Neuman, October,
1993.
-------
4-11
of an engineer's time at a rate of $45 per hour to write up the bill of lading and three minutes
of a manager's time at a rate of $60 per hour to supervise the write-up.
Shipping costs included the cost of shipping the waste to a consolidation point as well as
pro rata costs of transporting the waste from the consolidation point to the reclamation facility.
Transportation from the generator to the consolidation point was based on an assumed distance
of 20 miles using common carrier (truck) transportation rates. Transportation costs were based
on rate schedules received from several common carriers. For all the shipment sizes in this
analysis (e.g., the average waste size per generator) for a distance of 20 miles, the generator
incurred the fixed rninimurn cost of the transporter.
Costs of shipping the total waste volume from the consolidation point to a reclamation
facility were assigned to generators on a pro rata basis, transportation from the consolidation
point to a reclamation facility were based on an assumed distance of 1,500 miles. Generators'
pro rata share of shipment from a consolidation point are approximately $0.11 per pound.
Transport costs from a consolidation point to a reclamation facility also included the cost of
manifesting the shipment and the prices charged by hazardous waste transporters. Manifest costs
incurred by consolidation points were assigned to generators on a per pound of waste generated
basis to spread the costs between the users of the consolidation point. Per generator costs of the
manifested shipment from the consolidation point were $0.0009 per pound. The unit cost
elements used to calculate shipping costs are presented below hi Exhibit 4-6.
Exhibit 4-6
Proposed Part 273 Requirements
Unit Costs for Shipping under the Consolidation Point Compliance Option
(in 1992 dollars)
Shipping Cost Element
Shipment from generator to a
consolidation point (20 miles)
Shipment from a consolidation point to a
reclamation facility ($2,817.40 per
shipment)1
Manifest costs
Unit Costs
$44. 14 (fixed minimum)
per generator
approximately $0.11 per pound of
waste
$0.0009 per pound of waste
1 Based on apportioning all the waste generated by CESQGs, SQGs, LQGs
between the 268 consolidation points assumed to exist.
EPA based the cost of operating a consolidation point on the assumption that one
consolidation point would exist per metropolitan statistical area (MSA). Each consolidation point
was assumed to receive an equal amount of the total waste volume. Given EPA's interest in
collecting batteries and thermostats from all types of generators (including conditionally exempt
-------
4-12
small quantity generators), the Agency developed model consolidation facilities capable of
accepting waste from all generators and assigned pro rata costs to the generator groups based
on their share of the total waste handled. Pro rata costs of operating a consolidation point are
approximately $0.50 per pound of waste.
The Agency calculated the size of each consolidation point for receiving thermostats and
batteries based on the amount of batteries and thermostats that could be packed in a 55-gallon
drum and storage arrangements for these drums that would allow easy inspection. Each
consolidation point was assumed to manage an equal volume of the total battery and thermostat
waste. Assuming 16.36 pounds of batteries/thermostats per gallon, stored hi full 55-gallon
drums, packed two deep, with four feet of aisle space between rows, EPA calculated that 112
pounds of waste could be stored per square foot of warehouse space.53 This resulted in a
warehouse size of 222 square feet. In calculating warehouse cost per square foot, the Agency
used an average cost for retail business space. EPA also assumed that each consolidation point
would have two employees, available one half day each week to accept waste at the consolidation
point.
Exhibit 4-7 presents the costs per consolidation point as well as the total national costs
for consolidation points. The annual costs per consolidation point were approximately $12,000,
which resulted hi total annual costs for consolidation points of $3.2 million.
Exhibit 4-7
Annual Consolidation Point Costs for
Hazardous Waste Thermostats and Batteries
(in 1992 dollars)
Waste Handled per Consolidation Point (Ibs)
Average Size of Warehouse (square feet)
Cost per Square Foot (annualized)
Employee Training (annual)
Labor (annual)
Annual Cost per Consolidation Point
Number of Consolidation Points
Annual Total Cost
24,862
222
$4.55
$308
$10,800
$12,118
268
$3,247,651
53 Based on personal communication with Bruce Lawrence of Bethlehem Apparatus who
stated that a 55-gallon drum of batteries weighed approximately 900 pounds.
-------
4-13
The Agency obtained unit costs for reclamation through personal communications with
facilities currently treating these wastes.54 Reclamation costs varied depending on the size of
the waste shipment received by the treating facility. Reclamation costs represent the per pound
cost the generator would pay the reclamation facility to accept their waste. The unit costs for
mercury and ni-cd reclamation were based on price structures the Agency obtained from
reclaimers and are listed in Exhibit 4-8.
Exhibit 4-8
Proposed Part 273 Requirements: Consolidation Points
Reclamation Costs for Mercury and Ni-cd Batteries and Thermostats
(in 1992 dollars)
Material/Shipment Size
Mercury waste shipment 500 - 5,000 pounds
Vented ni-cd waste shipment (any size)
Sealed ni-cd waste shipment (any size)
Cost per Pound
$2.60
$0.26
$0.24
The total annual per generator costs for complying with the Proposed Part 273 Rule by
shipping waste by common carrier (truck) to a consolidation point that later ships the waste by
hazardous waste transporter are presented in Exhibit 4-9. Total per generator costs are presented
by generator type and size category,
54 Personal communications with Bruce Lawrence of Bethlehem Apparatus; Alan Wilds
of Mercury Refining; Todd Coy of Kinsbursky Brothers; and Mark Schweers of INMETCO,
September, 1993.
-------
4-14
Exhibit 4-9
Annual Per Generator Costs for Complying with
the Proposed Part 273 Requirements
by Shipping Hazardous Waste Batteries and
Thermostats to Consolidation Points1
(in 1992 dollars)
Universal
Waste
Coverage
Average
Annual
Waste
(pounds)
Annual Per Generator Costs:
On Site
Shipping
Consolidation
(Pro Rata Share)
T&fctlttOSttfte s-^ ;"' ^ ' " " "'
SQGs
LQGs
2
1
$315.50
$315.50
$44.37
$44.25
$0.98
$0.49
Reclamation
$5.20
$2.60
Total
Annual Per
Generator
Costs
$366
$363
venf^m-ca^fes, s' ' /"' '.'
LQGs
Seated NK& I
SQGs
LQGs
522
tatfftfie*
28
138
Mercuric-Oxide Batteries^
SQGs
LQGs
388
844
$315.50
Sf
$315.50
$315.50
$103.77
$254.43
$135.72
, *""'
$47.34
$59.90
$13.65
$67.26
'- / "' - . " "'?' "
$315.50.
$315.50
$88.46
$140.55
$189.16
$411.37
$6.72
$33.12
f
$1,008.80
$2,194.40
$809
-
$383
$476
$1,602
$3,062
1 Note that these costs are for activities generators complete under the proposed Part 273 Rule that have different costs
than exist under the full RCRA Subtitle C rules.
4.4.2 Generators Ship Directly to a Reclamation Facility Via Common Carrier
(Truck)
For this compliance option, generator costs were considered in three categories: on-site
costs; shipping costs; and reclamation costs. As with the consolidation point option, the on-site
costs incurred by small or large quantity generators under the proposed rule are employee
training and the bill of lading. Employee training for both generator size categories (small and
large quantity) was comprised of a $200 training course or equivalent preparatory work for each
generator. Additionally, generators were assumed to train 4 employees each for 1 hour at a
laborer's wage rate of $27. This resulted hi a total annual per generator training cost of $308.
The bill of lading cost is .05 of a manager's tune at $60 per hour and . 10 of an engineer's tune
at $45 per hour for a total of $7.50 per shipment.
-------
4-15
To analyze the cost of shipments directly from the generator to a reclamation facility,
EPA assumed a distance of 1,500 miles from the generator to the reclamation facility. Because
the shipments were being transported directly to a destination facility, a manifest was not
required. EPA estimated the costs for transporting the waste based on communications with
representatives from several common carriers. The unit costs for shipping the waste amounts
used in this analysis are presented in Exhibit 4-10. To develop these costs, the Agency used an
average of two rate schedules provided. The Agency noted that some carriers establish rates
without sensitivity to the volume of waste carried. However, EPA assumed that generators
would locate carriers with variable weight rates in order to economize on the relatively small
shipments that they transport.
Exhibit 4-10
Proposed Part 273 Requirements: Option to Ship Direct Via
Common Carrier (Truck) Option Shipping Unit Cost
(in 1992 dollars)
Shipment Size1
(pounds)
Shipments < 200 pounds
Shipments of 388 pounds
Shipments of 522 pounds
Shipments of 844 pounds
Per Generator Unit Cost
$60.09 (fixed minimum)
$100.15
$115.36
$186.52
' These shipment sizes match up to the average annual wastes
produced by different generators of battery and thermostat waste.
The Agency obtained reclamation costs through personal communications with facilities
currently treating these wastes and are listed by the size of the waste shipment hi Exhibit 4-11.
Reclamation costs varied depending on the size of the waste shipment received by the treating
facility. Reclamation costs represent the per pound cost the generator would pay the reclamation
facility to accept their waste. The unit costs for mercury and ni-cd reclamation were based on
prices the Agency obtained from commercial facilities reclaiming these wastes.55
55 Personal communications with Bruce Lawrence of Bethlehem Apparatus, Alan Wilds
of Mercury Refining, Todd Coy of Kinsbursky Brothers, and Mark Schweers of INMETCO
September, 1993.
-------
4-16
Exhibit 4-11
Proposed Part 273 Requirements: Option to Ship Direct Via
Common Carriers (Truck) Reclamation Costs for Batteries and Thermostats
(in 1992 dollars)
Material/Shipment Size
Mercury shipment < 500 pounds
Mercury shipment 500 - 5,000 pounds
Vented ni-cd shipment (any size)
Sealed ni-cd shipment (any size)
Cost per Pound
$2.85
$2.60
$0.26
$0.24
The total annual per generator costs for complying with the proposed Part 273 Rule by
shipping waste directly to a reclamation facility are presented hi Exhibit 4-12. Total per
generator costs are presented by generator type and size category.
Exhibit 4-12
Annual Per Generator Costs for Complying with Part 273 Requirements
Option where Generators Ship Directly to a Destination Facility
(in 1992 dollars)
Universal
Waste
Coverage
Average
Annual
Waste
(pounds)
Annual Per Generator Costs:
On Site
Uiermestafe "'" I'" *
SQGs
LQGs
2
1
Veated ^C&BafcedKr -" "'
LQGs
522
$315.50
$315.50
Shipping
? "> \
$60.09
$60.09
' "ff
$315.50
SMfe* *&$* Spates * *
SQGs
LQGs
28
138
Mm:ttfM^B%>ie$ '
SQGs
LQGs
388
844
$315.50
$315.50
$315.50
$315.50
$115.36
'
$60.09
$60.09
*
$100.15
$186.52
Reclamation
T;/^
$5.70
$2.85
c- r^
$135.72
Total Annual
Per
Generator
Costs
$381
$378
& * - .-
$567
.,, yf
$6.72
$33.12
1,105.80
$2,194.40
$382
$409
$1,521
$2,696
-------
4-17
4.4.3 Generators Ship Waste Via Parcel Carrier
For this compliance option, on-site costs included employee training. Employee training
for both generator size categories (small and large quantity) was comprised of a $200 training
course or equivalent preparatory work for each generator. Additionally, generators were
assumed to tram 4 employees each for 1 hour at a laborer's wage rate of $27. This resulted hi
a total annual per generator teaming cost of $308. EPA estimates indicate that handling and
packing a parcel for shipment would require five minutes of processing time annually.
Processing costs per wholesaler were estimated using the labor rate for a distribution center
employee of $20 per hour.
The Agency obtained shipping costs for this option from a United Parcel Service (UPS)
rate schedule for commercial customers.56 Shipping costs include the cost of purchasing the
box as well as the cost of transporting it via UPS. Shipments for thermostats were based on the
cost for shipping a 10-pound box. Due to the low volume of waste for used thermostats, the
Agency assumed a box price of $0.80 per box with only one shipment per year. For batteries,
the cost of shipping was based on the volume of waste shipped by each generator. If a
generator's average annual waste exceeded UPS's maximum parcel weight of 70 pounds, the
Agency assumed the cost of the 70 pound box with multiple shipments occurring during the
year. Due to the low volume of waste per generator for SQGs of sealed ni-cd batteries, the
Agency estimated the cost of shipment for this generator group using UPS's cost for a 30 pound
parcel. Boxes for used batteries were estimated to cost $1.90 per box due to the density of the
batteries and the size of shipments.57 The unit cost for shipping used in the analysis of this
option are presented in Exhibit 4-13. EPA assumed that the average shipping distance was 1,500
miles to the commercial reclamation facilities.
Exhibit 4-13
Proposed Part 273 Requirements: Shipment Via Parcel Carrier
Shipping Costs for Batteries and Thermostats
(in 1992 dollars)
Shipping Cost Element
Small box for thermostats
Larger box for batteries
UPS cost for shipping a 10-pound box
UPS cost for shipping a 30-pound box
UPS cost for shipping a 70-pound box
Per Generator Unit Cost
$0.80
$1.90
$3.14
$15.00
$26.56
56 Rate schedules obtained from John Davis of UPS, October, 1993.
Box prices obtained from United Parcel Service, October, 1993.
57
-------
4-18
The Agency obtained reclamation costs through personal communications with facilities
currently treating these wastes.58 Reclamation costs varied depending on the size of the waste
shipment received by the treating facility. Reclamation costs for batteries represent the per
pound cost the generator would pay the reclamation facility to accept their waste. Cost of
mercury thermostat reclamation were different than the cost used for mercuric-oxide batteries.
For thermostats, reclamation costs were based on the cost of reclaiming a half-gallon box which
contains approximately five thermostats. Small quantity generators of thermostats would ship
three boxes annually and LQGs would ship one box annually. These costs are listed below in
Exhibit 4-14. The unit costs for batteries were based on price structures the Agency obtained
and are listed by the size of the waste shipment hi Exhibit 4-8. Costs differed due to the
exceptionally low volume of waste per generator of used mercury-containing thermostats.59
Exhibit 4-14
Proposed Part 273 Requirements: Shipment Via Parcel Carrier
Reclamation Costs for Batteries and Thermostats
(in 1992 dollars)
Material/Shipment Size
Mercury Thermostats
Mercury shipment < 500 pounds
Mercury shipment 500 - 5,000 pounds
Vented ni-cd shipment (any size)
Sealed ni-cd shipment (any size)
Unit Cost
$115 per box
$2.85 per pound
$2.60 per pound
$0.26 per pound
$0.24 per pound
The total annualized per generator costs for complying with the Proposed Part 273
requirements by shipping wastes via parcel carrier are presented in Exhibit 4-15 by generator
type and size.
58 Personal communications with Bruce Lawrence of Bethlehem Apparatus, Alan Wilds
of Mercury Refining, Todd Coy of Kinsbursky Brothers, and Mark Schweers of INMETCO,
September, 1993.
59 In this case, to allow direct comparison with the Honeywell system, the Agency used
the prices quoted by the same commercial facility Honeywell planned to use for
thermostats.
-------
4-19
Exhibit 4-15
Annual Per Generator Costs for Complying with Part 273 Requirements
Option where Generators Ship Wastes Via Parcel Carrier
(in 1992 dollars)
Universal
Waste
Coverage
1$agpM«gfr
SQGs
LQGs
Average
Annual
Waste
(pounds)
Annual Per Generator Costs:
On Site
Shipping
%
2
1
$308
$308
$3.94
$3.94
Reclamation
f
;
$345
$115
Total Annual
Per
Generator
Costs
$657
$427
Vested HI-&I latteries " '"" .. ""' 1" - - -
LQGs
.Sfe^ $&£&&&&
SQGs
LQGs
Mef^lMMdsBa
SQGs
LQGs
522
rlesr ""_
28
138
ifisnes-
388
844
$308
$227.68
,;.. '
$308
$308
\^
$308
$308
$16.90
$56.92
-
$170.76
$369.98
$135.72
,
$6.72
$33.12
X -
$1,105.80
$2,194.40
$671
,
$332
$398
%s ' %.
$1,585
$2,872
4.4.4 Generators of Thermostats Ship Via Parcel Carrier to Honeywell Corporation
EPA was approached by Honeywell Corporation, a major manufacturer of mercury-
containing thermostats requesting that the Agency allow for a unique reverse distribution system
for the collection and treatment of used thermostats.60 This approach relies on a mail delivery
system to transport used thermostats from wholesalers back to the manufacturer where the
mercury ampule is then removed. The used ampules are then stored at a permitted RCRA
Subtitle C storage facility until they are shipped to a mercury reclamation facility.61
Although the Agency only focused on the implications of generators that must currently
meet the full RCRA Subtitle C requirements using the Honeywell option, the company intends
to allow CESQGs and the public to return thermostats to them to enable mercury reclamation.
60 Honeywell Corporation has requested that EPA allow the mailing of used thermostats
by their wholesalers to a central location for processing and disposal.
61 Details of the approach were presented to the Agency by Honeywell in "Technical
Proposal For Honeywell's Mercury Reclamation and Recycling Program".
-------
4-20
EPA analyzed the costs associated with this approach. EPA assumed that the
manufacturer proposing the reverse distribution system would receive all thermostats generated
annually, including those manufactured by other firms. EPA assumed all thermostats generated
by SQGs and LQGs would be sent to the one manufacturer proposing the mailing approach.
Therefore, the manufacturer would receive 217,000 thermostats or about 33,000 pounds of waste
annually. The Agency examined the annual costs associated with this approach by estimating
the costs of on-site generator and wholesaler activities, shipping, storage, and reclamation, using
the following approach.62
On-site costs for this approach included the cost of employee training for both generators
and wholesalers of used thermostats and the cost of handling and packaging the thermostats for
shipment. EPA based the number of wholesalers on the manufacturer's statement of the existing
number of wholesaler locations (5,000) distributing their thermostats.63 Each wholesaler was
assumed to train two employees for one hour each on the proper handling and packaging
requirements for the used thermostats. The Agency assumed that each generator would train
four people for one-half hour each based on the manufacturer's statement about the tune
necessary to read a company-published safety brochure on the proper handling of thermostats.
The labor cost for wholesalers was based on the hourly wage for an employee at a distribution
center of $20, and the labor cost for generators was based on the hourly wage for a laborer of
$27. Per generator training costs were $54 for both SQGs and LQGs. Per wholesaler training
costs were $40.
The Agency assumed that no packaging costs would be incurred by generators when they
return them to the wholesaler. Each wholesaler was assumed to invest five minutes of
processing time annually (at a wage of $20 hour) for receiving and packaging the thermostats.
Per wholesaler packaging costs were, therefore, $1.06 annually.
Shipping costs included the cost of purchasing the box, shipping via a parcel carrier to
Honeywell, and hazardous waste transport of the ampule to a storage facility and then to the
reclamation facility. Generators were assumed to have negligible transportation costs to the
wholesaler because EPA assumed generators would return used thermostats at the tune that they
purchased a new supply. The Agency used prices already negotiated between the manufacturer
and the parcel carrier as the actual cost for both the box and the price of shipment.64 The
boxes are recyclable and wholesalers are expected to use each box for 10 shipments. Each
wholesaler was assumed to ship one box of used thermostats to the manufacturer once a year
62 EPA worked with Nancy Onkka of Honeywell to develop the unit costs and coverage
of the Honeywell option during the preparation of the economic impact analysis.
63 Based on conversation with Nancy Onkka of Honeywell who stated that Honeywell
has 2,000 wholesalers. Most of these wholesalers have multiple locations, which resulted in
a total number of wholesalers of approximately 5,000.
64 Based on personal communication with Nancy Onkka at Honeywell, August 1993.
-------
4-21
based on the number of wholesalers and the average number of thermostats per wholesaler.
Boxes cost $1.20 per use and each box shipment costs $5.10.65
The mercury ampules, which would be removed by the manufacturer, would then be
shipped for temporary storage to an existing RCRA-permitted storage facility owned by the
manufacturer and then on to the final reclamation facility. The total distance of travel for the
ampules is 984 miles.66 The Agency assumed ampules would be shipped hi 55-gallon drums
and transported by a hazardous waste hauler. Hazardous waste transportation costs were based
on the per pound cost of transporting a partial load ($0.0015 per pound/mile).67 Total per
wholesaler shipping costs are $6.35. Costs incurred by wholesalers were then assigned on a pro
rata basis to both small and large quantity generators.
The Agency developed storage costs assuming the ampules would be stored in four 55-
gallon drums requiring four square feet per drum. The annual cost per square foot of storage
needed was obtained from EPA's RCRA Reauthorization Cost Analysis (1992) and inflated to
1992 dollars ($4.55 per square foot). Total storage costs were $73 annually.
Disposal costs included the cost of training an employee for ampule removal, removal
of the ampule, reclamation of the mercury ampules, and disposal of the solid waste portion of
the thermostat. The Agency assumed that the manufacturer would pay $200 for a training
course and would tram four people for an hour each on safe ampule removal procedures. Total
training costs for the manufacturer were $308.
Ampule removal was assumed to take 1 minute per thermostat and would be conducted
at a cost of $27 per hour (assumed laborer completing the task). EPA assumed 217,000
thermostats require ampule removal per year for a total cost of $97,650.
The cost of recovering the mercury ampules was based on price quotes obtained from the
reclamation facility that has agreed to participate in the manufacturer's reverse distribution.
system ($2,140 per 55-gallon drum).68 Total ampule recovery costs were $8,560. The non-
hazardous portion of the used thermostat (95 percent of the weight of the thermostats) would be
disposed of at a municipal solid waste facility. Municipal solid waste collection and disposal
costs were obtained from the EPA's RCRA Reauthorization Cost Analysis (1992) and inflated
to 1992 dollars. The inflated cost for solid waste disposal was $70 per ton, which resulted in
a total cost for solid waste disposal of $1,097.
65 The boxes cost $12 each and have a cost of $1.20 per use if used 10 times.
66 Distance determined by measuring highway miles from Honeywell Corporation to their
storage facility and from the storage facility to the reclamation facility that has agreed to
accept the ampules.
67 Mercury ampules weigh five percent of the weight of the thermostat, which results in
approximately 1,650 pounds of mercury ampules annually.
68Based on personal communication with Bethlehem Apparatus, October 1993.
-------
4-22
In order to estimate costs for small and large quantity generators under this option,
wholesaler costs and costs incurred after consolidation of the thermostats were assigned to the
generator groups proportionately, based on the number of generators in each group.
4.5 Cost Elements for a Pesticide Recall under the Proposed Part 273 Rule
On-site costs incurred under the proposed Part 273 Rule for pesticides include employee
training. Generators of recalled pesticides were assumed to spend $308 on employee training.
Employee training costs include $200 per generator for a safety training course and the cost of
training four employees for one-half hour each using a laborer's wage of $27 per hour.
Storage costs were based on the cost of storing the pesticide at eight bonded warehouses
for one year. Bonded warehouses were assumed to be single story structures with concrete
floors, temperature control, sprinkler systems, security, and secondary containment. Costs for
the eight storage facilities were obtained from EPA's Cost Analysis of Hypothetical Pesticide
Recall Actions and inflated to 1992 dollars. Costs for storage were presented hi the aggregate
and therefore could not be broken down to the unit cost level. Total storage costs for each
facility are estimated to be $1,629,071.
-------
CHAPTER 5. RESULTS OF COST ANALYSIS
This chapter presents the results of EPA's cost analysis of the savings the Agency
estimates would occur under the proposed Universal Waste Rule. The results from the battery
and thermostat analysis and the pesticide analysis are presented independently below. For
batteries and thermostats, the total cost for each compliance option are presented as well as the
least-cost compliance method for each generator type and size. This is followed by a sensitivity
analysis of key parameters for the least cost option and a discussion of the major limitations of
the analysis.
5.1 Thermostats and Batteries Savings
Exhibit 5-1 presents the total annual on-site, shipping and reclamation costs to generators
under full RCRA Subtitle C requirements. Costs in Exhibit 5-1 are disaggregated by generator
type, size, and whether the costs were attributable to on site handling, shipping or reclamation.
Total annual costs associated with full RCRA Subtitle C compliance for cost elements that will
differ under the proposed rule are approximately $70 million.
Exhibit 5-2 presents the total annual costs associated with compliance with the proposed
Part 273 requirements by generators shipping wastes to consolidation points. Exhibits 5-3, 5-4,
and 5-5 present the total annual costs for compliance with the proposed Part 273 Rule by
generators shipping wastes directly to a destination facility via truck, shipping wastes via parcel
carrier, and the Honeywell reverse distribution system, respectively. In Exhibit 5-5,.the costs
incurred by wholesalers hi the reverse distribution system were attributed to small and large
quantity generators on a pro rata basis.
The least-cost method of compliance for the generators of the different universal wastes
are presented hi Exhibit 5-6. The least-cost method combines the lowest cost of compliance for
each individual generator type and size category to estimate the aggregate least-cost method of
compliance for all generator types. Under the least-cost method, total annual costs for the parts
of the proposed rule that are different than the full RCRA Subtitle C compliance costs are
approximately $26 million. The selection by universal waste generators of the least expensive
method of compliance with the proposed rule should result in a total annual net savings to
generators of thermostats and batteries of approximately $43 million.
5.2 Pesticide Recall Savings
The total cost per pesticide recall of compliance with both the full RCRA Subtitle C and
the proposed Part 273 Rule are presented hi Exhibit 5-7. The total cost of compliance with the
full RCRA Subtitle C requirements for pesticides for provisions that are different under full
RCRA Subtitle C requirements and the proposed Part 273 requirements are estimated to be $271
million per recall. Total costs for generators of pesticides that are cancelled and recalled under
the proposed Part 273 Rule for provisions that are different under full Subtitle C and the
proposed Part 273 are estimated to be $19 million per recall. This results hi an estimated $252
million in savings per recall. As shown in Exhibit 5-8, the total annualized savings over a 20-
year period are $50 million.
-------
5-2
Exhibit 5-1
Total Annual Costs for Generators Complying with Full RCRA Subtitle C Requirements
Hazardous Waste Batteries and Thermostats1
(in thousands of 1992 dollars)
Universal
Waste
Coverage
Ttoostats
SQGs
LQGs
Number of
Generators
:? s ; ^-
13,000
1,400
Average
Annual
Waste
(pounds)
Annual
On-Site
Costs
Annual
Shipping
Costs
Annual
Reclamation
Costs
Total
Annual
Costs2
s-* - / :
2
1
$8,099
$2,022
Vented Nl-Cdi Battfenes, ^\ '"'I """
LQGs
670
522
$967
$1,016
$109
$100
Sealed Nt-Cd. Bakeries -\ ^ ; /
SQGs
LQGs
MefcftirffcXfedd
SQGs
LQGs
60,000
8,000
28
138
$37,380
$11,552
$4,687
$625
t'iy ^ '+V ^ ^^ s - ^ «««««« ^^^ f
800
225
388
844
TOTALS
$498
$325
$60,843
$104
$55
$6,696
$74
$4
'
$91
'
$403
$265
$9,189
$2,135
$1,158
$42,470
$12,442
i
$885
$494
$2,216
$1,487
$874
$69,755
1 Costs include only those cost elements expected to vary between the full RCRA Subtitle C
requirements and the proposed Part 273 requirements. Total costs do not estimate full costs for
compliance with all of the RCRA Subtitle C requirements.
2 Costs may not total in some cases due to rounding.
-------
5-3
Exhibit 5-2
Annual Total Costs for Generators Complying with the Proposed Part 273 Rule
by Shipping Hazardous Waste Batteries and
Thermostats to Consolidation Points1
(in thousands of 1992 dollars)
Universal
Waste
Coverage
Tiiemastais
SQGs
LQGs
' \&**i*w3: KB f vt
y-eiwjw jVJ'wO
LQGs
Sealed BGM3U
SQGs
LQGs
; Mmraic-dda
SQGs
LQGs
Number of
Generators
13,000
1,400
jjauejriss
670
8ateds&
60,000
8,000
« Batteries .
800
225
TOTALS
Average
Annual
Waste
(pounds)
;
2
1
!* *
x
522
28
138
, ',
388
844
Annual
On-Site
Costs
\ ,\
$4,102
$442
$ * ' ' M
\ >. > 4
$211
:..*.; . \\
$18,930
$2,524
& ' 1 4i
\ ^ ";*
$252
$71
$26,532
Annual
Shipping
Costs
,f - I""V
$577
$62
t
} ^f,/ '
$70
i'< t . ' \*
$2,840
$479
i n ^ "
$71
$32
$4,130
Annual
Consolidation
Costs
^ ,
jt
$13
$686
^
$170
/*
$819
$538
.'. '' " ,
$151
$93
$1,785
Annual
Reclamation
Costs
$68
$4
$91
'/<'<
$403
$265
f ''<
$807
$494
$2,131
Total Annual
Costs2
;
$4,759
$508
$542
"" .
$22,993
$3,806
I
$1,282
$689
$34,578
1 Costs include only those cost elements expected to vary between the full RCRA Subtitle C requirements and
the proposed Part 273 requirements. Total costs do not estimate full costs for compliance with Part 273.
Costs may not total in some cases due to rounding errors.
-------
5-4
Exhibit 5-3
Annual Total Costs for Complying with the Proposed Part 273 Rule
Generators Ship Directly to a Destination Facility Via Truck1
(in thousands of 1992 dollars)
Universal
Waste
Coverage
.Ttaoftg* '
SQGs
LQGs
Vented KM^BaS
LQGs
Sealed Nt-Cd^BaSg
SQGs
LQGs
Me* fttme-Oaddf Ba
SQGs
LQGs
1
Number of
Generators'
~\$^ ;^
13,000
1,400
Dries'" ^xV
670
sfef o "t".
60,000
8,000
> * '%*f?'''
800
225
TOTALS
Average
Annual
Waste
(pounds)
2
1
.-&&*
522
5 ^"js "
28
138
^ , ,
388
844
Annual
On-Site
Costs
^*.^^^x-
$4,102
$442
. ss? ' Sf fjf ""ty ff / " ""/
$211
-"
$18,930
$2,524
V w "
$252
$71
$26,532
Annual
Shipping
Costs
v..,.
$781
$84
,..,*?/' ""
$77
^^ '<
r ft^..
$3,605
$481
//';
$80
$42
$5,151
Annual
Reclamation
Costs
$74
$4
'
$91
;5o
$403
$265
^ ,,; ";^xx" ~~
$885
$494
$2,216
Total Annual
Costs2
" / ,
$4,957
$530
'"
$380
-
$22,939
$3,270
$1,217
$607
$33,898
1 Costs include only those cost elements expected to vary between the full RCRA Subtitle C
requirements and the proposed Part 273 requirements. Total costs do not estimate full costs for
compliance with Part 273.
2 Costs may not total in some cases due to rounding.
-------
5-5
Exhibit 5-4
Annual Total Costs for Complying with the Proposed Part 273 Rule
Option where Generators Ship Wastes Via Parcel Carrier1
(in thousands of 1992 dollars)
Universal
Waste
Coverage
Number of
Generators
ffae£n$osta|$.
SQGs
LQGs
13,000
1,400
Ve^dM-Cd Batteries
LQGs
670
Average
Annual
Waste
(pounds)
2
1
Annual
On-Site
Costs
Annual
Shipping
Costs
Annual
Reclamation
Costs
s
$4,004
$431
$51
$6
$4,485
$161
Total Annual
Costs2
' -
$8,540
$598
, """1
522
$206
$153
$91
$450
Sealed^-Oi Batssties " '"? , ' ,,
SQGs
LQGs
60,000
8,000
28
138
$18,480
$2,464
$1,014
$455
$403
$265
$19,897
$3,184
Mer«udB-0xlde Batteries- _ - --~~ - "j '-
SQGs
LQGs
800
225
388
844
TOTALS
$246
$69
$25,900
$137
$83
$1,899
$885
$494
$6,784
$1,268
$646
$34,583
1 Costs include only those cost elements expected to vary between the full RCRA Subtitle C
requirements and the proposed Part 273 requirements. Total costs do not estimate full costs for
compliance with Part 273.
Costs may not total in some cases due to rounding error.
-------
5-6
Exhibit 5-5
Annual Total Costs for Generators Complying with the Proposed Part 273 Rule
Using the Honeywell Corporation Reverse Distribution System
(in thousands of 1992 dollars)
Universal
Waste
Coverage
Number of
Generators
Average
Annual
Waste
(pounds)
Annual
On-Site
Costs
Annual
Shipping
Costs
Annual
Storage
Costs
Annual
Disposal
Costs
Total
Annual
Costs
f ^ ^ ,,""";. f * f -. f < "
thermostats- ^ \ ;* --
SQGs
LQGs
13,000
1,400
2
1
TOTALS
$890
$96
$986
29
3
$32
$.065
$.007
$.072
$97
$10
108
$1,016
$109
$1,125
Exhibit 5-6
Least-Cost Method of Compliance
for the Proposed Part 273 Rule by Generator Type1
(in thousands of 1992 dollars)
Generator Type
Least-Cost Option
Total Annual Cost
* *-,'. v. X ' "s
Hierraosfsas" |--.J" ^ _ ' ,r^
SQG
LQG
Honeywell
Honeywell
$1,016
$109
Vent*a|4^*a^«» ~ ' " " '
LQG
Ship Direct via Truck
$380
Sealed M-ed'Baiferfes - '"'
SQG
LQG
Wem^'Oxi^ i^^rles
SQG
LQG
Ship via Parcel Carrier
Ship Direct via Parcel Carrier
;' ,:', '
Ship Direct via Truck
Ship Direct via Truck
Total Annual Cost Using Least-Cost Method
Total Annual Full RCRA Subtitle C Compliance Cost
Total Annual Savings from the Proposed Part 273 Rule
$19,897
$3,184
''' >f ff
, r"«v
$1,217
$607
$26,410
$69,755
$43,345
1 Costs include only those cost elements expected to vary between the full RCRA Subtitle C requirements and
the proposed Part 273 requirements. Total costs do not estimate full costs for compliance with Part 273.
-------
5-7
ExhibitS-7
Total Costs for Complying with the Proposed Part 273
and Full RCRA Subtitle C Requirements for Pesticides Per Recall
(in thousands of 1992 dollars)
Requirements
Full RCRA Subtitle
C
Proposed Part 273
Number of
Generators
20,000
20,000
Total On-Site
Costs
$61,163
$6,400
Total Storage
Costs
$210,334
$13,033
Net Savings Per Recall
Total Costs per
Recall
271,497
$19,433
$252,064
Exhibit 5-8
Total and Annualized Savings under the Proposed Part 273 Rule for
Large Pesticide Recalls Every Five Years
(in thousands of 1992 dollars)
Years of Recall
3
8
13
18
Discount Factor
.8163
.5820
.4150
.2959
Total Present Value Savings
Annualized Savings
Discounted Value
of Savings1
$205,760
$146,701
$104,607
$74,586
$531,653
$50,184
The savings are discounted unsing a 7 percent discount rate and are annualized over a 20-year period.
5.3 Total Savings
EPA estimates the total annual savings incurred to generators of hazardous waste
batteries, thermostats, and recalled pesticides as a result of the proposed Universal Waste Rule
are approximately $93 million.
-------
5-8
5.4 Sensitivity Analysis
This section presents the results of EPA's analysis of the effects of varying selected major
parameters in the cost analysis (where the Agency used considerable judgment hi arriving at the
parameter's value) on the estimated savings incurred under the proposed Universal Waste
Rule.69 Each parameter that EPA used was analyzed with regard to the relevant range of
values it potentially could have. In EPA's analysis of the sensitivity of each cost factor, all
other parameters remained as they were hi the initial "base" case analysis that was presented
above (i.e. were held constant), except hi the best-case and worst-case analysis where all the
elements under examination were increased and decreased by 25 percent, respectively.
5.4.1 Batteries and Thermostats
Exhibit 5-9 shows the results of the sensitivity analysis for batteries and thermostats. For
purposes of comparison, the results from generators selecting the least-cost option for
compliance that were presented earlier hi this chapter appear at the top of the exhibit as the base
case estimate. Note that from the original analysis, none of the least-cost options change due
to the varying of unit cost parameters that EPA examined, except for LQGs with sealed Ni-cd
batteries when then: direct transportation costs are reduced by 25 percent. The following
assumptions were analyzed in the sensitivity analysis for EPA's analysis of batteries and
thermostats:
o Number of Generators - EPA set its lower bound estimates of the number of generators
equal to 25 percent less than the values used hi its initial cost-effectiveness analysis. It
set its upper bound estimates equal to 25 percent greater than the values used hi its initial
cost analysis.
o Cost to Transport Waste - The Agency varied the estimates of the cost of transportation
via truck by plus or minus 25 percent of the original estimate. The costs of
transportation via parcel carrier were not varied because these costs were obtained
directly from the parcel carrier.
o Cost of Employee Training - EPA increased and decreased the cost of employee training
required by 25 percent.70
o Cost of Contingency Plan - The Agency increased and decreased by 25 percent the cost
of maintaining the contingency plan required under full RCRA Subtitle C compliance.
69 EPA did not examine the discount rate in this analysis because ail the costs examined
were annual costs.
70 Under the Honeywell reverse distribution system, the only training costs that were
varied were those that were thought to be highly uncertain. Since Honeywell had provided
specific values for the cost of their training program associated with their approach, these
costs were not varied.
-------
5-9
Also included in Exhibit 5-9 are estimates of the possible range of costs under both
regulatory scenarios. The costs associated with the best-case scenario were estimated using the
high end estimates (i.e., increased by 25 percent) for each cost element included in the
sensitivity analysis. The costs associated with the worst-case scenario combined the lower bound
estimates for each cost element. The results from these two analyses suggest that the range of
total annual savings from the proposed Universal Waste Rule's RCRA requirements for
generators of batteries and thermostats could be $27 million to $63 million.
Exhibit 5-9
Results of Sensitivity Analysis on the Annual Cost of Compliance with the Proposed
Part 273 Rule to Generators of Batteries and Thermostats
under the Least-Cost Method of Compliance1
(in thousands of 1992 dollars)
Cost Case Examined
Base Case Estimate
Increase number of generators by 25 %
Decrease number of generators by 25 %
Increase cost of training by 25 %
Decrease cost of training by 25 %
Increase cost of a contingency plan by 25 %
Decrease cost of a contingency plan by 25 %
Increase cost of truck transport by 25 %
Decrease cost of truck transport by 25%
Best-case estimate (all elements above increased by
25 %)
Worst-case estimate (all elements above decreased by
25 %)
Annual Costs of:
Full RCRA
Subtitle C
Compliance
$69,755
$87,194
$52,316
$76,946
$62,564
$73,960
$65,550
$71,429
$68,081
$103,531
$42,514
Part 273
Compliance
by Least
Cost Method
$26,410
$33,013
$19,808
$31,971
$20,849
$26,410
$26,410
$26,580
$26,240
$40,176
$15,510
Annual
Incremental
Savings
$43,345
$54,181
$32,509
$44,975
$41,715
$47,550
$39,140
$44,849
$41,841
$63,355
$27,004
1 The costs provided are only for areas where the unit costs for activities under the Full RCRA Subtitle C
requirements and the proposed Part 273 Rule are different. They do not represent total compliance costs
for all requirements.
-------
5-10
5.4.2 Pesticides
The results of EPA's sensitivity analysis of the cost of compliance with the Universal
Waste Rule for generators of suspended or cancelled and recalled pesticides are presented in
Exhibit 5-10. The following major assumptions were analyzed hi the sensitivity analysis for
EPA's analysis of pesticides:
o Number of Generators - EPA set its lower bound estimates of the number of generators
equal to 25 percent less than the values used hi its initial cost-effectiveness analysis. It
set its upper bound estimates equal to 25 percent greater than the values used in its initial
cost analysis.
o Cost of Employee Training - EPA increased and decreased the cost of employee training
required by 25 percent.
o Cost of Contingency Plan - The Agency increased and decreased by 25 percent the cost
of maintaining a contingency plan that is required under full RCRA Subtitle C
compliance.
o Storage Costs - EPA increased and decreased the per facility cost of storage by 25
percent for compliance under both the proposed Universal Waste Rule and full RCRA
Subtitle C compliance.
o Discount Rate - EPA estimated the net present value of savings using discount rates of
3 percent and 10 percent.
Also included in Exhibit 5-10 are estimates of the costs associated with the best-case
scenario (where all the above cost elements are increased 25 percent and the 3 percent discount
rate is used) and the worst-case scenario (where all the above cost elements are decreased 25
percent and the 10 percent discount rate is used). The results from these two analyses suggest
that the range of total annual savings from the proposed Universal Waste Rule for generators
of recalled pesticides ctiuld be $28 million to $78 million.
-------
5-11
Exhibit 5-10
Results of Sensitivity Analysis on the Cost of Compliance with the Proposed
Part 273 Rule to Generators of Suspended or Cancelled and Recalled Pesticide
(in thousands of 1992 dollars)
Cost Case Examined
Base Case Estimate
Increase number of generators by 25 %
Decrease number of generators by 25 %
Increase cost of training by 25 %
Decrease cost of training by 25 %
Increase cost of a contingency plan by 25 %
Decrease cost of a contingency plan by 25 %
Increase cost of storage by 25 %
Decrease cost of storage by 25%
Discount rate set at 3 percent
Discount rate set at 10 percent
Best-case (all elements increased by 25%, discount
rate 3 percent)
Worst-case (all elements decreased by 25%,
discount rate 10 percent)
Full RCRA
Subtitle C
Compliance
$271,497
$339,371
$203,623
$274,427
$268,567
$281,497
$261,497
$324,081
$218,913
$271,497
$271,497
$421,264
$154,487
Proposed
Part 273
Compliance
$19,433
$24,291
$14,575
$20,973
$17,893
$19,433
$19,433
$22,691
$16,175
$19,433
$19,433
$30,289
$10,976
Incremental
Savings Per
Recall
$252,064
$315,080
$189,048
$253,454
$250,674
$262,064
$242,064
$301,390
$202,738
$252,064
$252,064
$390,975
$143,511
Total Net
Present Value
of Savings1
$531,653
$664,567
$398,740
$534,585
$528,722
$552,745
$510,561
$635,692
$427,615
$749,361
$425,333
$1,162,330
$242,161
Annualized
Savings Over
20 Years2
$50,184
$62,731
$37,638
$50,461
$49,908
$52,175
$48,193
$60,005
$40,364
$50,369
$49,959
$78,127
$28,444
* The costs are discounted using a 7 percent discount rate (unless otherwise specified) and are annualized over a 20 year period.
The costs provided are only for areas where the unit costs for activities under the Full RCRA Subtitle C requirements and the proposed Part 273 Rule
different. They do not represent total compliance costs for all requirements.
are
-------
5-12
5.5 Major Limitations
In reviewing the above results of the economic impact analysis for the proposed Universal
Waste Rule, the following limitations should be recognized:
o Published data on the quantities of wastes generated and the number and type of
generators were sparse. EPA developed estimates of the affected universe of batteries
and thermostats based on communications with experts in the industries of concern. The
estimates of the generators and waste volumes for pesticide recalls are for a plausible
future scenario based on work that EPA has done to support its development of pesticide
recall procedures. EPA was required to exercise a considerable degree of judgment in
developing the estimates of generators and volumes of universal wastes.
o The baseline for EPA's analysis assumes compliance with the full RCRA Subtitle C
requirements. Non-compliance in the baseline situation (full RCRA Subtitle C rules)
would lower the savings estimated for the proposed Part 273 Rule.
o The analysis is based on the handling of average volumes of waste streams in each
generator class, rather than some type of distribution of volumes of waste in each
generator category.
o EPA's analysis considers regulations at the federal level only. Some states are hi the
process of establishing rules for their own special collection systems. State programs are
not reflected in EPA's analysis. Also, the analysis assumes states will adopt the Part 273
requirements, rather than maintain the stricter status quo situation. They have authority
under RCRA to have more stringent hazardous waste programs. Therefore, the estimated
savings shown in this chapter depend on state adaptation of the Proposed Part 273 rule.
o EPA simplified the analysis by handling all costs of compliance with the full RCRA
Subtitle C requirements and the proposed Part 273 Rule using a framework for analysis
that examined the costs on a per waste type basis for the generators of each waste.
Implicit in this approach is the assumption that there are no significant economies of
scale available to generators who generate more than one of these wastes. Overall, this
assumption appears valid given the limited generator overlap that EPA estimates exists
between waste categories, and the variations in what generators would need to do to
properly manage different wastes.
o Unit costs are based on assumed averages. Individual entities in the universe may bear
higher or lower unit costs.
o The number of consolidation points available for battery and thermostat wastes for the
compliance option that relies on truck transport to consolidation points was estimated
based on the number of MSAs, rather than on the number of storage facilities hi
existence. This estimate may over or understate the actual number of consolidation
points that would exist under the proposed Part 273 Rule, and therefore not accurately
reflect the costs savings that could result from the rule.
-------
6-1
PART HI. POTENTIAL FOR REDUCTION IN ENVIRONMENTAL BENEFITS
CHAPTER 6 - ANALYSIS OF POTENTIAL FOR REDUCTION IN ENVIRONMENTAL
BENEFITS
To determine whether the proposed changes to the regulations are likely to cause
significant reduced environmental benefits when compared to the existing Subtitle C regulations,
the Agency assessed whether the risks posed by management of the universal wastes in question
under the proposed regulations (40 CFR Part 273) are likely to be significantly higher than the
risks posed by management of the same wastes under the existing hazardous waste regulations.
In summary, based on the requirements included in the proposed rule, the nature of the
wastes, and the generation and management patterns of the wastes, the Agency concludes that
it is not likely that management of these universal wastes under the proposed rule would pose
significantly increased risks compared to management of the same wastes under the existing
Subtitle C regulations. The factors the Agency assessed in coming to this conclusion include:
These universal wastes are contained and pose low potential for release;
The proposed requirements provide a higher level of protection for larger quantities of
waste;
The proposed regulations limit the length of time that these wastes may be stored;
The proposed waste management requirements provide sufficient protection to minimize
the risks posed by these wastes;
Other authorities and controls provide additional protection; and
The proposed regulations will facilitate improved management of unregulated wastes.
o
o
o
o
o
o
Each of these factors is discussed in detail below.
6.1 Wastes Are Contained and Pose Low Potential for Releases
The three wastes considered for regulation under Part 273 each represent a very limited
universe of wastes with characteristics that make the risk of releases of hazardous constituents
from the wastes during collection lower than those posed by the typical industrial hazardous
waste (e.g., sludges or production by-products). The three waste types include only materials
that, as wastes, exist in the same state they did as products, and the products themselves or the
product packaging have been specifically designed to protect against releases or exposures of the
contained hazardous constituents during reasonable worst case product management scenarios.
The management standards proposed for these universal wastes are designed to ensure that
management during collection of the wastes is similar to the normal product handling scenarios
the products have specifically been designed to withstand.
Due to the protective product or packaging design, the Agency believes that the risk of
release or other exposure during collection is relatively low as long as there are management
standards in place to ensure that management during collection is similar to product handling
procedures and that the integrity of the protective design is maintained. Thus, the Agency
believes that streamlining the requirements for collection of these wastes will not result in
-------
6-2
increased net risks. The characteristics that make the risk of release during collection low for
each of the wastes proposed for regulation under Part 273 (or discussed in detail in the proposal)
are described below.
The universe of hazardous waste batteries includes manufactured items that have been
produced with casings that are specifically designed to protect the internal components of the
battery from damages such as physical impacts, deterioration, corrosion, and chemicals or other
factors external to the battery, and to protect the user from contact with the internal battery
components. These casings are generally made of steel or rigid plastic and, it is reasonable to
assume, are designed to withstand reasonable worst case situations that batteries are likely to be
exposed to during product storage and use. Because the conditions batteries will be exposed to
during collection (e.g., transport, storage for relatively short periods of time (less than one
year)) are similar to those encountered during use, the Agency believes that the casings will
continue to rninimize the risk of damage to batteries and releases of hazardous constituents from
batteries during collection. In addition, the Agency believes that a large percentage of the
batteries managed under this rule will be the small consumer-type batteries generally found in
retail stores. This is because the large majority of hazardous waste batteries (other than lead
acid batteries) are of this type. For example, 70% of nickel-cadmium 'batteries are small
consumer-type batteries.71 These batteries, known as starved electrolyte batteries, generally
do not contain free liquids. The electrolytes for these batteries are a gel or are absorbed into
a porous separator material. Thus, releases from these batteries are even more unlikely than
from those with liquid electrolytes. Due to this low risk of release or other exposure during
collection of hazardous waste batteries, the Agency believes that there will not be significant
reduced environmental benefits from managing these wastes under the proposed rule as
compared to management under the existing full Subtitle C regulations.
The universe of hazardous waste pesticides included in the proposal is quite narrow and
includes only cancelled and/or suspended pesticides that are recalled under regulations now being
developed under the Federal Insecticide, Fungicide, and Rodenticide Act (regulations governing
these recalls were proposed under FIFRA on May 5, 1993 (58 FR 26856)). These regulations
will require that a registrant conducting a recall have the recall procedures pre-approved by EPA
and that the recall meet certain requirements. The proposed 273 regulations would include only
pesticides packaged in non-leaking original product packaging (or overpacked if leaking), hi a
tank meeting the hazardous waste tank requirements (including secondary containment), or in
a non-leaking transport vehicle or vessel.
It is expected that many of the pesticides managed under Part 273 will be hi the original
product packaging because it will be returned from distributors or users who have the pesticides
hi storage but have not yet sold or used them. This packaging, it can be assumed, has been
designed by the manufacturer to contain and protect the pesticide under reasonable worst case
product storage and transport conditions. Under the recall, the pesticides will be managed under
similar conditions. They will generally be stored and transported by the same entities that
managed the products through the product distribution chain. Pesticides that will be returned
"Cadmium Council, 1993.
-------
6-3
in larger quantities will also be returned through the distribution chain and will likely be
managed in tanks and transport vehicles that are similar to those in which bulk product pesticides
were managed through the product distribution chain. Because of the packaging described
above, the Agency believes that the risk of releases of the universe of pesticides included in the
proposal is relatively low. Due to this low risk of release or other exposure during collection
of suspended, cancelled, and/or recalled pesticides, the Agency believes that there will not be
significant reduced environmental benefits from managing these wastes under the proposed rule
as compared to management under the existing full Subtitle C regulations.
Similarly, the mercury hi mercury-containing thermostats is enclosed in a shock-resistant
glass ampule protected by a surrounding metal structure which is constructed to ensure that the
mercury does not escape from the thermostat during product storage, installation, use, and
removal. Due to the materials of construction (metal and shock-resistant glass), this protective
apparatus remains intact and continues to protect the mercury from release when the thermostat
is removed from its installation. Management of the waste thermostat under the proposed rules
will be similar to management of the product thermostat prior to use (e.g., removal by the same
person installing the replacement thermostat, and transportation and storage through the same
system used to distribute new thermostats). Due to the protective apparatus in which the
mercury in a thermostat is housed, the crush-resistant glass vial in which the mercury is
contained, and the similarity of thermostat management methods under the proposal to the
management scenarios this product was designed by the manufacturer to withstand, the Agency
believes that the risk of releases of mercury is relatively low. Thus, the Agency believes that
there will not be significant reduced environmental benefits from managing these wastes under
the proposed rule as compared to management under the existing full Subtitle C regulations.
6.2 Requirements Provide A Higher Level of Protection For Larger Quantities of Waste
The proposed Part 273 regulations were designed to minimize the regulatory requirements
for management of relatively small quantities of universal wastes, and to provide increased
protection for management of larger quantities of these wastes. As discussed above, the Agency
believes that the risks posed by management of these wastes under the proposed rule is relatively
low due to the packaging or protective construction of the products that become universal
wastes. To ensure that the risks of collecting these wastes are minimized, however, the Agency
has identified the two typical collection scenarios that it believes could present relatively high
risks (compared to other collection scenarios), and has specifically designed management
standards to minimize these risks. The first scenario of concern is situations where larger
quantities of these wastes are consolidated at one location or transported in one shipment. For
example, if a fire or other emergency occurred at such a location, relatively large quantities of
hazardous constituents could be released to the environment. Similarly, if the management
practices are poor at a facility where large quantities of these wastes are managed, the risk of
larger quantities of hazardous constituents being released through poor management practices is
increased.
To counter the relatively increased risks posed by management of larger quantities of
these wastes the proposed management requirements were tailored to provide increased
protection when larger quantities are managed. For example, handlers who store more than
-------
6-4
specific quantities of batteries identified in the rule are required to notify the Agency (or state
agency) that they are managing these quantities of these wastes, thus providing the regulating
authority the opportunity to conduct inspections to ensure that the wastes are being managed
properly. (Comment was requested on an appropriate quantity cut-off for thermostats.)
Pesticide handlers will be identified through the recall plan approval procedures). Use of the
manifest for shipments of batteries from the last consolidation point to the final destination
facility was proposed to ensure that these larger, consolidated shipments are handled only by
registered hazardous waste transporters and that point-to-point tracking is provided by the
manifest. No regulatory changes were proposed for destination facilities (treatment, recycling,
and disposal facilities); they will retain the current full Subtitle C protection for their treatment,
disposal, and recycling activities.
EPA believes that there will not be significant reduced environmental benefits under the
proposal because, when aggregated into larger quantities, universal wastes become subject to
more stringent regulation (similar to Subtitle C) designed to protect against the relatively
increased risks of large quantities. The requirements are designed to be less stringent only for
the initial phases of collection (from generators that each generate relatively small quantities of
these wastes), when typically the wastes will be managed hi smaller quantities and the risks will
be lessened.
6.3 Regulations Limit the Length of Time That Universal Waste Be Stored
The second typical collection scenario that the Agency has identified as one that could
present relatively higher risks (compared to other collection scenarios) is situations where
universal wastes are stored for relatively long periods of tune. The Agency believes that the
risks may be increased when universal wastes are stored for long periods of tune for several
reasons. First, long storage tunes may indicate that the manager of the facility does not have
procedures in place to ship the wastes on for recycling, or treatment and disposal (e.g., contracts
with transporters and receiving facilities), or that the manager is having difficulty making such
arrangements. Since use of storage space is generally a cost to a facility, long storage tunes
may signal inattention to proper management of these wastes. Long storage tunes may also
increase the risk of managing these wastes in that the products or the packaging may begin to
deteriorate over time (e.g., corrosion of battery casings, thermostat housings, or pesticide
packaging in the presence of high humidity or dampness), which could eventually lead to
releases of the contained hazardous constituents.
To minimize the potential for increased risks posed by long storage tunes the proposed
management standards limit storage of universal wastes at any location to one year or less.
Storage in the course of transport is limited to ten days. The one year storage time limit is
documented and made easily enforceable by requiring the handler to demonstrate, by one of
several methods, that universal wastes have not been on-site for more than a year. This one
year time limit and associated documentation are designed to ensure that handlers of universal
wastes keep the wastes moving through the collection system toward recycling or treatment and
disposal facilities and that they maintain active attention to management of the wastes to ensure
that they do not exceed the time limit.
-------
6-5
EPA believes that there will not be significant reduced environmental benefits under the
proposal due to storage for excessive periods of time (as compared to the current hazardous
waste regulations) because the one year time limit and the associated documentation will limit
such excessive storage. The Agency believes this mechanism will successfully limit long storage
tunes because it will be simple for handlers to understand and to comply with, and for regulatory
agencies to enforce. Limiting the storage tunes for these wastes will ensure that handlers of
these universal wastes continue active management of the wastes and do not overlook them
through negligence or neglect. Limited storage times will also minimize the likelihood that the
protective product or packaging design will be compromised through deterioration or by repeated
movement of the wastes over time among different storage locations at the facility.
6.4 The Proposed Part 273 Requirements Provide Protection
The existing Subtitle C requirements for hazardous waste are designed to minimize the
risk of releases of hazardous waste to human health and the environment and to ensure that any
releases that do occur are handled in such a way as to minimize damages to human health and
the environment. This is accomplished through regulations applicable to each entity managing
the waste including generators, transporters, storage facilities, and treatment and disposal
facilities. These regulations impose requirements to prevent leaks and spills during storage and
transport, to ensure that wastes are managed by the appropriate regulated persons, to track
movement of wastes, to alert regulating agencies to activities that may require some oversight,
to ensure that wastes are treated to the extent possible prior to land disposal, and to ensure that
treatment and disposal units are designed to prevent releases to the environment.
The proposed Part 273 requirements include basic standards to minimize the risk of
release to the environment and manage releases should they occur. In addition, these
requirements are enforceable. They include sufficient requirements to provide regulatory
oversight and ensure compliance with these requirements.
Proposed Part 273 includes regulatory provisions that require universal wastes to be
managed in a manner that minimizes risk to human health and the environment. Part 273 waste
handlers are subject to general performance standards to minimize the risk of releases to the
environment and contain releases in the event they occur.
To help reduce the likelihood that releases of hazardous constituents from universal
wastes occur, Part 273 regulatory provisions include a basic training requirement for generators
and owner/operators of consolidation points. These handlers are required to make employees
familiar with proper waste handling and emergency procedures appropriate to the wastes they
are handling. Thus, handlers must ensure that employees managing universal wastes are familiar
with the possible safety and environmental risks associated with these wastes, the standard
operating procedures appropriate for minimizing these risks, the warning signs indicating that
risks may be increased (e.g., a leaking battery), and procedures to control the risks should an
emergency occur. Providing this training to employees managing universal wastes will improve
their ability to protect against risks to human health and the environment, and will decrease the
probability of a release of hazardous constituents from universal wastes to the environment.
-------
6-6
To compliment its release prevention provisions, proposed Part 273 includes a release
response requirement for all universal waste handlers. Handlers are required to immediately
contain and appropriately manage any releases from universal wastes. Handlers are also
required to determine if materials resulting from a release are hazardous waste, and if so,
manage them under the full Subtitle C hazardous waste regulations. This would including any
material released from the universal waste article or packaging, contaminated cleanup materials,
and contaminated media. Thus, any materials that do not retain the protective product or
packaging design discussed in Section A will be provided the full protection of the hazardous
waste regulations, since the reduced requirements of proposed Part 273 would no longer be
appropriate.
In addition to these requirements, handlers managing universal wastes are subject to
prohibitions to ensure that the wastes retain the characteristics that make the minimized Part 273
requirements appropriate. All universal waste handlers (except final destination facilities) are
prohibited from diluting, treating (except for removing battery electrolyte or responding to a
release), or disposing of universal wastes on-site. These prohibitions assure that universal
wastes that are packaged or self-contained in a manner that minimizes the risk of release remain
intact until they reach a fully regulated destination facility for treatment, recycling or disposal.
These prohibitions also reduce the risks of managing these wastes by ensuring, that universal
waste handlers are not conducting any complex waste management operations such as mixing
or separating wastes or constituents, managing volatile or liquid wastes hi open containers, or
transferring liquid wastes from one container to another.
The risks of managing universal wastes are further reduced by the limited universe of
wastes covered, the easily identifiable nature of the wastes, and the uniformity of the wastes in
terms of hazardous constituents and characteristics. Universal waste handlers will be sure of the
nature and character of the wastes they are handling without conducting any waste sampling,
testing, or analysis because they can rely on the uniformity of the manufactured products that
have become wastes.
Under the proposal, universal waste generators and consolidation point operators are also
prohibited from sending the wastes to any place other than a consolidation point or destination
facility. This ensures that the wastes will eventually reach a destination facility for appropriate
recycling or treatment and disposal. Destination facilities receiving universal wastes remain
subject to applicable Parts 260 to 272 Subtitle C requirements. Therefore, under proposed Part
273, the protective product design or packaging must remain intact until they become aggregated
at a destination facility, where they are subject to management under the more stringent
regulation of full Subtitle C. For this reason, EPA believes that management of universal wastes
under proposed Part 273 would not result hi significant reduced environmental benefits.
To ensure that waste handlers comply with the terms of the new system, Part 273
includes provisions, albeit streamlined, to ensure that the system is enforceable. First, the
sanction for noncompliance with Part 273 requirements is to subject universal waste handlers to
«the full Subtitle C hazardous waste regulations of 40 CFR Parts 260-272. In addition, the
burden of proof for demonstrating that the universal waste handler qualifies for the Part 273
requirements remains with the handler (see 40 CFR §261.2(f)). This requires the waste handler
-------
6-7
managing waste under the reduced requirements of Part 273 to show through appropriate
documentation that his or her activities are limited to those allowed under the Part 273
regulations.
In addition to these requirements, proposed Part 273 includes specific recordkeeping and
reporting requirements to better ensure compliance. For example, for hazardous waste battery
management, Part 273 includes a notification requirement for waste handlers who accumulate
more than 20,000 kg of hazardous waste batteries. This requirement will facilitate Agency
oversight of facilities aggregating universal wastes in larger quantities, where the risks posed by
the wastes may be increased. Comment was requested on an appropriate quantity limit for
notification of handlers managing mercury-containing thermostats. (Suspended and/or cancelled
pesticides that are recalled and managed under Part 273 are subject to recordkeeping and
reporting requirements under Section 19 of the Federal Insecticide, Fungicide and Rodenticide
Act (FIFRA)). In addition, all Part 273 waste shipments from the final consolidation point to
the destination facility must be accompanied by a hazardous waste manifest and transported using
a hazardous waste transporter, providing control equivalent to full Subtitle C for these larger
shipments. Finally, any shipments of universal wastes to foreign destinations are subject to the
same procedures for notice and consent from the receiving country as any other hazardous
waste.
6.5 Other Authorities and Controls Provide Additional Protection
In addition to the controls included within the proposed Part 273 regulations discussed
above, the Agency further believes that there are not significant reduced environmental benefits
for hazardous wastes managed under Part 273 because other federal statutory authorities for
environmental protection provide safeguards against forms of environmental injury. Universal
waste pesticides remain subject to storage and transport requirements under Section 19 of
FIFRA. Releases of universal wastes above reportable quantity (RQ) thresholds are subject to
reporting requirements under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), also known as Superfund. In a worst case scenario involving releases
of hazardous constituents from universal wastes, cleanup could be accomplished under RCRA
(materials released from universal wastes are subject to applicable RCRA Subtitle C
requirements) or under Superfund (because universal wastes are hazardous wastes, they are also
hazardous substances under Superfund, for which liability for remediation is assigned). Further,
as mentioned above, EPA has authority under Section 7003 of RCRA to take immediate action
hi the event of a release from hazardous waste that presents an imminent and substantial
endangerment to health or the environment.
With respect to transportation, the Department of Transportation's (DOT) regulations
governing hazardous materials will apply to universal wastes in the same way that they apply
to the products that become universal wastes (e.g., product batteries, thermostats, and
pesticides). Thus, if a universal waste is identified as a hazardous material when shipped as a
product, it will continue to be a hazardous material when shipped as waste and all of the same
hazardous materials controls designed to protect against transportation risks will apply.
Conversely, if a universal waste is not identified as a hazardous material when shipped as a
product because the DOT has determined that hazardous materials controls are not necessary,
-------
6-8
the universal waste will not be a hazardous material when shipped as a waste and the hazardous
materials controls will also not be applicable. Because the DOT regulations are designed to
rninimize risks during transport of these materials when products, and the materials are basically
the same when shipped as wastes as they are when products, the DOT regulations will provide
adequate protection for transport of universal wastes.
Finally, in addition to these statutory and regulatory controls, the Agency generally
expects to include in the universal wastes system wastes for which there is some indication that
public or private entities are likely to sponsor "take back" or collection programs. Specifically,
the rechargeable battery industry and thermostat manufacturers are both proposing national "take
back" programs under which procedures and charges for shipping universal wastes from
collectors (e.g., retailers and contractors) back to the manufacturer or to a reclamation facility
(and any costs for reclamation) will be prearranged and prepaid by the manufacturers.
Similarly, pesticide recall procedures provide an infrastructure and funding for returning recalled
pesticides to the registrant for treatment and disposal. Such programs increase the likelihood
of collecting these wastes from generators by removing economic barriers to collection, i.e., the
cost of .shipping. Such programs also reduce the risk of releases and mismanagement by
specifying appropriate shipping and packaging procedures, by minimizing the likelihood of
intermediate collection points collecting wastes and then finding they do not have the resources
to ship and reclaim or dispose of the wastes, and by ensuring that the waste reaches the
appropriate destination facility.
6.6 The Proposed Rule Will Facilitate Improved Management of Unregulated Wastes
Finally, the Agency believes that streamlining the regulatory requirements for collection
of the portion of these universal wastes that are regulated will facilitate unproved management
and recycling of the portion that is not regulated (or minimally regulated). Specifically, the
same universal wastes that are regulated when generated by small or large quantity generators
are completely exempt from the hazardous waste regulations when generated by households, and
are basically exempt when generated by Conditionally Exempt Small Quantity Generators
(generate less than 100 kilograms of hazardous waste per month). Universal wastes in each of
these regulatory categories are totally indistinguishable, however, once they are removed from
the generator's facility.
Fear of enforcement action for noncompliance with the hazardous waste regulations has
reportedly greatly inhibited the voluntary collection and management of these unregulated
portions of the waste stream. Sponsors of collection programs for these wastes (generally
municipalities' household hazardous waste collection programs or manufacturers' product take-
back programs) point out that it is not administratively feasible to document that the wastes they
collect are not regulated hazardous wastes (assuming that such a determination was correctly
made by the generator in the first place). This inability to identify the various regulatory
categories of universal wastes has been a major barrier to participation in collection programs
because potential participants (e.g., retailers, communities) are not willing to take on the liability
of non-compliance with the hazardous waste regulations, and compliance would be prohibitively
expensive.
-------
6-9
The Agency anticipates that the proposed streamlined regulatory requirements for the
regulated portion of the universal waste stream will make it such that persons wishing to collect
these wastes will be able to implement programs with greatly reduced costs and administrative
effort. Because these programs will be in compliance with requirements for the most regulated
portion of the waste stream, these programs will not only be able to collect all three categories
of universal wastes without any additional expense or effort, but also will not be required to
keep track of which wastes fall into which category. The Agency anticipates that this will
greatly increase the number and scope of collection programs run by manufacturers,
communities, and other entities. As required under the proposed Part 273 requirements, wastes
managed under such programs will be recycled or treated and disposed at facilities in compliance
with the full Subtitle C hazardous waste regulations. Thus, the proposal would decrease the
quantity of unregulated waste disposed of in municipal landfills or combustors, and increase the
quantity managed at controlled hazardous waste recycling or disposal facilities designed to
minimize the risks posed by recycling and disposal of similar waste types. Further, because
recycling is mandatory for many of the proposed universal wastes under the land disposal
restrictions rules (40 CFR 268), and because many of the sponsors of collection programs will
choose the recycling option, the Agency believes the proposal will increase recycling of these
wastes.
-------
-------
APPENDIX A. SOURCES FOR UNIT COSTS ESTIMATES
This appendix presents the sources, assumptions, and methodology for developing the
individual unit cost estimates used in this analysis. Cost elements are categorized as either on
site, shipping, consolidation, or reclamation. Cost elements are presented separately for
batteries and thermostats, and pesticides in Exhibit A-l.
A-l
-------
Exhibit A-l
Sources for Unit Cost Estimates
Cost Element
Source
Assumptions/ Methodology
On-Site Costs
Packaging and labeling to DOT
specifications
Obtained from DPRA, September 1993.
Assumed cost of reading DOT regulations was a sunk
cost and not included.
Assumed one half-hour of labor per shipment using the
hourly wage of a laborer of $27.
Labor costs were obtained from Employment and
Earnings. March 1993, Bureau of Labor Statistics,
USDL.
$13.50 per shipment.
Maintenance cost of a contingency
plan
Obtained from "Estimating Costs for the Economic
Benefits of RCRA Noncompliance" Draft Report, May
1993.
$200 per generator.
A-2
-------
Cost Element
Source
Assumptions/ Methodology
Employee training
EPA professional judgment.
For compliance under the Proposed Part 273, assumed
$200 per training course per small quantity generator and
training for 4 employees per generator and requiring 1
hour per employee to attend the course, which resulted in
a total of $308 per generator.
Large-quantity generators receive more in-depth training.
For compliance under full RCRA Subtitle C
requirements, assumed $300 per training course per
generator and training 4 employees for 2 hours each.
Additionally, 1 hour of labor was assumed for the plant
manager and one half hour for a clerical person to
maintain records. Total training costs under full RCRA
Subtitle C requirements were $586 per generator.
Under the Honeywell reverse distribution system,
training costs were $308 for ampule removers, $40 for
generators, and $54 for wholesalers.
Bill of Lading
Personal communication with Lorie Prince of Ametech,
Inc. Environmental Transportation Services, Chanute,
Kansas, and EPA professional judgement.
Assumed .05 hours of a manager's time and .10 of an
engineer's time to fill out the bill of lading.
Labor rates used are $60 per hour for managers and $45
per hour for engineers.
$7.50 per shipment.
Manifest completion
& recordkeeping
Hours per labor group from Information Collection
Request Number 801 "Requirements for Generators,
Transporters, and Waste Management Facilities Under
the RCRA Hazardous Waste Manifest System", June
15, 1992.
Hourly rate per labor group from Employment and
Earnings. March 1993.
Assumed a total of .78 hours for completion and
recordkeeping. Time for completion was divided
disproportionately between a plant manager, engineer,
and clerical personnel.
$36.24 per shipment.
Land ban notification
Information Collection Request Number 1442.04 "Land
Disposal Restrictions for Newly Listed Wastes and
Hazardous Debris", November 24, 1992.
For large- and small-quantity generators, assumed a .10
hours of an engineer's time and .125 hours of clerical
time, with labor rates of $45 and $27 per hour,
respectively.
$7.88 per shipment
A-3
-------
Exhibit A-l (continued)
Sources for Unit Cost Estimates
Cost Element
ttMMMMW
Shipping Costs
Source
Assumptions/ Methodology
Hazardous waste transport
EPA professional judgement based on EPA's 1990
Survey of Selected Hazardous Waste Management
Industry.
Per pound costs were not available for less than truckload
quantities, however, full load averages were
approximately 1.3 times higher than common carrier
costs. Therefore, common carrier costs based on the size
of the load were multiplied by a factor of 1.3 to estimate
hazardous material transport costs.
Common carrier and parcel carrier
transport
Telephone interviews with common carriers.
Contacted Poole Truckline, Independent Freightwide,
TNT Red Star Express, J.B. Hunt Special Commodities,
Miles, Inc., and UPS
Distance from generator to
consolidation point
EPA professional judgment.
Assumed one consolidation point existed per metropolitan
statistical area (MSA). Average shipment distance to it
was 20 miles.
Distance from generator to
destination facility
EPA professional judgment.
The distances to disposal facilities was assumed to be
1,500 miles.
A thermal recovery facility handling Ni-cd batteries was
located hi Pennsylvania.
Mercury retorting facilities handling mercury-containing
batteries and thermostats were in Pennsylvania and New
York.
Distance from consolidation point
to destination facility
EPA professional judgment.
The distances to disposal facilities was assumed to be
1,500 miles.
Thermal recovery facilities handling Ni-cd batteries were
located in California and Pennsylvania.
Mercury retorting facilities handling mercury-containing
batteries and thermostats were hi Pennsylvania and New
York.
-------
Exhibit A-l (continued)
Sources for Unit Cost Estimates
Cost Element
Source
Assumptions/ Methodology
Consolidation Costs
Number of consolidation points
Cost per square foot of
consolidation facility
Warehouse size
Metropolitan statistical areas obtained from "Statistical
Abstract of the United States, 1991", Department of
Commerce, Census Bureau.
"Analysis for RCRA Reauthorization. " 1992, EPA.
EPA professional judgement.
Assumed one consolidation point per metropolitan
statistical area. This leads to 268 consolidation points.
Inflated the 1990 average cost of retail business space of
$4.26 per square foot to 1992 dollars.
$4.55 per square foot.
EPA developed size based ou the pounds of waste per
drum and drum storage arrangements assumed to be
appropriate. Assumed 55 gallon drum to be 2 ft by 3 ft.
packed 2 deep with 4 feet of aisle space between rows.
Assumed 16.36 Ibs/ gallon. This resulted in 112 pounds
of waste stored per square foot.
Reclamation Costs
Reclamation costs
Telephone interviews with reclamation facilities.
Obtained price quotes from INMETCO, Mercury
Refining, and Bethlehem Apparatus.
A-5
-------
Exhibit A-l (continued)
Sources for Unit Cost Estimates
Cost Element
Source
Assumptions/ Methodology
On-Site Costs
Contingency plan (Development)
Obtained from "Estimating costs for the Economic
Benefits of RCRA Noncompliance," Draft Report, May
1993.
$2,000 per generator.
Bill of Lading
Personal communication with Lorie Prince of Ametech,
Inc. Environmental Transportation Services, Chanute,
Kansas, and EPA professional judgement.
Assumed .05 hours of a manager's time and .10 of an
engineer's time to fill out the bill of lading. Assumed an
additional .10 of an engineer's time to fill out DOT
requirements on a shipping paper for hazardous materials
transported by a common carrier. Labor rates used are
$60 per hour for managers and $45 per hour for
engineers.
$12.00 per shipment.
Land ban notification
Information Collection Request Number 1442.04 "Land
Disposal Restrictions for Newly Listed Wastes and
Hazardous Debris", November 24, 1992.
Assumed a .10 hours on an engineer's time and .125
hours of clerical time, with labor rates of $45 and $27
per hour, respectively.
$7.88 per shipment
Employee training
EPA professional judgment.
For compliance under the Proposed Part 273, assumed
$200 per training course per generator and training for 4
employees per generator and requiring 1 hour per
employee to attend the course, which resulted in a total
of $309 per generator.
For compliance under full RCRA Subtitle C
requirements, assumed $300 per training course per
generator and training 4 employees for 2 hours each.
Additionally, 1 hour of labor was assumed for the plant
manager and one half hour for a clerical person to
maintain records. Total training costs under full RCRA
Subtitle C requirements were $586 per generator.
A-6
-------
Exhibit A-l (continued)
Sources for Unit Cost Estimates
Cost Element
Manifest
Source
Hours per labor group from Information Collection
Request Number 801 "Requirements for Generators,
Transporters, and Waste Management Facilities Under
the RCRA Hazardous Waste Manifest System", June
15, 1992.
Hourly rate per labor group from Employment and
Earnings. March 1993.
Assumptions/ Methodology
Assumed a total of .78 hours for completion and
recordkeeping. Time for completion was divided
disproportionately between a plant manager, engineer,
and clerical personnel.
$36.24 per shipment.
Shipping Costs
Hazardous waste transport
Transport Distance
EPA professional judgement based on EPA's 1990
Survey of Selected Hazardous Waste Management
Cost Analysis of Hypothetical Pesticide Recall Actions
U.S. EPA, Office of Pesticide Programs, July 19,
1991.
Per pound costs were not available for less than truckload
quantities. Full load averages were approximately 1.3
times higher than common carrier costs; multiplied the
common carrier cost by a factor of 1.3.
Assumed transportation to consolidation point was 300
miles.
Consolidation Costs
Bonded warehouse (Consolidation
Point)
RCRA Facility Storage
Cost Analysis of Hypothetical Pesticide Recall Actions
U.S. EPA, Office of Pesticide Programs, July 19,
1991.
Cost Analysis of Hypothetical Pesticide Recall Actions
U.S. EPA, Office of Pesticide Programs, July 19,
1991.
Assumed to be single story structures with concrete
floors, temperature control, sprinkler systems, security,
and secondary containment.
$1,629,071 per storage facility.
Assumed to be single story structures with RCRA
permits, insurance, concrete floors, temperature control,
sprinkler systems, security, secondary containment, and
ground water monitoring.
$26,291,758 per storage facility.
A-7
-------
v°/EPA
United States
Environmental Protection Agency
(5305)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
------- |