130987501
       HAZARDOUS WASTE PICKUP PROBLEMS
                   AMONG
AUTOMOTIVE MAINTENANCE AND DRY CLEANING FIRMS
                 July 1987
             George F. Lord II
          Administrative Assistant

      Office of Small Business Ombudsman
      Environmental Protection Agency

-------
                              EXECUTIVE SUMMARY

                       HAZARDOUS WASTE PICKUP PROBLEMS
                                    AMONG
                 AUTOMOTIVE MAINTENANCE AND DRY CLEANING FIRMS


     Following  the  September  1986 effective date of EPA Small Quantity Generator
 regulations,  the EPA Office of  Small Business Ombudsman began receiving complaints
 from small  business firms citing hazardous waste pickup problems.  Most of the
 complaints  were  from automotive maintenance and dry cleaning firms, especially
 the latter.   Trade  associations representing these firms joined them in expressing
 concerns that these problems  were leading toward business mortalities or massive
 illegal dumping.  Seven  trade associations and two trade journals distributed a
 common questionnaire to  their respective constituents/subscribers to determine
 the substance, severity, and  geographical location of the problems reported.  In
 this collaborative  effort, the Office of Small Business Ombudsman agreed, in its
 role as recipient and investigator of small business complaints, to receive,
 review, and report  response to  the questionnaire.  Following receipt of 1,102
 responses (38% from automotive maintenance and 62% from dry cleaning firms), the
 results were  reviewed and the attached report prepared.

     The response obtained substantiated the allegations which prompted the
 investigation, indicating prevalence of the following salient problems:

     0 Hazardous waste pickup service is not available in some isolated, rural,
       and  small town areas;

     0 Some generators are not  utilizing or are terminating pickup service
       because it is deemed unreasonably costly or unnecessary;

     0 Monopoly  of  pickup service is widespread;

     0 Where monopoly prevails, high and escalating prices, coercion, intimida-
       tion, and threatened boycott are present;

     0 Confusion, largely attributable to abstruse regulatory language, is
       prevalent with respect to what is and is not regulated waste and between
       overlapping  Federal, state, and local regulations;

     0 Government environmental agencies are deemed responsible for compliance
       problems with an obligation to resolve them; and

     0 Without corrective action, extensive small business mortality or massive
       illegal dumping will probably result.

     Cursory assessment of these problems indicates that Agency economic impact
analyses applied to development of the Small Quantity Generator Regulations do
not reflect realities of the  current compliance situation.  A thorough evaluation
of this situation,  followed by rectifying action, appears warranted.

     The methodology, results, and economics of this collaborative investigation
suggest that it may serve well as a model applicable to the periodic review of
regulations impacting small business, which the Agency is committed to conduct
in implementation of the Regulatory Flexibility Act.

-------
                                 CONTENTS


Title                                                                Page

  I.  Overview	   1-1

 II.  Transporter Availability	II-l

III.  Transporter Cost
      Introduction	Ill- 1
      Satisfied/No Complaint	Ill- 4
      No Competition/Monopoly 	 Ill- 5
      Monthly Charge Unjustified	Ill- 6
      Coercive Product Marketing	Ill- 7
      High/Unreasonable Prices	Ill- 9
      Equitable Pricing Uncertainty 	 III-ll

 IV.  Transporter Service Rendered	IV-1

  V.  Compliance/Enforcement	   V-l

 VI.  Regulations	VI-1

VII.  Summary and Assessment	VII-1

Appendix A.  Questionnaire	A-l

Appendix B.  Comments 	 .... 	 .....B-l
               Transporter Availability 	 B-2
               Transporter Cost	B- 5
               Transporter Service Rendered 	 B-31
               Compliance/Enforcement ...... 	 B-36
               Regulations	B-41

-------
       HAZARDOUS WASTE PICKUP PROBLEMS
                    AMONG
AUTOMOTIVE MAINTENANCE AND DRY CLEANING FIRMS
                  July 1987
              George F.  Lord II
           Administrative Assistant

      Office of Small Business Ombudsman
       Environmental Protection Agency

-------
                              EXECUTIVE SUMMARY

                       HAZARDOUS WASTE PICKUP PROBLEMS
                                    AMONG
                AUTOMOTIVE MAINTENANCE AND DRY CLEANING FIRMS


      Following  the  September  1986 effective date of EPA Small Quantity Generator
 regulations,  the  EPA Office of  Small Business Ombudsman began receiving complaints
 from small  business firms citing hazardous waste pickup problems.  Most of the
 complaints  were from automotive maintenance and dry cleaning firms, especially
 the  latter.   Trade  associations representing these firms joined them in expressing
 concerns that these problems  were leading toward business mortalities or massive
 illegal dumping.  Seven  trade associations and two trade journals distributed a
 common questionnaire to  their respective constituents/subscribers to determine
 the  substance, severity, and  geographical location of the problems reported.  In
 this collaborative  effort, the Office of Small Business Ombudsman agreed, in its
 role as recipient and investigator of small business complaints, to receive,
 review, and report  response to  the questionnaire.  Following receipt of 1,102
 responses (38% from automotive maintenance and 62% from dry cleaning firms), the
 results were  reviewed and the attached report prepared.

      The response obtained substantiated the allegations which prompted the
 investigation, indicating prevalence of the following salient problems:

      0 Hazardous waste pickup service is not available in some isolated, rural,
       and small town areas;

      0 Some generators are not  utilizing or are terminating pickup service
       because it is deemed unreasonably costly or unnecessary;

      0 Monopoly of  pickup service is widespread;

      0 Where monopoly prevails, high and escalating prices, coercion, intimida-
       tion, and threatened boycott are present;

      0 Confusion, largely attributable to abstruse regulatory language, is
       prevalent with respect to what is and is not regulated waste and between
       overlapping  Federal, state, and local regulations;

      0 Government environmental agencies are deemed responsible for compliance
       problems with an obligation to resolve them; and

      0 Without corrective action, extensive small business mortality or massive
       illegal dumping will probably result.

     Cursory assessment of these problems indicates that Agency economic impact
analyses applied to development of the Small Quantity Generator Regulations do
not  reflect realities of the  current compliance situation.  A thorough evaluation
of this situation,  followed by rectifying action, appears warranted.

     The methodology, results, and economics of this collaborative investigation
suggest that it may serve well as a model applicable to the periodic review of
regulations impacting small business, which the Agency is committed to conduct
in implementation of the Regulatory Flexibility Act.

-------
                                 CONTENTS


Title                                                                Page

  I.  Overview	   1-1

 II.  Transporter Availability	II-l

III.  Transporter Cost
      Introduction	 Ill- 1
      Satisfied/No Complaint	Ill- 4
      No Competition/Monopoly 	 Ill- 5
      Monthly Charge Unjustified	Ill- 6
      Coercive Product Marketing	Ill- 7
      High/Unreasonable Prices	Ill- 9
      Equitable Pricing Uncertainty 	 III-ll

 IV.  Transporter Service Rendered	IV-1

  V.  Compliance /Enforcement	   V-l

 VI.  Regulations	VI-1

VII.  Summary and Assessment	VII-1

Appendix A.  Questionnaire	A-l

Appendix B.  Comments	•	8-1
               Transporter Availability 	 B- 2
               Transporter Cost	B-5
               Transporter Service Rendered 	 B-31
               Compliance/Enforcement ....... 	 B-36
               Regulations	B-41

-------
                                    I

                                 OVERVIEW
      Soon  after  the  September  1986 effective date of most requirements
 under the  Environmental Protection Agency Small Quantity Generator reg-
 ulations,  the EPA Office of Small Business Ombudsman began receiving
 varied complaints from impacted small business firms citing compliance
 problems related to  hazardous  waste pickup.  The source of complaints
 indicated  that the problems reported were heavily concentrated among
 automotive maintenance and dry cleaning firms, especially among the
 latter.  Initially the complaints were discounted as probably the inevi-
 table consequence of regulatory impact upon business firms heretofore
 unencumbered by  paperwork requirements, with a tradition of casual disposal
 of  all wastes to drainage systems or general trash collection and now faced
 with  new costs contributing nothing to productivity or profit.  However,
 during ensuing months these complaints become more numerous and more
 severe.  Some trade  association representatives joined the entrepreneurs
 in  expressing apprehensions over what appeared to be an accumulating
 collection of problems, possibly developing into a trend leading eventually
 to  either  unbearable economic  burdens (business mortalities) or massive
 noncompliance (illegal dumping).  Some of the complaints were expanded to
 include serious  allegations against EPA, state environmental agencies,
 and especially waste collection firms.  These allegations included:

      0 Inadequate or unrealistic Agency regulatory economic impact analysis;

      0 Premature promulgation  of regulations without allowance of time for
       industrial technological adjustments;

      0 State regulations combining with economic factors impacting
       transporters  so as to effectively nullify federal provisions
       for minimization of regulatory Impact on small business;

      0 EPA creation  of a waste collection market situation inviting legal,
       technical, and financial exploitation of Small Quantity Generators,
       as  well as Conditionally Exempt Generators;

      0 Transporter monopolistic pricing policies and coercive marketing
       tactics;  and

      0 Unavailability or refusal of transporter collection services for
       isolated, rural, and small town areas.

     During subsequent discussion between the Office of Small Business
Ombudsman and representatives  of seven trade associations and two trade
journals, agreement  was reached to look into the substance, severity, and
distribution of  some of these  complaints through a collaborative effort.
The representatives  agreed to  a common questionnaire which they would
distribute to their  respective constitutents/subscribers.  The Ombudsman
agreed, in its role  as recipient and investigator of small business
complaints, to receive, review, and report the response, as well as

                                   1-1

-------
alert Agency administrators to any allegations substantiated or other
salient problems illuminated by the data collected.

     The participating entities representing automotive maintenance and
dry cleaning were:

     0 Automotive Body Repair News
     0 Automotive Service Association
     0 National Automobile Dealers Association
     0 Washington Metropolitan Auto Body Association
     0 International Fabricare Institute
     0 Institute of Industrial Launderers
     0 The Coin Laundry Association
     0 National Clothesline
     0 Neighborhood Cleaners Association

     The questionnaire devised began with a brief explanation of purpose,
followed by a query to determine classification of respondents in terms of
volume of hazardous waste generated.  Next, four "yes" or "no" questions
were posed concerning:  regulatory compliance through use of a hazardous
waste transporter, if available; availability of competing alternatives
in transporter selection; consistent reliability of scheduled transporter
pickups; and respondents' judgment of reasonableness of transporter
prices.  Space was provided at the end for respondents' listing of any
"other problems."  A copy of the questionnaire is included herein as
Appendix A.

     Receipt of response began in mid-March of 1987 and, despite a
continuing trickle of input, a decision was made to tally and examine the
data on hand as of the end of June.  At that time 1,102 responses were
tabulated, 423 (38%) from automotive maintenance firms and 679 (62%) from
dry cleaning plants.  Table 1-1 shows the total automotive maintenance
and dry cleaner response distributed by Federal Regions and States.  The
invitation to submit "other problems" resulted in contributions from 533
respondents (48%), many consisting of vivid comments, some short and
some as lengthy as two attached typewritten pages.*  The delineation of
"other problems" and comments are reproduced verbatim in Appendix B.

     The repondents' statements of problems and comments add substance,
elaboration, and detail to statistical response to specific questionnaire
queries and, additionally, surface a number of unanticipated issues of
concern as well as some general and specific recommendations.  These
statements, along with the larger number of responses received from dry
cleaning versus automotive maintenance firms, indicate that hazardous
waste pickup problems are comparatively far more widespread and severe
among dry cleaners at this time.

*Each comment cited is followed by parenthetical data identifying:  state
of origin; type of industry; class of generator, i.e., zero, under 100
kilograms, small (100 to 1000 kilograms), or large (over 1000 kilograms);
"yes" or "no" reponse to questionnaire items 2, 3, 4, and 5; and  the
number assigned to the specific response.  Respondents' identification of
seven specific transporter firms has been deleted  and replaced, in
brackets, with Transporter X.

                                   1-2

-------
Table 1-1:   Response Distributed by Federal Regions and States
Region
State
Region 1
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont

Region II
New Jersey
New York

Region III
Delaware
D.C.
Maryland
Pennsylvania
Virginia
West Virginia

Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
No. Carolina
So. Carolina
Tennessee

Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin

Auto
Maint.
7
2
1
2
2
0
0

30
8
22

41
0
0
7
30
1
3

32
1
16
4
1
0
3
4
3

71
15
6
11
13
22
4

Dry
Clean.
33
7
2
19
4
1
0

55
7
48

79
1
1
34
27
15
1

118
3
29
35
7
4
18
10
12

133
31
22
13
21
28
18

Total
40
9
3
21
6
1
0

85
15
70

120
1
1
41
57
16
4

150
4
45
39
8
4
21
14
15

204
46
28
24
34
50
22

Region
State
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas

Region VII
Iowa
Kansas
Missouri
Nebraska

Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming

Region IX
Arizona
California
Hawaii
Nevada

Region X
Alaska
Idaho
Oregon
Washington

Not Located



TOTAL
Auto
Maint.
88
1
6
9
9
63

15
2
1
10
2

15
10
1
1
0
1
2

83
7
75
0
1

21
0
0
11
10

17



423
Dry
Clean.
83
4
25
1
4
49

27
12
5
9
1

33
18
2
1
3
9
0

73
11
60
1
1

23
2
3
3
15

25



679
Total
171
5
31
10
13
112

42
14
6
19
3

48
28
3
2
3
10
2

156
18
135
1
2

44
2
3
14
25

	 45



1,102
                                   1-3

-------
     The results from the data collection effort are presented and discussed
in the following sections under the headings:
     0 Transporter Availability,
     0 Transporter Cost,
     0 Transporter Service Rendered,
     0 Compliance/Enforcement, and
       Regulations.

     Some cautionary words are appropriate preceding perusal of this
presentation.  First, both the substance and quantity of the data must be
regarded as indicative; the reponse was not solicited from a statistically
valid representative sample of the universe of automotive maintenance and
dry cleaning firms.  That universe is very large, with an estimated total
of 250,000 automotive maintenance and 25,000 dry cleaning firms.  Hence,
although obtaining precise measurement of issues was obviously never
within the scope of the effort, indicative generalizations from the data
at hand are certainly appropriate.  Second, the data present facts and
opinions from one frame of reference, that of hazardous waste generators,
without the benefit of contributions or rebuttals from regulatory agencies,
environmentalists, transporters, or disposers.  One aspect of these two
factors is embedded in the solicitation of response, which was primarily
directed to members of trade associations.  Such membership may be more
extensive in heavily populated urban areas than in areas where population
is scattered or clustered in small towns.  Still, with respect to the recog-
nized nonrepresentative nature of the data, it is interesting to note that
the geographical distribution of response nearly parallels federal regional
population distribution, with a difference of only two or less percentage
points in eight of the ten regions and a difference of four percentage
points in Regions IV and VI.

Table 1-2;  Population and Total Response Distributed by Federal Region

  Region                    % Population                  % Response

     164
    II                            7                             9
   III                           11                             11
    IV                           18                             14
     V                           21                             19
    VI                           12                             16
   VII                            5                             4
  VIII                            3                             4
    IX                           13                             13
     X                            4                             4
 Blank                           —                           	4
    Total                       100                           102

     A third factor, to which potential bias might be attributable, is
nonresponse from firms knowingly not in compliance.  Despite encouragement
of anonymous response, this factor may have substantial weight; only
eight of the 117 respondents (11%) without pickup arrangements  indicated
                                    1-4

-------
they were small or large quantity generators.  However, substantial non-
response due to noncompliance would suggest that the pickup problems
reported may be more extensive than reflected in the data collected.
Fourth, it is apparent from the text and temper of numerous comments
submitted that the solicitation of response to the questionnaire opened
the door to expressions of regulatory discontent from many entrepreneurs.
Further to this, it is generally accepted that those only mildly or not
at all discontented are not highly motivated to respond to such a solicit-
ation.  To some extent this factor is reflected in the data, adding some
additional measure of bias.  However, the fact that many respondents
indicated no problems and some expressed satisfaction with their situation
mitigates the weight of this bias.

Despite the above qualifications, the data collected indicate a growing
prevalence and severity of small business hazardous waste pickup problems
which should not be ignored and, if not resolved in some measure, pose a
threat to achievement of the objectives of the Environmental Protection
Agency.
                                   1-5

-------
                                    II

                         TRANSPORTER AVAILABILITY
     Among the 1,102 respondents, 970 (88.0%) reported a hauling firm
available and being utilized to pick up their hazardous waste.   Fifteen
respondents (1.4%) failed to answer this question.  The remaining 117
respondents (10.6%) were comprised of 85 automotive maintenance firms
(7.7%) and 32 dry cleaning firms (2.9%) reporting no disposal arrangements.
Table II-l shows the latter group categorized according to reported
quantity of hazardous waste generated and distributed by Federal regional
locations.

     A much larger proportion of the automotive maintenance than dry
cleaner respondents reported no arrangements for hazardous waste pickup,
20 percent versus 5 percent.  Some explanation of this difference probably
stems from the perception among auto maintenance entrepreneurs of exemption
from disposal regulations because of the small amount of hazardous waste
generated; 64 (15%) of the total reported generation of less than 100 kilo-
grams per month and 11 (3%) reported zero generation.  These figures com-
pare to 26 (4%) of the total responding dry cleaners reporting less than
100 kilograms and only 5 (0.7%) reporting zero generation.  Other factors
contributing to this difference include the comparative diversity of auto-
motive maintenance wastes (solvents, batteries, asbestos, oil, hydraulic
fluids, coolants, tires, mufflers, sheetmetal), combined with confusion
surrounding Federal versus state regulations.  The situation among dry
cleaners is less complex, their wastes being limited to solvents, filters,
and still bottom residue.  These latter wastes are generally known to be
regulated, although some confusion prevails concerning the identification
of purged filters as hazardous, as well as the applicability of regulations
to dry cle'aners generating less than 100 kilograms per month.  Probably the
most influential factor affecting this difference between the two industries
is the more widespread and aggressive marketing activities applied to dry
cleaners by waste transporting firms.

     The eleven automotive maintenance firms with no disposal arrangement
reporting generation of no hazardous waste were located in six of the ten
Federal regions:  one in Region IV (Florida), four in Region V (one in
Ohio and three in Minnesota), two in Region VI (one in Oklahoma and one
in Texas), one in Region VIII (Colorado), one in Region IX (Arizona), and
one in Region X (Washington), along with one bearing no location identi-
fication.  Among the total response from automotive maintenance firms,
many indicated used motor oil was their only waste, and this is probably
true of most if not all of these eleven respondents.

     Five dry cleaning firms reported generation of no hazardous waste:
two in Region IV (Florida and North Carolina), one in Region V (Illinois),
one in Region IX (California), and one in Region X (Washington).  Only
the Washington respondent provided comment, contradicting his reported
zero waste generation:

                                   II-l

-------
 e
 o
 60
 V
 tt!
 01
•O
 OI


 3


•H
 IJ
4-1

 CO
•H

Q


4J

 C



 OI



 CO
 a


 o
M
OH

 O
 C
 01
•a

 o
 a
 co
 V
PS
 0>
M
.£>
C
CO
01
«
M
(0
CO
CO
O £H
CO
»-> s
O CO
4J
SP 1 .
C (U M
•H e oi
c o> -a
CO O C
a> is
M
>^ O
>-> M
O 01
M
CO
H
"s
CO
PQ
0>
M
M
CO
J
en
0) CO M
O CO M
C M CO
CO CJ 3
C c/5
0> lJ
C  M M M X
MMMM>>>>MX

cceecccecc
OOOOOOOOOO.X
bO &0 tU) &0 &C bo bC bo be bo rt
QJft)4)Q)4)4)4)QJVV ^H
CijQrfOiOtfQtfQcSodDiOrfOiCC


o



o




^o
tN


m

CN





^H




oo






"*^


-H


00

r**
^H


nJ
3
o
H


                                                      II-2

-------
     0 We have been trying to get someone to run to our town,  but none yet.
       We are a long way out of Seattle and Spokane.  Not many cleaners
       close by.  This makes it bad for us to get someone to pick up our
       filters and still bottom.  We are putting the still bottom in steel
       drums till we can get someone by to pick it up.

     Among the dry cleaners who reported no pickup arrangement not one
indicated that they were large or small quantity generators.  Of the 85
automotive maintenance firms reporting no pickup arrangements, only one
was classified as a large quantity generator and eight identified themselves
as small quantity generators.  The large quantity generator, located in
Region VIII (Colorado), did not respond to queries 3, 4, or 5, and provided
no comments.  Response of the eight small quantity generators  was as follows:

     0 One in Region II (New York) indicated inability to competitively
       select haulers, unreliability of pickups, and unreasonable hauler
       prices, with no comments;

     0 One in Region III (Maryland) reported hauler pickups unreliable
       and unreasonably priced, commenting that "No one wants mufflers
       and batteries, expense is clear out of line";

     0 Another in Region III (Pennsylvania) provided no reponse to queries
       3, 4, or 5, but commented that "Bids received so far are unreasonable";

     0 One in Region VI (Louisiana) did not respond to queries 3, 4, or
       5, and provided no comments;

     0 Another in Region VI (New Mexico) responded in the negative to
       queries 3, 4, or 5, but offered no comments;

     0 One in Region VIII (Wyoming) did not respond to queries 3, 4, or
       5, but reported "Can't find hauler";

     0 Two in Region X (California) did not respond to queries 3, 4, or
       5, and provided no comments.

     Respondents who identified themselves as generators of less  than  100
kilograms per month, conditionally exempt generators, accounted for 90
(77%) of the 117 having no disposal arrangements, 64 automotive maintenance
firms and 26 dry cleaners*  The response of this group is categorized
below by Federal region.

     Region I.  No automotive maintenance firms, but one dry  cleaner
(Connecticut) who provided no comments.

     Region II.  No dry cleaners, but two automotive maintenance  firms
(New Jersey and New York).  The New Jersey respondent reported having  had
a hauler:

     0 Previously, but not at present, stating  that  the  hauler's
       pickups were "Always too soon."


                                   II-3

-------
 The  New York  respondent stated that:

      0 We  use waste burners for all except antifreeze (not burnable).

      Region III.  No dry cleaners, but eight automotive maintenance firms,
 seven in Pennsylvania and one in West Virginia.  Problems or comments
 cited by the  Pennsylvania respondents included:

      0 Getting rid of used batteries legally.

      0 Have only used motor oil waste.

      0 Where  can I get a list of haulers in western Pennsylvania?

 The  West Virginia respondent reported:

      0 No  hauler within 80 miles that we can find.  Have made many calls
       for pickup - no response.

      Region IV.  Four automotive maintenance respondents, all in Florida.
 Their statements of problems or comments included:

      0 Understanding the EPA laws!

      0 No  haulers available.  We have a real problem with this!  Locations
       to  haul to are a problem also.

      0 I think the government should be responsible for waste.  What is
       their purpose?  They should help us.  We are not making millions
       of  dollars selling chemicals.  Chemical companies make these
       poisons, not me.  The price to dispose is a joke.  I'm responsible
       for producing wastes?  I did not manufacture these chemicals, a
       big chemical company did.  I thought the government was here to
       help us.  The poor pay as the rich play.

Six dry cleaning firms, two in Georgia, one in Mississippi, and two in
South Carolina.  One Georgia respondent commented:

      0 Waste generated by dry cleaning shop is 10-12 gallons a month.
       According to law (EPA regulations), less than 220 pounds or 1/2 of a
       55 gallon drum won't be necessary to report.  Let me know; do I have
       to report?

The Mississippi dry cleaner stated that:

      0 No one will service me or other plants in my area.

The South Carolina respondents commented as follows:

     0 Only one hauler is available that I know of, [Transporter X].
       About 5 gallons of oil from the still and 10 medium wet filters
       every 2-1/2 months doesn't require hauling.

                                   11-4

-------
      0  [Transporter X] is the only hauler in this area.  We had [Transporter
       X] contact us to set up service, but they never came back to pick
       up.  The price quoted to us by  [Transporter X] was not reasonable
       in our opinion.

      Region V.  Nine automotive maintenance respondents, two in Illinois,
one in Indiana, two in Michigan, one in Minnesota, two in Ohio, and one
in Wisconsin.  Four of these contributed comments as follows:

      0 Need guidelines for selecting hauler.  Outline other ways of
       disposing and how long they will be legal.

      0 We're getting a recycler (ordered).

      0 Recycling is not the answer!  What do you do with all the thinner?

      0 Prices will be high because this is a required task.

One of the respondent dry cleaners in Michigan stated:

      0 Our tested waste is 0.005 [due] to cookdowns.

      Region VI.  Twelve auto maintenance firms, one from Louisiana, two
from  New Mexico, one from Oklahoma, and eight from Texas.  The Louisiana
respondent stated that:

      0 Have called several haulers during the past 15 years.  They are hard
       to get to come out.  Takes 3 to 4 weeks before they will show up.
       You have to keep calling; they  promise the driver will show up, and
       he never does.  If you are small they do not want to be bothered.

Other comments from this group were:

      0 I generate 5 gallons per month.

      0 Not enough information on hauling firms.

      0 Cannot get consistent answers on what waste I generate is hazardous,
       in particular, coolant.

Of three dry cleaners, all in Texas, two contributed the following comments:

      0 [Transporter X] is the only game in town.  They know  it and their
       prices reflect it.  They were high in the first place.  Then they
       raised their prices even more this year.

      0 Our plant is small and in Houston.  Only one  company,  [Transporter
       X], picked up the waste and required us to be a member with
       unreasonable fees (setup fee $100 plus monthly fee  plus filters
       and waste pickup).  We wonder what we are going to  do in this
       case.  Please advise!

                                   11-5

-------
      Region VII.   Six  automotive maintenance firms, two in Iowa, one in
 Kansas,  one in Missouri,  and  two in Nebraska.  One of the Iowa respondents
 reported that:

      0 Occasionally  someone will take waste oil but no one takes solvents
       or  batteries.

 The  sole Iowa  dry  cleaner respondent in  this group stated that:

      0 I have  the  desire  to dump my hazardous wastes properly but can get
       no  help.

      Region VIII.  Five automotive maintenance firms, three in Colorado,
 one  in Montana, and  one in Wyoming.  Comments from two Colorado respondents
 were:

      0 So  far  have found  only one hauler.  Thought his prices were high.

      0 Our  paint supplier picks up waste and recycles it for our use.

 From Montana came  the  statement:

      0 No disposal site and no registered haulers in Montana, fourth
       largest  state.

 The  Wyoming  respondent alleged that:

      0 In towns under  2,000 population no hauler wants to come.

 Among the three dry  cleaners in this group, a Montana respondent, stated
 that:

      0 I cook down my  filters and when I change them I do not exceed 120
       pounds.

 The  other two,  from Montana and Utah, provided no comments.

     Region  IX.  Eleven respondents, ten automotive maintenance firms and
 one  dry cleaner, all in California.  Two of the automotive firms contributed
 comments:

     0 I am  confused as to what hazardous waste I do generate.

     0 Our only waste  is  engine oil and antifreeze.

     Region X.  Two automotive firms, both in Washington, offered no
comments.  Nine dry cleaners, two in Alaska, two in Idaho, three in
Oregon, and  two in Washington.  The Alaskans contributed the following:

     0 Alaska is too small a market for disposal services.  We're on our
       own up here.
                                   11-6

-------
     0 Have to ship still bottom oil, with only trace amounts of perc in
       it, as hazardous waste.  Has to be shipped to Seattle in ocean-
       going container all by itself, cost $2,000.  I generate only 55
       gallons over 270 days.  End cost of about $2,500 for disposal of
       55 gallons of still bottom oil v.ith only trace amounts of perc in
       it.

One of the Washington respondents commented:

     0 In this state there is a lot of confusion regarding disposal of
       hazardous waste.  The state law supersedes Federal law and
       definitions and interpretations are difficult to understand.

     Not Located;  One comment was provided by a respondent among the
seven who failed to identify their locations:

     0 Rural area; hauler not available.

     The foregoing indicates that hazardous waste pickup is available and
being utilized by most automotive maintenance and dry cleaning firms in
most areas of the country (88.0 percent of the respondents).  Comments
from the comparatively small proportion of respondents with no pickup
arrangements (7.7%) disclose a variety of specific reasons given for that
situation.

     0 Pickup service in the generator's area is not available,

     0 Service is unavailable with respect to specific wastes generated,

     0 Service is unavailable or unreliable for small generators,

     0 Service available is not used because of high prices,

     0 Service once utilized has been terminated because of escalating
       prices,

     0 Service is deemed not required because of small quantity regulatory
       exemption,

     0 Service is deemed not necessary because of generator's hazardous
       waste minimization,

     0 Service not initiated because of uncertainty/confusion concerning
       type/quantity of wastes subject to regulation,

     0 Service not initiated because of rejection of governmental  decision
       placing disposal responsibility on generators rather  than chemical
       manufacturers.

     The lack of disposal arrangements among this group might be discounted
as a small residual problem which (with education, expansion of available
service, and time) will eventually disappear.  Furthermore,  the large  pro-
portion of respondents with pickup arrangements now functioning might  be

                                   II-7

-------
viewed as evidence of a nationwide effective system evolving.  However,
response from the group of generators now utilizing pickup services reveal
many of the same problems cited above plus others threatening tenability
of the evolving system.  Data reflecting this are examined in the following
sections.
                                   II-8

-------
                                   Ill

                            TRANSPORTER COSTS
Introduction

     With respect to transporter competitive selection and cost, the
questionnaire solicited response from only those with waste pickup
arrangements.  These included 970 (88%) of the 1,102 respondents,
334 automotive  maintenance firms and 636 dry cleaning firms.  The
remaining 15 failed to indicate whether or not they had pickup service.
Tabulation of answers to the questions of whether or not (1) the respondent
was able to select his hauler from competing firms and (2), in the respond-
ent's judgement, his hauler's prices are reasonable appear in Tables III-l
and III-2, the first showing response from automotive maintenance firms
and the second from dry cleaning firms.  The respondent's classification
of his volume of hazardous waste generated in any month is also shown in
these tables:  i.e., zero, less than 100 kilograms, between 100 and 1000
kilograms, and over 1000 kilograms.

     Tables III-l and III-2 reflect significant differences between
automotive maintenance and dry cleaning firms.  Whereas over half (52%)
of the automotive firms indicated selection of haulers from competitors,
only slightly over one-fifth (22%) of the dry cleaners indicated a choice
was available to them.  Availability of choice exceeded no-choice among
automotive maintenance firms in four of the ten Federal regions and in
none among the dry cleaners.  Although the proportion of automotive firms
unable to select their transporters was high, 47 percent, this restriction
among dry cleaners was far more widespread, 79 percent.

     A relationship between availability of hauler selection and judgement
of reasonableness of hauler prices is suggested in comparisons between
the two tables.  Among automotive maintenance respondents, 59 percent
judged transporters' prices reasonable against a 37 percent judgement of
unreasonable.  This contrasts sharply with dry cleaner response, where
the judgement was 22 percent reasonable and 70 percent unreasonable.  The
judgement of reasonable from automotive maintenance firms exceeded unrea-
sonable in six of the ten regions, but among dry cleaners in only one of
the regions.

     Combining response from the two industrial groups, 68 percent
indicated they were unable to select their hazardous waste transporter
from competing firms, 30 percent were able to do so, and 2 percent did
not answer the question.  Concerning transporter prices, collectively
59 percent judged them unreasonable, 35 percent judged them reasonable,
and 6 percent did not respond.  Among the 6 percent who failed  to answer
the latter question, nearly all commented that they were unable  to form a
judgement due to the absence of competition.
                                  III-l

-------
  C
  CU

  CU
  M
 •O

 ^  C
      o
  CU -H
  U  bo
 •H  01
   •  CO

  O  CU
 i-l T3
 4J  01
  CJ pt<
  0>

  0) JS
 C/5
     •o
  rJ  01
  Ol 4J
 M  3
  3 rO
 -    w
••  CO -H
 i-l   01
 pti   co
      c
  01   O
  o   a
  c
  CO
  c
  CU
      §
  CO  i-l
  0)
  >   01
 •H  4J
  4-1   CO
  O   CO
  3   C
 <   co
 jD
  CO
 H
•a
CO
oa
01
be
co
OJ
3 -O
r-l CU rH-
O 4J rH
> n) CO
M S
cu o> co
4J C
CO O
CU
•g
O
o
CU
N
C
CO
03
i— I
CO £>
CU CO O
U C Z
•H O
U CO
Qu CO
CO
CU
1
«
•o
M 0)
0) 4J O
r-l U Z
3 V
CO r-l
X 01
CO
O>
in

4-1
o
H





C
o
•H
00

fit*

o o -< o o



O -* O — i CN




en rn O> — < esl
«— f f— ( — H




-* CN O en O
rH CM "> -*

O O -H CN en


— i en CN O — i



CN en \o en -^
rH -H -H CN




I-l M I-l M >

C C C C C
O O 0 0 0
•H tH -H -H i-l
bo bo bO bo bb
cy cy gj 4) cy
Di Oi OS ft! Btf
OOO— irnoen— i



^HOOrHOOCjNen




om— i—  m
-H-nO-HOOen— "


meNinincy>eNva3r»-
en esa m •*
^H


f"*.*ocN*3'Oors»incN
en •» r~ in
v-H
enc7Nr^.Or-s > > M X « C
O rH 0)
CCCCCOCOU
OOOOOrJ4Jl-l
•H -H i-l -H -rt O 01
bObObObObC4->HrM
01 0) 01 01 9) O
0(4 Oj 0£ QEi Qtf Z
                                                                       III-2

-------
    C

  « o
•U  -H
C  bo
01  01
E  OH
01
bO M
T3  CO
3  l-i
<->  0)
    •o
01  01
O  b-
•H

^  >,
BLi  -Q
 C  O)

 O  4J

•H  3

4-1  XI

 CJ  -H

 01  I-l

M  4-1

 oi- > -a
 M   c
a   co
CM
 CO

H
1
M
CU
b£
l-i
CO
01
3 T3
M 0) M
O W M
> cfl co
>-> e
01 01 CO
4-1 C
CO O
CU
•o
C
o
^4
01
c
CO
CO -Q
01 CO O
U C Z
•H O
I-l CO
eu cfl
CO
01
c
CO
oa
u-s
01 4J O
•H y z
d o)
CO M
5C 01
co
OJ
M
CO
o
H





c
o
T-l
bC
01
Oi
OOOcN-^-*OOOOO
OOOOCM—  CM -sfr ~^ *-*•—<




t~j i^ > en r** r^* o^ f^ oo o^ c*o "^
CM *a* *a~ \O 00 *^* ^^ ^^ "^ ^^ *— '

cnporoincMcNO^^'^'OCM
I— t

•^ in so m o *a* ""^ CM oo *a* CN

cNCM^eyi^—JOin-Hinin
^H ^a* vjp v^ Q^ vp CN CN *^ *™^



inoocMmoo-3'>3'fri-^inin
-^ ^H CM CM -H CM
-HOOmenoo-^cNCNO



ON QO "-^ CO 00 CO C*"> VtO CO P^ sO
— -*\4300Or>-CNCM-a- ^^


»->
en in r^ c^ m r*^ CN en r*^ ^^ c^
^^


M T
"^ ^H
m —i



m p^
r-~ CM




r^ vo
^— H vp
"*
m m
m

i— i oo
in
m o
•^ ^,
•^


O CM
>* CM
CM CM
-H


^f CTv
O r^*
in


I 0 <*
I CM --
1 "^
vO O
fO O
s,O *••<

01
bo
M MM 0) CO
MM> MMMX 4-
1 U
MMMM>>>>MX!Cfl C
C,
) M 01
ccceccccccocou
OOO OOOOOOOJWl-i
b0b0b0b0b0bcb0b0b0b04>
O 01
> H 0-
CUOIOIOIOIOIOICUOIOIO
oiaittiaiaiaiQicrfoialz
                                                    III-3

-------
     Among  the  970  respondents with hazardous waste pickup arrangements
 619  (64%) reported  generation of less than 100 kilograms per month,
 60 percent  of the automotive maintenance and 66 percent of the dry clean-
 ing  firms.   Some of  these generators may be classified as conditionally
 exempt  small quantity generators under Federal regulations.  However,
 this exemption  does  not, of course, prevail in states with more stringent
 regulations under which a lower level or no exemption exists.  Despite
 this, it appears that many, possibly all, hazardous waste transporters
 find it technically  or economically impractical, or deem it financially
 undesirable, to distinguish between firms exempt and firms not exempt
 from regulations.   The position of the transporters is understandable and
 in some measure justifiable.  Still, from the data at hand, the question
 emerges as  to whether or not some generators are unwittingly bearing some
 unrequired  pickup costs.

     Three  hundred  and nineteen (33%) of the 970 respondents with pickup
 arrangements submitted comments related to transporter costs.  Five
 percent of  these contributed comments favorable to their transporters,
 9  percent reflected  uncertainty regarding the reasonableness of transporter
 prices, and 86  percent expressed cost complaints.  All of these comments
 are reproduced  in Appendix B, where they are grouped under six categorical
 headings:

       Satisfied/No  Complaints,
       No Competition/Monopoly,
       Monthly  Charge Unjustified,
       Coercive Product Marketing,
       High/Unreasonable Prices, and
       Equitable Pricing Uncertainty.

     The following abbreviated sampling from the comments, under the same
 headings, reflect salient features of those in each group.  The words of
 caution and  caveats  delineated in the introductory overview of this report
 may be appropriate to assessement of some of these examples.

 Satisfied/No Complaint

     Fifteen (5%) of the transporter cost comments were appropriate to
 this category,  two from automotive maintenance and 13 from dry cleaning
 firms.   That this is a meager portion of the total is probably in large
measure an indication of the disinclination of those content to comment;
substance Is added to this in the foregoing, where the tabulation of
assessement of  prices shows 198 (59%) of the automotive maintenance and
 140 (22%) of the dry cleaning firms reporting transporter prices as
reasonable.

     0  Prices are reasonable, being only one firm is operating in my
       geographical area.  (MI/DC-U-YNNN-M1019)

     0  Currently using [Transporter X]; no problems with service. ...
       (PA/DC-S-YNYX-M922)
                                  111-4

-------
     0 Out here in West Texas we are lucky to have anyone picking it up.
       I'm just happy to see them every month.  (TX/DC-L-YNNX-M960)

     0 It is difficult to properly evaluate the hauler's prices as we are
       not really aware of all the problems involved in proper disposal
       of the waste.  (FL/DC-S-YNYN-M148)

     0 Nothing to compare to, but company is good.  (MD/DC-S-YNYY-M672)

     0 They have increased considerably this year but seem to be in line
       with others in area.  (ME/DC-S-YYNX-M799)

     0 [Re 5] Yes, considering what they have to do.  (PA/AM-S-YNYY-M429)

     0 No problems. . . .(KY/DC-U-YNYY-M836)

     0 Everyone needs to show a profit for any enterprise. . . .  (IA/DC-U-
       YNYY-M839)

No Competition/Monopoly

     Eighty-three (26%) of the cost related comments were in this category,
9 from automotive maintenance and 74 from dry cleaning firms.  As shown
in Tables III-l and III-2, 156 (47%) of the automotive maintenance firms
and 504 (79%) of the dry cleaners reported that they were unable to select
their transporter from competing firms.

     0 Talk about raising prices and a monopoly - WOW!. . .They got you
       by the nose.  (FL/DC-U-YNYN-M346)

     0 They are like the modern-day Mafia.  They come into my shop, pick
       up waste, and charge an extremely high price.  Since I do not have
       another option of another hauler in Maryland, I have to pay this
       high price.  (MD/DC-U-YNYN-M82)

     0 No competition.  Free to charge whatever. . . .BLACKMAIL. ...
       (IL/DCU-YNYN-M258)

     0 We feel very trapped in this situation.  We have no choice but to
       pay the hauler's price as there are no others to choose from.
       (FL/DC-U-YNNN-M133)

     0 There is an ugent need for competition among haulers.  Lack of
       competition in this matter has encouraged the only present hauler
       to take advantage of the situation.  (MD/DC-S-YNNN-M885)

     0 There is no competition in this area for waste pickup.  We have to
       trade with one company and they are very independent.   (MD/DC-S-
       YNNN-M859)
                                  III-5

-------
      0  When  there  is  only  one  firm supplying a service.  . .then our
        prices  will  never be  competitive.  This creates an even bigger
        problem.  .  .since some  dry cleaners may dispose of waste in an
        illegal manner.  (SC/DC-U-YNYN-M229)

      0  No other  companies  to choose from.  Prices are very unreasonable.
        (TX/DC-U-YNNN-M72 5)

      0  They  got  us  over a  barrel. . .  .   (PA/DC-U-YNYN-M710)

      0  A lack  of competing firms causes higher hauling rates.  (OR/AM-U-
        YNYN-M447)

      0  Our hazardous  waste hauler has  a "take-it-or-leave-it" attitude
        since they are the  only source  available to us.   (MI/DC-U-YNNN-
        M749)

      0  A monopoly.  .  .We are being ripped off.  (CO/DC-U-YNYN-M749)

      0  The worst thing is  the  noncompetitiveness.  There is only one show
        in town - so you have no choice but to use them.  (WI/DC-S-YNNN-M3)

      0  We need a choice! We  have none.  (MS/DC-0-YNYN-M1033)

      0  My problem (and I'm not the only one!) is that only one company
        picks up  the waste here.  I understand that it's  costly for them
        to do it, but  they're so arrogant, and literally  have a monopoly
        going here!  Is it  right?  (TX/DC-U-YNYN-1014)

      0  What  competing firms?   This is Mafia!. . .You have got to be
        kidding.  NO COMPETITION.  (FL/DC-U-YNYN-M1016)

      0  Present set up has only given [Transporter X] a license to steal.
        They have no competing  firms and can therefore charge as they
        wish.   We pay  for lack  of choice or other option.  (X/DC-U-YNYN-
       M202)

Monthly Charge Unjustified

     This issue was protested  in 51 (16%) of the cost related comments,
one from an automotive maintenance firm and 50 from dry  cleaners.

     0 We have a very small  plant.  We only need [Transporter X] to pick
       up our  filters every  six weeks.  They come once a month whether we
       need them to stop or  not.  For  this we are charged $40 each visit
        . .  . .Their man comes to the door - says "hi," asks if we need
       pickup.   We say no.    He leaves and sends a bill for $40.  I feel
       like we are being robbed.  If I protest, they could refuse to
       service us at all and then we would be in trouble with EPA.  Our
       government has created a monster.  It's like paying protection
       money.  It's NOT FAIR.  (WI/DC-U-YNYN-M657)
                                  III-6

-------
     0 We have to pay $40 per month per store whether we have waste or
       not!  We had to quit cleaning at one plant, hauling all clothing
       to our other plant to cut our cost on hazardous waste hauling.
       NOW to resign up with our hauler, for the store we dropped, we
       must pay a $200 charge!  (TX/DC-U-YNNN-M748)

     0 For a small business it's a big rip-off, because every time they
       drive up in our driveway and walk in the door it's $40 whether
       they pick up anything or not.  Their prices are outrageous; they
       have no competitors and can charge whatever they want.  PLEASE
       HELP US PUT THIS UNDER CONTROL!!!!!  (TX/DC-U-YNYN-M743)

     0 $40 per month, actually $100 per month, or about original of
       filters for pickup. . . .1 am unhappy with the government for this
       situation.  (MD/DC-U-YNYN-T1003)

     0 Most of my operation generates waste on a five or six week schedule.
       My hauler comes every four weeks and charges me a $40 fee whether
       I have waste or not.  (MN/DC-S-YNYN-M770)

     0 This company has a dictatorial attitude, with fee per month whether
       waste is picked up or not.  Some other arrangements must be made
       for the very small generators.  (NY/DC-U-YNNN-M863)

     0 They come monthly and charge a minimum fee.  I do not have waste
       for them to take each month.  If they don't come monthly, they
       double the fee.  (NY/DC-U-YYYN-M114)

     0 Every time the hauler stops he charges us $40.  We haven't sent
       any waste for six weeks but we still must pay.  They know we send
       every two months.  (WI/DC-U-YNYN-M802)

     0 Must be picked up every four weeks.  We do not generate enough
       waste to fill their containers.  We must pay for full pickup when
       a six-week or eight-week pickup would be adequate for our needs.
       (NY/DC-YNYN-M935)

     0 I generate waste approximately every quarter.  My hauler stops
       every month and charges a minimum fee.  (GA/DC-0-YNYN-M894)

     0 They charge a monthly $40 even if I don't have any waste to remove.
       I don't think this is fair.  I've raised my prices just because  of
       the waste removal and my customers are complaining.  I'm a very
       small cleaner and these new laws are going to put us out of business.
       If it weren't for the small business in this country, this country
       wouldn't exist.  (OH/DC-U-YNYN-M196)

Coercive Product Marketing

     Twenty of the cost related comments, all from dry cleaners,  objected
to increasing coercive product marketing practices of hazardous waste
transporters.  Some of these complaints contained allegations  that  the
                                  III-7

-------
monopolistic character of pickup service was being exploited  as  leverage
to pressure generators into purchase of their products.   The  following
comments exemplify these objections.

     0 The company who picks up our waste alsc  is putting pressure  on us
       to buy perc and cartridges from them.  We did  not, so  they went  up
       on their price.  (VA/DC-U-YNNN-M88)

     0 Now they are trying to sell back the reclaimed solvent and giving
       discounts to cleaners who do.  It looks like they will soon  be
       selling all types of supplies,. • .using hazardous waste  pickup  as
       leverage.  (MD/DC-S-YNYN-M347)

     0 Pressure is sometimes applied from the hauler  to  purchase products
       from them, such as filters, reclaimed perc, and detergents.   Some
       of the products are of a very low grade and not compatible in my
       business so I cannot purchase them.  (KY/DC-U-YNYN-M186)

     0 Pickup service pressures clients to purchase supplies  from the
       service, offering discounts on disposal charges.   I tend  to  blame
       the government for this non-competitive environment.   (MD/DC-U-
       YNYN-T979)

     0 [Transporter X] is insistent on purchase of materials  from
       transporter;  materials are not of best quality.  (NY/DC-U-YNYN-
       T956)

     0 Company started off as hauler.  Now is competing  with  product
       companies.  When you buy their products, you get  discounted  or
       cheaper rates for hauling residue.  I think this  is unfair.   (IN/DC-
       YNYN-M883)

     0 If we do not purchase the filter cartridges and solvent from the
       hauler, then the price for pickups are way higher.  In other words,
       we are at the mercy of this hauler only.  (TX/DC-U-YNYN-M880)

     0 The hauler also requires me to purchase perchloroethylene from him
       at a much higher price than what I could purchase.  (GA/DC-S-YNYN-
       M200)

     0 They will lower prices if you buy cartridges and  perc  from them.
       I  tried both and found that they were selling  below-standard
       products.  A monopoly if ever I saw one.  (GA/DC-U-YNNN-M741)

     0 They insisted on [my] buying their "recycled"  products and other
       filters or else they would not pick up the hazardous waste.   (NY/DC-
       U-YNNN-M1053)

     0  [Transporter X] has developed their own filters which  they  sell at
       a  reasonable market rate and give a discount of $3.00  for each
       cartridge when they are disposed and hauled away.  I refuse  to use
                                  III-8

-------
       their cartridges because they are not near the quality, in my
       estimation, as the [Product Y] filters, [Transporter X's] filters
       completely fell apart and collapsed in the filter housing.  I feel
       very fortunate that I did not pay out a lot of customer claims for
       ruined garments from that filter system.  A proper filter system
       is a must for a quality dry cleaner, and our customers expect
       quality.  (IA/DC-S-YNYN-M762)

     0 A serious conflict of interest exists since the hauler recently
       established a product line for sale to our industry.  If we buy
       their chemicals and filters we can receive discounts on waste
       disposal.  Their route men receive commissions on sales and
       consequently provide better service to those customers who buy
       their products.  (VA/DC-S-YNNN-M1060)

High/Unreasonable Prices

     As shown in Tables III-l and III-2, 568 (59%) of the 970 respondents
with pickup arrangements judged transporter prices to be unreasonable,
37 percent of the automotive maintenance firms and 70 percent of the dry
cleaners.  This judgement is apparent again in the cost related comments,
where complaints of high and/or unreasonable prices are the most numerous,
accounting for 120 (38%) of the total.  Distributed between the two indus-
trial groups, 25 (21%) of the protests were from auto maintenance and 95
(79%) from dry cleaning firms.  Here, again, the problem is attributed
primarily to the prevalence of transporter monopoly.  Frequently mentioned
among these complaints was continual escalation of transporter prices,
e.g., "prices have doubled in two years," "three price increases in the
past year," "costs have increased 30 times as compared to prior to use of
this service."  Among the comments were reports that these rising cost
burdens are increasingly motivating generators to illegal dumping.

     0 $100 member's fee (required), $15 three boxes at $5 each (required),
       $11 per cartridge.  Each cartridge will average 11 pounds, 9 pounds
       new:  11-9-2 pounds of dirt, oil, grease, etc., etc.  We cook and
       strip perc from same.  Two pounds at $5.50 per pound for dirt-oil-
       grease to be hauled away per cartridge.  (TN/DC-U-YNYN-M714)

     0 [Transporter X] is the only hauler that I know of in our area.
       Their prices to get our filters hauled off are as much or more
       than new filters cost.  With few locations, our monthly cost is in
       excess of $500.  Small operators like myself need some relief.
       (TX/DC-U-YNYN-M981)

     0 They are very bad, very expensive, very independent.  Don't like
       this, but have to have it hauled off because I want to do right by
       the law.  Bad situation.  [Re 5] Absolutely not - very unreasonable.
       (TX/DOU-YNNN-M164)

     0 These costs are astronomical for us and it is very difficult  to
       pass them on to our customers.  (AZ/DC-U-YNYN-M909)
                                  III-9

-------
0 Has added an additional expense of $2,000 to $2,500 to my small
  business.  Will force many small businesses out.  (IL/DC-S-YNXY-
  M915)

0 Prices started good; keeps raising costs.  (TX/DC-S-YNYN-M905)

0 I wrote out a check in full to [Transporter X] representative for
  $295 to remove my paint thinner two times a year.  They never
  came, even after numerous phone calls.  (NJ/AM-U-YNNN-M10)

0 Price for small generator like myself is unreasonably high compared
  to what large generators pay.  I paid $40 each for a small 15 gal-
  lon drum in 1986, and in 1987 have to pay $90 each for the same
  size container for perc residue.  This may not be much money, but
  for a real small business every dollar paid out hurts.  (OH/DC-0-
  YNNN-M822)

0 The cost is prohibitive and just about to put me out of business.
  (KS/DC-U-YYNN-M261)

0 I hope you will see how the dry cleaner is being held up!  (IA/DC-
  YNNN-M253)

0 Between hazardous waste and right-to-know I'd guess we will spend
  easily $15,000 in one year.  (OR/AM-S-YNYY-M34)

0 Some smaller cleaners with the depressed economy may have to resort
  to other means of disposing of their waste if something isn't done
  about the ever increasing costs, and this will snowball into
  increased costs to the government by having to regulate and monitor
  the proper disposal of these wastes.  (TX/DC-S-YNYN-M211)

0 Cost is extremely high.  Gives initiative to simply dump waste.
  (MI/AM-U-YYNN-M4 9)

0 Waste disposal has increased our operating expenses 3 percent
  ($2,000) annually.  The basic costs to this firm are:  $5/waste
  container for each 15 gallons of still residue or 4 cartridges,
  and $35/15 gallons of residue and $1 I/cartridge.  While we are
  concerned with the dry cleaning effects on our environment and
  follow all directions, how can we compete with the cleaners not
  doing so?  They can put the $2,000 in their pockets.  (CO/DC-U-
  YYYY-M203)

0 It costs well over $200 to haul one 55-gallon drum!   (OR/AM-U-YNYN-
  M61)

0 HAULER'S PRICES KEEP GOING UP.  They have been given  a license to
  steal.   (KS/DC-S-YNYN-M690)
                             111-10

-------
     o
       Pick up situation here is out of control.  [Transporter X] has law
       on their side, has a monopoly, is charging exorbitant prices, and
       is using coercive tactics.  Two of the largest cleaners here have
       recently dumped them; what they are doing with waste, I don't
       know.  Disposal must be on a practical basis or dumping/lawbreaking
       will become rampant.  They want $40 per month with or without
       pickup need, plus $5 to $6 for new drum each trip.  Will reduce
       pickup price by $3 and waive drum charge if we buy their products.
       Products are inferior to  [Product X], which we have been using.
       EPA should call moratorium on law NOW till solution is provided.
       (NC/DC-S-YNYN-T216)

     0 This company won't pay for disposal.  (OH/AM-U-YYNN-M464)

     0 The price has gone from $25 per drum for pickup to a cost now of
       $75 per drum plus an additional charge for still oil of $2 per
       gallon.  My costs have gone from $25 total pickup to $125 for the
       same amount.  If costs continue at this rate, all that will happen
       is the encouragement to have more illegal dumping.  (CA/DC-U-YNYN-
       M792)

     0 Bids received so far are  unreasonable.  (PA/AM-S-NXXX-M70)

     0 $110 sign-up fee, $5 per  15-gallon Drum (I must buy the drum for
       $5 to give them to haul away), $40 per month for 0 to 1 drum (I pay
       $40 if I don't have any waste), $45 for each drum thereafter.  My
       only waste is split filter.  (AZ/DC-U-YNYN-M1081)

Equitable Pricing Uncertainty

     Responding to the question  of whether or not transporter's prices
were reasonable, 30 (92) of the  respondents with pickup arrangements
indicated that they did not know.  Nine of these were from automotive
maintenance firms and 21 from dry cleaners.  Many simply placed a question
mark beside the query, others asked what is reasonable, and a few stated
that their local trade associations had arranged for their pickup service.
However, most of this group indicated that, in the absence of competition,
there was no alternative to which they could compare prices:  i.e.,
"Nothing to compare" and "With only one hauler, how would you know."
                                  III-ll

-------
                                    IV

                       TRANSPORTER SERVICE RENDERED
     The questionnaire solicited response to the question of whether or
not haulers' pickups were consistently reliable, i.e., as scheduled.
Table IV-1 presents a tabulation of the response, separately and combined,
from those automotive maintenance and dry cleaning firms reporting
arrangements with transporters.  The response is distributed between the
Federal regions.  As can be seen, percentage distribution of response
from the two industries was comparatively very similar:  73 versus 76
percent reported yes and 25 percent versus 21 percent reported no.

     These similarities may be misleading, due to significant differences
between the two groups in the types of waste and the circumstances
surrounding the pickup services rendered.  First, as mentioned before,
there are many different kinds of automotive maintenance wastes, with
different types of waste collection firms serving this need; additionally,
many of these generators stated that used motor oil was their only waste.
On the other hand, dry cleaners' wastes are usually limited to used
filters and still bottom residue, which are generally collected by
transporters specializing in serving that need.  Furthermore, automotive
maintenance wastes are generally collected sporadically, whereas waste
collection service available to dry cleaners is apparently dominated by a
rigid policy of monthly pickups.  The reliability of scheduled pickups in
the latter case appears to be strongly motivated by the fact that charges
are levied for each monthly transporter visit, whether or not waste is
present and collected.  Consequently, as shown above in Section III, the
service provided to dry cleaners is regarded by many of them as redundant,
too reliable.

     The solicitation of information concerning transporter pickup
reliability was apparently a stimulus precipitating numerous comments
related to other aspects of transporter services rendered.  The total of
service related comments contributed was 67, representing seven percent
of the respondents reporting pickup arrangements, 18 of them from automotive
maintenance and 49 from dry cleaning firms.  These comments may be
categorized into three groups:  8 as favorable to transporters, 14 as
neutral, and 45 as negative.  Seven of the favorable comments and 38 of
the unfavorable were from dry cleaners.  Here again, the stronger
inclination of the discontented than the contented to comment appears to
be manifested.

     0 [Transporter X] is very professional and precise in their work.
       (CA/DC-S-YYYY-M896)

     0 Hauler's service is very satisfactory from our standpoint.  (VA/DC-
       S-YNYY-M676)

     0 Currently using [Transporter X]; no problems with service.  (PA/DC-
       S-YNYX-M922)
                                   IV-1

-------





o
u
01 X
CO 4-1
C i-l
a l-l
CO J3
5 CO
OS 1-4,
r-l
co ai
1-4 3
CJ
ffa
•H
0) 0)
CJ CO
& S c
O 0 0
•O M
C - CO
CO 03 Pd
01 0) iH
O 4-1 CO
CUP
c a. -o
OJ CO OJ
B § **
•H l-i >»
cc H .O
V O 0)
> 4->
•H C 3
•U O -fi
O -H i-l
O CO 4J
3 3 ^5
^^ ^^ f^
• •
»-4
1
1— (
V
ft
C8
(_i
^ Clean.
Blank
a
*c o
(U .
C 4-1
fl -H
B CO
O 2 co
u -<
•H
Autorao
Total
C
CO
•H O
§z
OJ
0
^ CO
M 0)
Q >«
i-H
W
O
H
CO
OJ .H
U CO
Ma intern
L No J
:omotive
Yes
3
CO
0
H
C
O
•H
00
0«-*«--~-.--
22SSS3-»S"'-
^^ ^^ 00 ^^ *^ ^5 ^J C^ ^™ ^ ^^ ^^
00 ^^ ^5 ^^ ^^ ^^ *^ ^^ C? ^^ ^H
OC,OC,.O-CM.C.O
00 "*^ ^O '"^ *"3" ^H iO **tf 00 *^" C*J
-H -^ CN CM f)
S^2S|52JMS-S
----2-S°g--
00----OOC.O-
f-H »4 — <
»H CM ^M •* «O ID -H
-£££££"—£::<*
M T3
M l-l l-l 01
LJ LJ ^^ LJ ^j ^j s*J 4.
ccccccccecc
ooooooooooi-:
- "
-H CM
CM
S 1C
g §
CM
cn CM
» s
VO -H
- -
OO CM
CN
f> O
?n --
c
iH 4)
CO O
U Wi
O 0)
IV-2

-------
 0  [Transporter X] does a fine job.  Customer service is prompt and
   courteous.  Mr. [Y], who picks up and services our plant is a very
   fine young man.  (IL/DC-YNYY-M233)

 0  Waste hauling conditions are bad now and getting worse!  (PA/AM-U-
   YNNN-M67)

 0  Carrier will attempt to haul off all waste (including those not
   classified as hazardous - cartridges from petroleum machines) and
   charge me for them.  This is in my mind a misrepresentation of the
   law.  (TX/DC-U-YNYN-M784)

 0  They charge for drums, but drums they bring are always rusted or
   crunched.  They are not safe for containing hazardous waste, in
   our point of view.  (MD/DC-U-YNYN-M237)

 0  Dirty cans. Lids don't fit.  Lock rings missing.  (IL/DC-U-YNNN-
   M996)

 0  We find that the [Transporter X's] manifested weights and actual
   weights differ greatly.  We presently utilize the [Product X] unit
   to stip our cartridges and in no way does the actual weight compare
   to the [Transporter X's] "standard" weight.  This inaccuracy shows
   that I am producing more waste than I really am.  (PA/DC-U-YNNN-
  M345)

 0 They are currently using a cardboard box with a liner to pick up
   used cartridges.  The county health and hazardous waste department
   isn't very pleased about this.  (MO/DC-S-YNYN-M335)

 0 Containers are delivered bearing waste from previous use, ill-
  fitted lids, and without labels.  Confirmation of arrival at
  destination is sometimes not returned.  (VA/DC-0-YNNN-M893)

 0 My hauler's pickup schedule is as reliable as the weatherman's
  forecast.  (SC/DC-S-YNNN-M568)

 0  [They] say they can only pick up two containers a month.  We
  changed filters three months ago.  We are actually storing hazardous
  waste because they can't pick it all up at one time.  (TX/DC-U-
  YNNN-M164)

0 Storage containers are made of cardboard.  [Transporter X] first
  suggested I store the cartridges (spent) in our boiler room next
  to our gas burners.  The representative was completely unaware of
  any natural gas/perc interaction problems.  Then he suggested I
  keep the cartridges in my finishing room where the cartridges
  would be near my employees.  [Transporter X] is the largest waste
  disposal agency in the nation.  They have not educated their
  representatives well enough.  (VA/DC-S-YNYN-M925)
                              IV-3

-------
                          COMPLIANCE/ENFORCEMENT

     A total of 54 comments contained expressions of compliance or
enforcement concerns.  They were nearly equally divided between automotive
maintenance and dry cleaning firms.  Confusion regarding what is and what
is not hazardous waste accounted for many comments from automotive main-
tenance respondents.  Some problems with obtaining EPA identification
numbers were reported.  Generators' concerns over liability coverage,
absence of compliance enforcement, and lack of confidence in transporters'
proper disposal of wastes were the subject of most of the balance of
these comments, being expressed by both industry groups.  The following
are typical of this comment category.

     0 Total confusion by everyone as to what constitutes hazardous waste.
       (NY/AM-S-YNNN-M4 3)

     0 We need more direction as to what is legal and what to do with new
       hazardous materials on list.  (MD/AM-S-YNYX-M20)

     0 It would be nice to have a set of rules and regulations in manual
       form for all car dealers.  (FL/AM-L-YYYY-M31)

     0 Cannot get consistent answers on what wastes I generate are
       hazardous.  (TX/AM-U-YNNN-M656)

     0 I have not received an EPA ID number though I applied over nine
       months ago.  (TX/DC-YNYN-M784)

     0 My difficulty has been in getting my EPA identification number
       changed to a proper Arizona number.  I have contacted EPA numerous
       times with no luck.  (AZ/DC-U-YNYY-M806)

     0 This problem of waste disposal and liability has become very
       difficult.  (ND/AM-S-YNNN-M41)

     0 The question of eternal liability is heavy on our minds.  (TX/DC-U-
       YNNN-M689)
     o
       Lack of enforcement.  I'm complying the best I know how, but other
       cleaners are doing absolutely nothing at all and getting away with
       it.  (WI/DC-S-YNNN-M3)

       I see cleaners throwing in garbage pails instead of having proper
       pickups.  I called EPA and local health department to show the
       filters left outside back doors for months and no one ever comes
       or does anything about violators.  Violators should be written
       about in local papers and driven out of business!!  (NY/DC-0-YYYY-
       M95)
                                   V-l

-------
0 Have little confidence that disposal procedures are being properly
  followed.  (MI/AM-S-YNNN-M18)

0 No way of verifying handling of wastes.  Pay companies to properly
  dispose of waste and then they take them to the regular dumps.
  (CA/DC-S-YNYN-M891)

0 How do I determine if these hauling companies are disposing of
  their materials as they tell me they are?  (SC/AM-S-YNNN-M79)
                              V-2

-------
                                    VI
                               REGULATIONS
     Eighty-three of the comments contained complaints or suggestions for
improvement concerning environmental regulations.  Automotive maintenance
firms contributed 17 of these and dry cleaners 66.  Half of the dry
cleaners' comments were directed to two regulatory issues:  (1) exclusion
of steam-stripped cartridge filters containing traces of perchloroethylene
from regulation as hazardous waste, thus permitted land disposal (24 com-
ments); and (2) the possibility of classification change of perchloroethylene
from "possible" to "probable" carcinogen (9 comments).  Sixteen respondents
complained about regulatory language, forms, and/or paperwork, these
protests being equally divided between the two industries.  Seven automotive
maintenance complaints expressed confusion or irritation stemming from
the complex of Federal versus state and local regulations.  A few placed
blame on govenment regulators for their difficulties with waste transporter
and disposal firms, suggesting more stringent regulation of these firms.
The following are examples of this group of comments.

     0 I have spent $1,000 on a cooker that brings the cleaning fluid -
       "perc" - down to less than 2% surrounded by the filter's bed of
       clay and carbon which makes it NOT a danger to the environment.
       Some states say it is fine for normal trash disposal and some
       states say it is not.  Laboratory tests say the cooked filters are
       not a danger and the law should allow cooked filters to be disposed
       of with normal trash.  (CO/DC-U-YNYN-M323)

     0 What I strongly object to is the charge for hauling away used filter
       cartridges.  We own a Puritan 4000 SRS recovery system used only
       for the recovery of solvent from used filter cartridges.  We get
       an average of 30 gallons of solvent out of these 21 cartridges, and
       I feel that the Perc content is well below any reasonbale allowance
       set by EPA.  I feel we should be allowed to throw them away as
       junk (metal and paper) instead of paying $11.00 each to have them
       hauled away.  This charge has doubled my cost of filtration in the
       last 3 years. . . .The EPA should randomly select companies and
       check to ensure proper limits are being adhered to as far as the
       maximum allowable residue left in the cartridge. . . .1 believe
       stripping cartridges properly is a logical step in helping to keep
       the costs of hazardous waste disposal under control without damaging
       the environment.  (IA/DC-S-YNYN-M762)

     0 I would buy a purging unit, reducing solvent content in filters to
       less than one percent, if less than one percent would be considered
       non-hazardous, as it is in three other states.  As the present law
       stands, there is no incentive to purchase this equipment.  My
       business expenditure on hazardous waste disposal for year to date
       (10 months) is $1,266.84.  (CO/DC-U-YNYN-M1006)
                                   VI-1

-------
 0 Please push for disposal of purged filters as non-hazardous waste.
  (CA/DC-S-YNXN-M902)

 0 [Transporter X] will probably pull out of Washington state if
  Puritan-type cartridge strippers are OKed for land fill.  (WA/DC-U-
  YXYY-M967)

 0 REGULATION - TOO MUCH/TOO FAST.  Give our industry time to develop
  the technology to deal with this problem.  (KS/DC-S-YNYN-M690)

 0 We have heard that the EPA Administrator may change the classification
  of our dry cleaning solvent (perchloroethylene) from a "C" to "B"
  even though the Science Advisory Board of the EPA found that the
  evidence presented by the Cancer Assessment Group did not warrant a
  change in classification.  If the classification was changed, that
  would be a real problem.  Then the survey would be meaningless,
  because dry cleaners could not meet the new standards of disposal.
  (UT/DC-U-YNYX-M8 2 4)

 0 Our legislators may put us out of business with their idea of perc
  classification.  Then we can all wear disposable garments.  (MI/DC-
  U-YNYX-M824)

 0 Possibility of perc classification from "possible" to "probable"
  carcinogen would cause serious problems and lead to the closing of
  our business of dry cleaning.  (ME/DC-S-YYNX-M799)

 0 If EPA changes the class of perc from "possible" carcinogen to
  "probable" carcinogen the resulting regulations will probably get
  so unreasonable that most dry cleaners will not be able to operate.
  (TN/DC-S-YYY-M2 39)

 0 First the Federal EPA, then the state EPA, then the county, now the
  damn city.  None of whom are helpful.  (CA/AM-S-YNNY-M613)

 0 Everyone has different regulations:  city, county, state, federal.
  (CA/AM-U-YYYY-M1045)

0 Regulations very complicated and difficult for small business to
  unde rstand.  (KY/DC-U-YNYN-M9 91)

0 I am an American.  Quit speaking kilograms; speak pounds and
  ounces.  (IN/DC-U-YNYN-M886)

0 Need to get regulations in English that can be understood.  (WA/AM-
  U-YNNN-M372)

0 Paperwork for manifesting, labeling, and record keeping is confusing
  ana complicated.  (OH/DC-U-YYYN-M4)

0 Too much paper work and file keeping for requirements of EPA.
  Ridiculous.  (FL/AM-U-YNYN-M46)

                              VI-2

-------
0 Too many regulations producing too much paper work taking too much
  unnecessary time.  (MD/AM-S-YYYN-M80)

0 Your forms are written as only a government person can understand
  them.  We speak English, not governmenteeze.  (NY/DC-U-YNYN-M127)

0 Make the laws simple and everyone will comply with them.   (TX/AM-U-
  YYNY-M362)

0 They got us over a barrel.   With no competition in a situation
  which we must obey, the government should regulate prices, or
  allow us to use stripping machines to do a lot of the work ourselves.
  (PA/DC-U-YNYN-M710)

0 Tend to blame government for this non-competitive environment.
  (MD/DC-U-YNYN-T979)

0 $40 per month, actually $100 per month, or about original of
  filters for pickup.  Am pressured to purchase from pickup.
  Am unhappy with government for this situation.  (MD/DC-U-YNYN-
  T1003)

0 Since the majority of us have only one choice for hauling waste, I
  feel that these people should be regulated - similar to phone and
  utility companies.  (CO/DC-S-YNNN-M665)

0 Outrageous rules and regulations for the small businessman. ...
  These are totally unreasonable and impossible to follow.   I am
  begging you, please STOP!  I feel like I am in Russia.  1 am afraid
  to give you my name.  I never felt like this before.  I guess Big
  Brother is watching us. . . .Anonymous.  (NY/DC-U-YNNN-M120)
                              VI-3

-------
                                   VII
                          SUMMARY AND ASSESSMENT
     The data  collected and reported here indicate prevalence of hazardous
 waste pickup problems among automotive maintenance and dry cleaning firms,
 problems that  are seriously threatening now and that are potentially criti-
 cal  to  the achievement of future environmental protection objectives.  The
 Agency  regulations  relevant to issues addressed in this investigation were
 promulgated to achieve environmental protection through placement of prac-
 tical,  achievable requirements upon individuals and/or entities involved
 in specific hazardous waste disposal streams.  The data reported here indi-
 cate the evolvement of a situation which raises questions regarding the
 achievability  of such objectives through compliance with these regulations.
 Unfortunately, many of the factors contributing to this situation were
 nonexistant and unforeseeable at the time of compilation and promulgation
 of the  regulations.  This, however, does not absolve the Agency from the
 obligation to  thoroughly examine the realities of the current situation
 to determine the remedial options available and take whatever action is
 necessary and  appropriate.  The following cursory review and assessment
 of the  data collected should provide sufficiently persuasive evidence to
 establish a commitment to this obligation.

 Transporter Availability

     Not surprisingly, the response contained complaints that hazardous
 waste pickup service is simply unavailable in some isolated, rural, and
 small town areas.  Respondents reporting unavailability were not numerous,
 possibly because generators in these areas are aware of and concerned
 about their noncompliance.  Apparently pickup service is not available
 to these generators because providing it is not deemed profitable by
 transporters.  Where unprofitable, it is probably deemed prohibitively
 costly  by the  generator to provide his own transportation.

     The solutions that respondents offered to unavailability included
 suggestions that:  (1) the permitted on-site storage regulations, with
 respect to weight and/or time limits, be extended, thereby limiting
 frequency of required pickups and enhancing pickup profitability; (2)
generators organize transporter service cooperatives to reduce hauling
costs to acceptable levels; (3) compliance be waived until development of
 technologically and economically practical means for reduction or elimin-
ation of the hazardous nature of the waste; (4) hauling firms be required,
as a condition of their transporter permit, to serve these areas; (5) the
criteria for definition of hazardous be revised downward; and (6) the
regulatory agencies accept an obligation to provide or subsidize pickup
service.

     The response clearly revealed another frame of reference regarding
 transporter availability:  nonutilization.  The data indicate that
                                  VII-1

-------
 instances  of  failure  to utilize available transporter service fall into
 three major categories:  (1) the service is deemed unreasonably and
 prohibitively priced;  (2) especially among dry cleaners, the service is
 deemed  unnecessary because of the small volume of hazardous material
 discarded  as  waste; and (3) especially among automotive maintenance firms,
 confusion  and uncertainty regarding what wastes are regulated as hazardous.
 Implicit in the comments are two other factors probably contributing to
 nonutilization:  a perception of weak or absent compliance enforcement
 and a suspicion that  transporters are not following proper disposal prac-
 tices.  Additionally,  protest was received from a few individuals who
 reject  the governmental decision placing the burden of responsibility for
 disposal of hazardous  waste on generators rather than manufacturers.

     The various aspects of alleged unreasonable and prohibitive transporter
 prices  are discussed  below under Transporter Cost.  Many respondents feel
 strongly that immediate government action is obligatory and essential to
 obtain  relief from what is regarded as a critical cost versus compliance
 situation.  Some report failure to arrange for utilization of pickup serv-
 ice because of high prices; others report and some threaten termination
 of pickup  service because of escalating prices.

        Among  those dry cleaners who feel that pickup service is not
 necessary, many identify themselves as Conditionally Exempt Generators
 producing  under 100 kilograms of hazardous waste per month.  Some claim
 exemption  because they consider their waste not hazardous, e.g., those
 using petroleum solvents.  Many others state that they are, or should be,
 exempt  from pickup requirements because their purging applied to filters
 reduces perchloroethylene waste to insignificant levels.  The latter exemp-
 tion is discussed below under regulations.  These dry cleaners protest
 that transporters refuse to acknowledge any of these exemptions.  Trans-
 porters apparently feel, with some measure of justification, that it is
 neither logistically  nor economically practical to distinguish between
 exempt  and unexempted  hazardous waste.  Still a question which surfaced
 through respondent comments asks whether transporters are deliberately
 applying misleading marketing of their services where they are not required.
 Clearly clarification  and reconciliation action is needed here.

     With  respect to  confusion and uncertainty regarding what is and what
 is not hazardous waste, as well as what regulations apply to specific
 hazardous waste, additional outreach is obviously needed, especially among
 automotive maintenance firms.  The distinctions between and substance of
Federal, state, and local regulatory requirements (as well as EPA, DOT,
 and OSHA requirements) need to be precisely and understandably presented
 to small business owners and operators.  Esoteric legal and technical
 jargon may be appropriate to the Federal Register and Code of Federal
Regulations,  but it is inappropriate and uncommunicative to small business.
Fortunately,  Agency recognition of this inadequate communication is emerg-
 ing; it is reflected  in the laymen's language of  the recent handbook and
 industry-specific educational outreach material directed to small business
 to explain provisions  of the Small Quantity Generator regulations.  The
 response obtained through this investigation shows that more material
 patterned  after this  example is needed.  Obtaining voluntary compliance
 through effective educational outreach and assistance is preferable to,
 and less costly than,  monitoring and enforcement  action.

                                  VII-2

-------
      The  negative  effect  of  suspicion or awareness of regulatory
 nonenforcement  upon  utilization of pickup service is discussed below
 under the heading  Compliance/Enforcement.

 Transporter  Costs

      The inclusion  among the  respondents' comments of some expressions
 of  satisfaction with their pickup service encourages an attitude of
 optimism,  that  an  effective  pickup service acceptable to all parties
 involved  can exist.   However,  the overwhelming evidence from the data
 collected indicates  the presence of far more dissatisfaction than satis-
 faction,  and most  of this  discontent is associated with alleged trans-
 porter monopoly.   The Fair Trade Commission identifies three primary
 potentially  adverse  consequences associated with monopoly:  coercion,
 intimidation, and  boycott.   The most frequent and vividly expressed of
 respondents' complaints against available transporter service were of
 monopoly.  Allegations of  coercion, intimidation, and threatened boycott
 were  included among  these  complaints.  Nearly all of these complaints
 were  related to transporter  costs.  These costs appear to be the most
 severe and critical  of the pickup problems confronting automotive main-
 tenance and  dry cleaning  firms, especially the latter.  In the judgement
 of  37 percent of the automotive maintenance and 70 percent of the dry
 cleaning  respondents transporters' prices are unreasonable.

      Fair assessment of complaints and accusations lodged against trans-
 porters requires awareness of  related factors surrounding the provision
 of  pickup service  which are  beyond the influence or control of the trans-
 porters.  These factors have contributed to escalating costs, limited
 competition, and the characteristics of some of the services provided.
 The severely restricted availability and soaring rates of liability
 insurance.imposed  upon transporters of hazardous wastes have resulted in
 the withdrawal  of  many small hauling firms from the field and substantially
 increased the cost of doing  business among surviving firms.  The financial
 responsibility  burden and  increasingly stringent regulatory requirements
 placed upon  disposal facilities have resulted in the closing of many such
 sites, increased transporters  hauling and disposal costs, and contributed
 further to elimination of  small hauling firms.  Ready access to recycling
 facilities is essential to transporters collecting reclaimable solvents;
 limited access  to  such facilities for small independent haulers has led
 to their abandonment  of pickup service.  When transporters collect waste
 from many small generators,  it is logistically and economically impractical
 to separate  unmanifested material of exempt generators from manifested
 material of  nonexempt generators; furthermore, most disposal facilities
will not accept unmanifested hazardous wastes.  Finally, collection of
 small amounts of waste from  numerous scattered generators cannot be profit-
able unless  pickups  are scheduled on a regular periodic routine basis
along established  routes.

     Whatever the  precipitating factors may be, the elimination of
 competition and arrival of monopoly in many areas appears to be undeniable
and increasing.  The  complaints of monopoly and its adverse consequences
are most heavily concentrated  among dry cleaners, where they are not
                                  VI1-3

-------
 exclusively but generally directed against one pickup firm specializing
 in service to dry cleaners and operating nationwide.  An urgent need for
 a thorough investigation of these complaints is reflected in the vividly
 descriptive vocabulary of the comments received, e.g.:

      0 They got you by the nose,
      0 Modern-day Mafia,
      0 Blackmail,
      0 Trapped in this situation,
      0 They got us over a barrel,
      0 Being ripped off,
      0 License to steal, and
      0 Like paying protection money.

     One of the most extensively and intensively resented of transporter
 service and pricing policies is the regular monthly scheduled pickup
 service with accompanying fee whether waste is present for pickup or not.
 Although a routine of regular periodic pickups may be logistically and
 economically justified, monthly pickups do not appear to synchronize with
 the needs of most if not all dry cleaners.  The pertinent question is
 whether fulfillment of need or enhancement of transporter income determines
 the frequency of pickups and, further, would the current rigid policy
 persist in a competitive situation.

     The indications of coercion, boycott, and intimidation in the comments
 of respondents were primarily associated with transporters' aggressive
 tactics applied to marketing their own products, perchloroethylene and
 filters.  Some dry cleaners claimed these products were of below-standard
 quality with above standard prices.  Transporters reportedly offer reduced
 pickup prices to purchasers of their products, and there were reports of
 increased pickup prices when purchase was refused.  Additionally, there
 were allegations that the quality of transporter services rendered was
 lower for nonpurchasers than for purchasers.  There were also charges
 that transporters threatened termination of pickup service unless dry
 cleaners purchased their products.  A perception of intimidation was
 implicit in some respondents' expressions of fear that if they did not
 accept the transporters' services and prices as offered, they would be
 reported for noncompliance with regulations and subjected to government
 penalties.  An investigation to determine with certainty the validity of
 all these accusations, and whether or not they stem from monopoly, is
 clearly in order.

High/Unreasonable Prices

     The fact that 79 percent of the dry cleaners reported that, in their
judgement, transporters' prices were unreasonably high raises the question
 as to whether these prices reflect costs plus a fair  profit or monopolistic
 control of the market.  The preponderant conclusion among dry cleaning
 respondents was that monopoly is the answer.  Additionally, 21 percent  of
 the automotive maintenance firms judged transporters' prices as unreasonable;
however, attribution of price levels to monopoly was  not as extensive
 among this group.  Dry cleaners price complaints (in  addition to protesting
monthly charges with or without pickup) included:


                                  VI1-4

-------
      0  Unjustified  initiation  of  service  (enrollment) fees,
      0  Increased  prices  immediately  following consignation of pickup
        agreement,
      0  Multiple price  increases over short  periods of time,
      0  Unreasonably high prices for  waste-holding boxes and barrels,
      0  High  unit  prices  for  waste collected,
      0  Coercively high prices  for unscheduled special pickups, and
      0  Penalty charges for reinstatement  of terminated pickup service.

      The  frequency  of  reports  that unreasonably high pickup prices are
 resulting in failure to  initiate  service  and termination of service, as
 well  as increased illegal dumping, underline the serious threat these
 prices  pose  to regulatory compliance.  Rectifying initiatives are needed
 here  to interrupt what appears to be a trend toward rejection of compliance.

 Transporter  Services Rendered

      The  questionnaire asked of respondents only whether or not their
 transporters' service  was consistently reliable, as scheduled.  Approximately
 three-fourths of both  industrial  groups reported that it was.  However,
 many  of the  dry cleaners noted that  a rigid policy of monthly pickups
 (whether  needed or  not)  with an accompanying monthly fee was the motivation
 to reliability.

      Comments from  some  dry  cleaners indicated a prevalence of transporter
 personnel  unqualified  to handle hazardous waste, along with sloppy and
 irresponsible service  rendered.   The following commentor condemned person-
 nel qualifications.

      0  [Transporter X] suggested  I store  the cartridges (spent) in our
       boiler room  next  to our gas burner.  The representative was
       completely unaware of any  natural  gas/perc interaction problems.
       Then  he suggested I keep the  cartridges in my finishing room where
       the cartridges  would  be near  my employees.  [Transporter X] is the
       largest waste disposal  agency in the nation.  They have not educated
       their representatives well enough.

Complaints of sloppy and irresponsible service included:

      0 The drums they  bring  are always rusted or crunched, they are not
       safe  for containing hazardous waste;

      0 Dirty cans,  lids don't  fit, lock rings missing;

      0 Containers are  delivered bearing waste from previous use, ill-
       fitted lids, and without labels; and

      0 Storage containers are made of cardboard.

     These reports  suggest that development of transporter qualifications
and performance standards is needed, and  that transporter permitting be
contingent upon evidence that  such standards will be met.

                                   VII-5

-------
Compliance/Enforcement

     As perviously mentioned, the comments received reenforce conviction
that obtaining regulatory compliance among small business is in large
measure dependent upon provision of comprehensible education and guidance
material.  As stated before, such material will not communicate effectively
unless it is in laymen's language, devoid of highly technical and legal
jargon, and industry specific.  A collaborative rather than confrontational
approach must be employed to obtain widespread significant voluntary
compliance among the nation's millions of small businesses impacted by
environmental regulations.  These factors frequently surfaced in the
comments received.  They are so critical to achievement of environmental
objectives that they warrant emphasis through repetition to assure
consistent attention throughout the Agency.

     A perception of weak or absent regulatory enforcement of requirements
applicable to generation, transportation, and/or disposal of hazardous
waste can diminish respect for regulations and, consequently, compliance.
When those in compliance become aware of no enforcement being applied to
reported cases of noncompliance, their level of dedication to continuation
of compliance is not enhanced.  This is especially true when entities not
in compliance are thereby enjoying a competitive advantage over those in
compliance; it is evidenced in strong words in the comments of many
respondents.  The temptation to discontinue utilization of pickup service
because of perceived nonenforcement is explicitly and implicitly stated
in comments received.  Prompt attention to reported cases of noncompliance
is essential to avoid potential escalation of noncompliance.

Regulations

     The largest portion of the 83 comments directly related to regulations
(40%) was from dry cleaners concerned with (1) the possible reclassification
of perchloroethylene from "possible" to "probable" carcinogen and (2) the
exclusion of purged filters containing only traces of perchloroethylene
from regulation as a hazardous waste.  Both of these issues are currently
under EPA review, and the comments received will be made available to
those assessing the pros and cons of the issues.  Pertinent to the second
of the issues is a question not raised by any of the numerous advocates
of this exclusion but surfaced in the comments:  i.e., would the pickup
service now available to dry cleaners survive if its collections were
limited to still bottom waste and, if not, how would disposal of this
waste be accomplished.

     Many commentors criticised the abstruse language characteristic of
Agency regulations, and this matter is addressed herein above.  A number
of other commentors stressed the need for consolidated clarification of
the overlapping regulations emanating from Federal, state, and local
government; certainly more effort directed to this is warranted.

     The perplexity of the respondents in their efforts to cope with
compliance requirements is reflected in the remaining group of regulation-
related comments.  These placed blame upon government environmental
                                  VII-6

-------
 agencies  for  the  problems  surrounding small business compliance and also
 placed  responsibility  upon these agencies for providing solutions and
 relief.   The  comments  predominately revealed a desire to collaborate in
 achievement of environmental objectives.  However, there were strong
 expressions of need, sometimes demanding, that government examine and
 assess  the realities of what is perceived currently a "mission-impossible"
 situation and take  such action as will  assure compliance achievability
 without demise of their business.

     The  investigation reported here involved a collection of data
 revealing the consequences of specific  regulatory implementation efforts.
 It  was  accomplished through willing (even eager) collaboration provided
 by  the  EPA Office of Small Business Ombudsman, trade associations, trade
 journals, and small business firms impacted by the relevant regulations.
 The methodology employed,  results obtained, and economies realized in the
 investigation suggest  that it could serve well as a model for similar
 future  undertakings.   The  Agency is committed to such undertakings in its
 pledge  to review  regulations every five years to determine if revision is
 appropriate.  This  pledge  is delineated in the Agency's Guidelines for
 Implementation of the  Regulatory Flexibility Act, the purpose of which
 "is to  ensure that while achieving the  Agency's statuatory goals. .  .
 regulations do not  impose  unnecessary costs on small entities."*  The
 evidence  in this  report emphasizes the  urgency for fulfillment of this
 pledge  without delay with  respect to the Small Quantity Generator
 Regulations,  since it  is quite apparent that the economic impact analysis
 applied to development of  those regulations does not reflect the current
 compliance situation.
*"EPA Implementation of the Regulatory Flexibility Act":  Memorandum from
the EPA Administrator to Associate Administrators, Assistant Administrators,
Regional Administrators, and Office Directors; February  9,  1982.

                                  VII-7

-------
                                APPENDIX A


     The EPA Office of Small Business Ombudsman is  concerned  that  some
small business entities may be experiencing difficulty in complying  with
small quantity generator regulations with respect to availability  and/or
cost of hazardous waste pick-up services.  They would like to hear from
you (anonymously, if you wish) in regard to the following or  any other
related problem you are experiencing.  You may respond by calling  the
Small business Ombudsman's toll-free "Hotline," 800/368-5888  (in D.C.
557-1938), or writing to the Small Business Ombudsman (A-149C), U.S.
Environmental Protection Agency, 401 M Street, SW., Washington, DC  20460.

     1.  In any month does the volume of hazardous  wastes generated  by
         your company amount to:

         / /  zero,

         / /  less than 100 kilograms (approximately 220 Ibs. or
              1/2 of 55 gal. drum),

         _/T  between 100 and 1000 kilograms,  or

         /"T  over 1000 kilograms?

     2.  Do you have any arrangement with a hauling firm to pick up  your
         hazardous waste?

                   [7  Yes              [J  No

         If your answer to question 2 was "yes," respond to questions
         3, 4, and 5.

     3.  Were you able to select your hauler from competing firms?

                   £7  Yes              n  No

     4.  Are your hauler's pick-ups consistently reliable, i.e., as
         scheduled?

                   [J  Yes              £7  No

     5.  In your judgement, are your hauler's  prices reasonable?

                   £7  Yes              £J  No

     6.  Other problems:	
                                   A-l

-------
                                APPENDIX B
                                 COMMENTS
The respondents' indentification of waste disposal problems and relevant
comments are reproduced verbatim below.  They are grouped under five
primary categorical headings:  (1) Transporter Availability, (2) Transporter
Cost, (3) Transporter Service Rendered, (4) Compliance/Enforcement, and
(5) Regulations.  Beneath these headings, identical or similar responses
are grouped.  Responses spanning more than one primary category are
partially or totally repeated, as appropriate, and each of these is
marked at the end with an asterisk.  Each response is followed with
parenthetical data identifying: the state of origin; type of industry;
class of generator; "yes" or "no" response to questionnaire items 2, 3,
4, and 5; and the specific response number assigned, prefixed with M or
T, indicating whether the response was received by mail or telephone.
Respondents' identification of seven specific transporter firms has been
deleted and replaced, in brackets, with Transporter X.
                                   B-l

-------
                         TRANSPORTER AVAILABILITY
     Alaska is too small a market for disposal services.  We're on our
own up here.  (AK/DC-U-NNNN-M847)

     Haulers used to pay for waste oil.  Sometimes it is difficult to get
it picked up - numerous calls.  (CA/AM-S-YYNX-M574)

     No one available to pick up used car batteries on the western slope
of Colorado.  Could get $0.05 to $0.22 each in Denver if delivered but
not sure we can transport.  (Are they hazardous waste?) Also they want a
minimum of 100 turned in.  Expensive to transport to Denver and requires
too much storage space to accumulate numbers needed.  (CO/AM-U-YNNX-M820)

     Problem - Antifreeze removal - Gas removal.  (CT/AM-S-YNNN-M123)

     No haulers available.  We have a real problem with this!  Locations
to haul to are a problem also.  (FL/AM-U-NXXX-M69)

     Until just a few days ago we were unable to transport our waste,
which has been accumulating over a period of time.  Getting service in
outlying areas is very difficult process, with less relief from current
laws.  (ID/DC-U-YNYY-M912)

     At present we are using [Transporter X] and are satisfied with them.
However, we are on the outer edge of their coverage and if they were to
withdraw service to this area, I don't know what we would do to get rid
of our hazardous waste.  (IL/DC-U-YNYY-M782)

     Occasionally someone will take waste oil but no one to take solvents
and batteries.  (IA/AM-U-YYYX-M53)

     I have the desire to dump my hazardous waste properly, but can get
no help.  (IA/DC-X-NXXX-M271)

     Have called several haulers during the past 15 years.  They are hard
to get to come out.  Takes 3 to 4 weeks before they will show up.  You
have to keep calling; they promise the driver will show up, but he never
does.  If you are small they do not want to be bothered.  (LA/AM-U-NXXX-M514)

     No one wants mufflers and batteries.  (MD/AM-S-NXNN-M42)

     No one will service me or other plants in my area.  (MS/DC-U-NXXX-M794)

     No disposal site and no registered haulers in Montana - 4th largest
state.  (MT/AM-U-NXXX-M488)

     Waste oil plus old tires are problem.  (NH/AM-S-YNNN-M12)
                                    B-2

-------
      Irregular  in  pickup.  Only one in  the State of New Mexico and they
 won't  come  to Fannington.  We have to get one out of Colorado.* (NM/AM-U-
 YNNN-M76)

      Don't  have access  to hauler for certain waste such as used glycol.
 (NM/AM-S-YNNY-M478)

      Nearest hauler is  95 miles distant.  Tough for rural areas to obtain
 haulers.  (NY/AM-U-YNYN-M37)

      [Problem is]  to get someone to pickup balance of items, such as
 batteries,  etc.  [Re 2] oil only.  (NY/AM-S-YYYY-M115)

      Have problems with tire and sheet  metal disposal.* (NY/AM-U-YNYN-T955)

     Waste  motor oil is what our waste  consists of.  (NY/AM-S-YYYY-M9)

      Not able to find haulers for all waste classes:  used batteries,
 solvents, tires.   (OR/AM-X-YYYY-M445)

     Where  can  I get a  list of haulers  from Western Pennsylvania?  (PA/AM-
 U-NXXX-M21)

     Getting rid of used batteries legally.  (PA/AM-U-NXXX-M433)

     Other  hazardous waste, like batteries, have not been covered properly.
 No one wants them.  (PA/AM-S-YNYY-M429)

     Hard to get anyone to pick up.  (SC/AM-U-YNYN-M422)

      [Transporter  X] is the only hauler in this area.  We had  [Transporter
 X] contact  us to set up service, but they never came back to pick up.
 The price quoted us by  [Transporter X]  was not reasonable in our opinion.*
 (SC/DC-U-NXXX-M993)

     I have no  way of knowing what is reasonable since we have only  one
 company [Transporter X],  Out here in West Texas we are lucky  to have
 anyone to pick  it  up.   I'm just happy to see them every month.* (TX/DC-L-
 YNNX-M960)

     Not enough information on hauling  firms.  (TX/AM-U-NNYN-M359)

     No one wants  to come into our area to pick up material.   They never
 return calls.   Don't know what the problem is.  (WA/DC-U-NXXX-M986)

     We have been  trying to get someone to run to our town, but none yet.
We are a long way  out of Seattle and Spokane, Washington.  Not many
 cleaners close  by.   This makes it bad for us to get someone to pick  up
 our filters and still bottom.  We are putting the still bottom in steel
 drums till we can  get someone by to pick it up.  (WA/DC-U-NXXX-M874)

                                   B-3

-------
     My first waste hauler, [Transporter X] apparently went out of
business.  When I requested service in the last months of 1986, they were
not picking up due to problems locating an incinerator.  My remaining
choice was [Transporter X] who would transport waste to an incinerator at
$900+ per drum, a price prohibitive to a small business such as myself.
My present waste hauler, [Transporter X], is satisfactory so far; they
have only been picking up dry cleaning solvents in Washington state for
approximately three months.  (WA/DC-U-YYYY-M785)

     No hauler within 80 miles that we can find.  Have made many phone
calls for pickup - no response.  (WV/AM-U-NXXX-M65)

     Can't find hauler.  (WY/AM-S-NXXX-T981)

     In towns under 2,000 population, no hauler wants to come in.  (WY/AM-
S-YYYY-M2)

     Rural area - hauler not available.  (X/AM-S-NXXX-M1038)

     Since there are no hazardous waste landfills in our area, we are
forced to ship filter cartridges, a small number per drum, at exhorbitant
prices.  These filters are steam stripped and carbon absorbed to 3-4
pounds their original weight.  Any hazardous waste left would have to be
infinitesimally small, but the cost is ridiculous!  I don't have any
problems with proper hazardous disposl of still bottoms even though it is
ridiculously expensive in "rural" areas.* (UT/DC-U-YNNN-M1076)
                                   B-4

-------
                             TRANSPORTER COST

Satisfied/No Complaints

     Prices are reasonable, being only one firm is operating in my
geographical area.  (MI/DC-U-YNNN-M1019)

     Currently using  [Tranporter X]; no problems with service.  [Re 5]
Have no one else to compare.* (PA/DC-S-YNYX-M922)

     I have no way of knowing what is reasonable since we have only one
company,  [Transporter X].  Out here in West Texas we are lucky to have
anyone picking it up.  I'm just happy to see them every month.* (TX/DC-L-
YNNX-M960)

     [Re  3] We now have two haulers in Nashville, TN.  (TN/DC-S-YYYY-M190)

     It is difficult to properly evaluate the haulers' prices as we are
not really aware of all the problems involved in proper disposal of the
waste.  (FL/DC-S-YNYN-M148)

     [Re  5] At the time being.  (NY/AM-U-YYYY-M94)

     [Re  5] Nothing to compare to, but company is good.  (MD/DC-S-YNYY-M672)

     They have increased considerably this year but seem to be in line
with others in area.  (ME/DC-S-YYNX-M799)

     [Re  51 Yes, considering what they have to do.  (PA/AM-S-YNYY-M429)

     This is part of business costs.  We need to include the safety costs
into the  end product.  (MI/DC-U-YXYX-M856)

     I am located in New Orleans, LA.  The price has increased dramatically
lately.   I understand the reason for this is because most plants are  just
putting their hazardous waste in the dumpsters instead of using proper
disposal methods covered by Louisiana law.  This loss of business has run
the cost of my hazardous waste hauler and recycler because of the loss of
distributing the cost.  Even though I do not cheat, I understand that
most cleaners are breaking the law and getting away with it.* (LA/DC-U-
YNYN-M647)

     No problems, but I'm afraid, with no competition in my market,
[Transporter X] will continue to raise prices until their prices become
prohibitive.  (KY/DC-U-YNYY-M221)

     [Transporter X] No others in the area that are set up to handle.
(IN/DC-U-YNNN-M8 2 9
                                   B-5

-------
      [Re 5] Depends.  In this sue-happy society can you ever charge enough
to cover yourself insurance-wise and be in business to make a profit?
Too bad our law schools were bursting at the seams a few years ago; the
effect now is terrible!  Hopefully in five years it'll clear itself out.
Then  again, maybe not.  Our legistators may put us out of busines with
their idea of perc classification.  Then we call all wear disposable garments!
(MI/DC-U-YNYX-M824)

     Everyone needs to show a profit for any enterprise.  Let's hope that
it's not an excessive price to pay just to be in compliance with state
and federal regulations.   [Re 3] Not initially, however, others are
available.  (IA/DC-U-YNYY-M839)
No Competition/Monopoly

     Hauler has a virtual monopoly and can dictate almost any price they
want.  (IN/DC-U-YNYN-M268)

     Talk about raising prices and a monopoly - WOW!  There is only one.
[Re 5] They were originally when we were asked to join - Then sky high
after it became law with EPA.  Charges by the month $45 or twice a month
pickup.  (Once for only two cartridges.  Once for 1/3 of a 15 gallon drum
of perc still.  One time for exactly two gallons of perc still.)  Of
course stops = more money!  Same charge per month:  it may be cheaper to
go on a $190 per drum plus a rental charge for the drum.  "They got you
by the nose."  (FL/DC-U-YNYN-M346)

     My problem is with my hazardous waste hauler.  They are like the
modern-day mafia.  They come into my shop, pick up waste, and charge an
extremely high price.  Since I do not have another option of another
hauler in Maryland, I have to pay this high price.  (MD/DC-U-YNYN-M82)

     What competing firms?  This is "Mafia"!  [Re 4] You better believe
it; they charge for it.  EACH VISIT!!  [Re 5] You have got be kidding.
NO COMPETITION.  What would you charge?  Anything you want!* (FL/DC-U-
YNYN-M1016)

     No competition.  Free to charge whatever.  Discount if I buy other
products from same company.  BLACKMAIL.   [Re 4] Usually; more reliable
recently.  (IL/DC-U-YNYN-M258)

     [Transporter X] is the only game in  town.  They know it and their
prices reflect it.  They were high in the first place.  Then they raised
their prices even more this year.  (TX/DC-U-NNNN-M271)

     [Transporter X] has a monopoly in my area and charge and raise
prices at will.  (OH/DC-S-YNYN-M736)
                                   B-6

-------
      Cannot get a comparative price.  Monopoly.  (CO/DC-U-YNYN-M1058)

      Item  3 is very important to look into.  (CA/DC-U-YNYN-M1063)

      We have no choice in who or when our filters are picked up.  The
prices was increased one year after we signed up and we had to sign up or
face  stiff fines from EPA and excessive charges if we didn't sign up
"NOW," from the hauler.  We feel very trapped in this situation.  We have
no choice  but to pay the hauler's price as there are no others to choose
from.  (FL/DC-U-YNNN-M133)

      We feel that because of the monopoly that exists in our area (Northwest
Indiana) our hauler is taking advantage of us with high prices and poor
service.*  (IN/DC-S-YNYN-M332)

      When  we initially contracted with [Transporter X] for picking up our
waste material we were quoted a price of $540 per year for their services.
After the  very first pickup with their present price structure it will
cost  us about $1,500 per year.  They have the monopoly around this region
for this service and are taking definite advantage of this monopoly.
(WI/DC-U-YNYN-M337)

      [Transporter X] has a monopoly in Virginia.  We are charged $219 for
a 20  gallon drum (which [Transporter X] sells us) plus filters (which
[Transporter X] sells us cartons).  There is no choice.  [Transporter X]
tells customers costs are much less than EPA estimates.  But our costs
have more  than doubled in past year.  In response to question 2, how
could any dry cleaner not do this?  (VA/DC-U-YNYN-M156)

      In the Denver, Colorado, area  [Transporter X] has a monopoly.  Since
their competition went out of business, they have tripled their prices.
(CO/DC-U-YNNN-M96)

      [Re 5] We can't tell, when you have no other hauler to compare with.
Only at peak seasons will we generate more than 220 pounds; average will
be below 100 kg.  The price has been changed 3 or 4 times since we started.
(OH/DC-S-YNNX-M126)

     We don't have any choice where we can go.  (NY/DC-U-YNYN-M127)

     I feel that the regulations can only be complied with by  [Transporter
X], thus giving them a monopoly on hazardous waste disposal.   (TX/DC-U-
YNYY-M132)

     Our hauler, [Transporter X], is the only haulers, recycler, and
treatment facility that we know of.  If they raise rates, we have to pay
or go out of business*  If they go out of business, well the handwriting
is on the wall for us as well.  (NY/DC-U-YNYY-M141)
                                   B-7

-------
     Our hauler is a monopoly so no one can tell if their prices are
reasonable or not.  (VA/DC-S-YNYN-M150)

     [Re 3] Only one available to us locally.  (FL/DC-S-YNYY-M151)

     [Re 3] There is no competing choice.  (IN/DC-U-YNYX-M152)

     [Transporter X] is too high and very unreliable.  They have no
competition, they charge what they want, and they come when they want.*
(NC/DC-U-YNNN-M163)

     If the government requires us to haul off the filters, we should at
least have some competitive hauling ocmpanies in Kentucky.* (KY/DC-S-YNYN-M180)

     We need two or three more companies.  (NY/DC-U-YNYN-M989)

     Not enough competition to bring rates down.  New EPA guidelines have
forced many carriers out of business.  Remaining companies can charge
whatever they please.  There should be some form of controls to establish
reasonable rates.* (CA/DC-U-YNYN-M978)

     Possible rate hike very soon. [Transporter X] will probably pull out
of Washington state if Puritan-type cartridge strippers are OKed for land
fill.  Not enough competition, [Transporter X] and one other in the area
(Western Washington and Seattle), to be choosy about who will carry your
waste.   [Transporter X] is about the only game in town.* (WA/DC-U-YXYY-M967)

     Tie-in of services (required) and pricing structure, and is a monopoly
for pickup services:  also monthly minumum charges.  (WI/DC-U-YNYN-T954)

     Prices and procedures always changing.  No competition.* (GA/DC-U-
YNNN-M917)

     Lack of competition.  Excessive cost of disposal; as much as to buy
new cartridges and cleaning fluid.  Less hazardous chemicals in waste
than disposed spray and wash cans.* (CA/DOS-YNYN-M891)

     There is an urgent need for competition among haulers.  Lack of
competition in this matter has encouraged the only present hauler to take
advantage of the situation.  (MO/DC-S-YNNN-M885)

     Besides inconsistent pickups and lack of competition by hauler, no
one seems to know what the total requirements are.*  (CA/DOU-YNNY-M868)

     No competitive firms.  (CA/DC-L-YNYN-M858)

     There is no competition in this area for waste pickup.  We have to
trade with one company and they are very independent.  (MS/DC-S-YNNN-M859)
                                   B-8

-------
      [Transporter X] is the only firm to pick up from cleaners.  [Re 5]
No, because they do not allow us to call for a pickup, charge a minimum
fee each month even when there is nothing to pick up.* (UT/DC-S-YNYN-M813)

      There does not seem to be any problems; however, I believe the waste
disposal firm more or less has a monopoly in many areas.  In return one
has to pay just about any amount they dictate.  I also believe the prices
may be somewhat on the high side.  It sure must be nice to run a business
without competition.  Wouldn't you just love to be in such a business.  I
sure  would.  [Re 5] How should I know, if there is no competition?  (IL/DC-
U-YNYX-M800)

      As for waste haulers in my area there is only one company.  There needs
to be more competition.  (GA/DC-S-YNYN-M262)

      The price for these services has almost doubled in the last two
years, and minimum charges have been assessed if there is no pickup in
any given month.  There is no competition for these services in the State
of Illinois, therefore, [Transporter X] has a monopoly in this state.
(IL/DC-S-YNYN-M246)

      [Transporter X] has no competition in Greenville, SC area.  (SC/DC-S-
YNYN-M241)

      When there is only one firm supply a service, such as [Transporter
X], then our prices will never be competitive.  This is creating an even
bigger problem than before [Transporter X], since some dry cleaners may
dispose of waste in an illegal manner.* (SC/DC-U-YNYN-M229)

      I feel that [Transporter X] realizes we have no one else to use, so
they  take advantage.  When they first started they would pick up when you
needed it, with no service charge, just a charge for the barrel and $11.00
per filter.  Now they charge $42.00 a month plus filter and barrel charge
whether you need them to stop by or not.  (TX/DC-U-YNNN-M231)

      Only one hauler is available that I know of, [Transporter X].  About
5 gallons of oil base from the still and 10 medium wet filters every 2-1/2
months doesn't require hauling.  (SC/DC-U-NNXX-M218)

     No competition.  (TX/DC-S-YNYN-M225)

     No other companies to choose from. Prices are very unreasonable.
(TX/DC-U-YNNN-M725)

      [Transporter X] is the only game in town.  (TX/DC-U-YNNY-M728)
                                   B-9

-------
     They got us over a barrel.  With no competition in a situation which
we must obey, the government should regulate prices, or allow us to use
stripping machines to do a lot of the work ourselves.* (PA/DC-U-YNYN-M710)

     Costs are very high and lack of competition gives us no choice.*
(CO/DC-S-YNYN-M707)

     No competition will not last in the long run.  (CT/DC-U-YNNN-M681)

     Since the majority of us have only one choice for hauling waste, I
feel that these people should be regulated - similar to phone and utility
companies.* (CO/DC-S-YNNN-M665)

     When there are no other haulers available, my service and price was
put on a take it, pay it, or do it yourself.  (AR/DC-U-YNYN-M663)

     Since I am responsible until it reaches the disposal site, I feel
it's over paid.  No competition.  (CA/AM-U-YNYN-M559)

     No competition.  (CA/AM-S-YNYN-M564)

     So far have found only one hauler.  Thought his prices were high.
(CO/AM-U-NXXX-M548)

     Need more competition in waste removal, more incentive to get into
the business.  (MN/AM-U-YNYY-M502)

     A lack of competing firms caused higher hauling rates.  (OR/AM-U-
YNYY-M447)

     [Re 3] Yes, but only one now.  (MN/DOS-YYYN-M311)

     Present hauler needs competition.  (MD/DC-U-YNYN-M315)

     We have no comparison of prices if there is no competition.  (MA/DC-
U-YNYN-M309)

     There is only one hauler in the state and they set  the prices.
There is no way of knowing about price.   [Transporter X] charges even  if
you have nothing to pickup.  (MD/DC-U-YNYX-M274)

     [Re 5] Have no basis upon which to offer an opinion.  It's the  only
game in town.  (VA/DC-U-YNYX-M276)

     No competition, so prices are high.  (LA/DC-U-YNYN-M279)

     Only one company.  Too high:  $160/barrel 55 gallon drum  and  $50
registration fee.* (WA/DC-U-YNNN-M747)
                                   B-10

-------
      [Transporter X] is the only hauler of dry cleaners' hazardous waste.
 (MD/DC-S-YNYN-M720)

     Our hazard waste hauler has a "take-it-or-leave-it" attitude since
 they are the only source available to us. . .Perhaps you can name another
 in our trade journals other than [Transporter X]!* (MI/DC-U-YNNN-M793)

      [Re 3] There is only one in state.   [Re 5] Who knows?  (AZ/DC-U-YNYX-
 M759)

      [Re 5] Don't know, no competitors.   (AZ/DC-U-YNYX-M757)

     There is no competing firm.  Only one in state.  There is no competition.
 (AZ/DC-0-YNYN-M758)

      [Transporter X] is now, from what can be determined, the only hauler
 in Washington state.  A monopoly.  Their  prices include monthly minimum
 plus hauling charges.  We are being ripped off.  (CO/DC-U-YNYN-M7A9)

     The worst thing is the noncompetitiveness.  There is only one show
 in town - so you have no choice but to use them.  (WI/DC-S-YNNN-M3)

     Impossible to get competitive quotes on disposal of hazardous waste.
 (PA/AM-U-YNXN-M19)

     When hauler was selected no one else was picking up waste.  There
 are still not a lot to choose from in this area.  (TX/AM-U-YNYY-M38)

     I believe there would be more firms  in the business, making prices
more reasonable, if the government regulations would not be so hard and
 expensive to comply with.*  (FL/DC-U-YNYN-M1054)

     We need a choice!  We have none.*  (MS/DC-0-YNYN-M1033)

     As to #5, the prices are as good as  you would likely get considering
 there are no competitors.  (TX/DC-U-YNYY-M1032)

     We have no other haulers in our area.  I have no alternative.  (PA/DC-
U-YNYX-M1013)

     My problem (and I'm not the only one!) is that only one company
picks up the waste here.  I understand that it's costly for them to do
it, but they're so arrogant, and literally have a monopoly going here!
Is it right?  (TX/DC-U-YNYN-M101A)

     We're dealing with a monopoly so it's hard to say prices are equitable
. . .Only one other company with dubious  record. . . [Re 5] I guess.*
(CA/DC-S-YNYY-M1002)
                                   B-ll

-------
      [Transporter X] is the only hauler in this area.  We had [Transporter
X] contact us to set up service, but they never came back to pickup.  The
price  quoted to us by  [Transporter X] was not reasonable in our opinion.*
(SC/DC-U-NXXX-M993)

     I get charged for a pickup even if I don't need it or I have to pay
$100 to get added back to the route for future pickups.  Unless I leave a
note saying I don't want filters, they leave a box of filters every time
they pickup.  They are [Transporter X],  There is no competition and they
have increased my cost, their prices, every year.  (IN/DC-U-YNYN-M990)

     Present set up has only given [Transporter X] a license to steal.
They have no competing firms and can therefore charge as they wish.  We
pay for lack of choice or other option.  (X/DC-U-YNYN-M202)

     Problem is:  There is no competition in the hauler - pickup firms.
Only one company is available.  He sets his own terms in regard to prices,
etc.  We need some kind of government agency to oversee the pricing of
the hauling service since there is no competition.* (0/DC-S-YNYN-M266)
Monthly Charge Unjustified

     Hauling firm requires pickup monthly and charges for pickup whether
or not required.  (FL/DC-U-YNYN-M197)

     We have a very small plant.  We only need  [Transporter X] to pick up
our filters every six weeks.  They come once a month whether we need them
to stop or not.  For this we are charged $40 each visit.  I have written to
protest this type of charging when we don't need them to stop by.  Their
man comes to the door - says "hi," asks if we need pick up.  We say no.
He leaves and sends a bill for $40.  I feel like we are being robbed.  If
I protest, they could refuse to service us at all and then we would be in
trouble with EPA.  Our government has created a monster.  It's like paying
protection money.  It's NOT FAIR.* (WI/DC-U-YNYN-M657)

     We have to pay $40 per month per store whether we have waste or not!
This is the hauler availability charge!  They estimate our weight.  They
will not accept our weight!  They include drum and waste in their weight.
We have had to quit cleaning at one plant, hauling all clothing to our
other plant to cut our cost on hazardous waste hauling.  NOW to resign up
with our "hauler" we must pay a $200 charge!  For the store we dropped.
(TX/DC-U-YNNN-M748)

     Our hazardous waste pickup service is a big rip-off.  I have told
the salesmen and have called the company, and their attitude is they
could care less.  [Transporter X] is our service company, and they have a
30-day pickup service, but it's not exactly 30 days, anytime between 20
and 30 days, in which is always sooner never later.  For a small business
it's a big rip-off because everytime they drive up in our driveway and
                                   B-12

-------
 walk  in  the  door  it's  $40 whether they pick up anything or not.  Their
 prices are outrageous,  they have no competitors and can charge whatever
 they  want.   PLEASE HELP US PUT THIS UNDER CONTROL!!!!!  (TX/DC-U-YNYN-
 M743)

      $40 per month, actually  $100 per month, or about original of filters
 for pickup.  Am pressured to  purchase from pickup.  Am unhappy with
 government for this situation.* (MD/DC-U-YNYN-T1003)

      Don't like paying  a monthly fee, whether 1 have a pickup or not.
 (X/DC-S-YNYN-M1011)

      [Re 1]  Per store  for eight stores.  I feel the prices charged would
 be reasonable if  I weren't charged for a once a month pickup whether I
 have  waste or not.  Most of my operation generates waste on a five to six
 week  schedule.  My hauler comes every four weeks and charges me a $40 fee
 whether  I have waste or not.  (MN/DC-S-YNYN-M770)

      The hauler now charges a flat fee per month whether they pick up
 anything or  not.  The monthly flat fee is $40 per month.  (GA/DC-U-YNYN-M330)

     They charge  me a flat rate; however, I pay for a container to store
 used  filters then I have to pay for a box to put the filters in.  If this
 is the case, then let me just pay for the box.  (GA/DC-U-YYYN-M336)

     Paying  hauler $40  whether he picks up or not once a month.  (MA/DC-0-
 YNYN-M350)

     Have to pay  for months that there is no waste.  Use [Transporter X].
 Do not really qualify but use company for safety reasons and environmental
 protection.  (X/DC-X-YNYN-M298)

     Pickups should be  only when needed, ordered by phone call, and be
 charged  for  only  the gallons  picked up.  (TX/AM-U-YNYN-M380)

     Must pay [Transporter X] $41.60 per month with or without pickup or
have special order pickup at  $85.00.  (NY/DC-U-YNYN-T641)

      [Transporter X] charges me regardless of whether I have waste; this
seems to me  rather unreasonable.  (TX/DC-U-YNYN-M206)

     We have only one hauler  available to us and they charge us a service
fee for every month regardless if they pick up or not.  This is not fair
in my judgement.  They  have you any way you look at it because there are
not any other haulers available in this area.  (GA/DC-U-YNYN-M879)

     Charge  us if they  pick up or not.  (NH/DC-U-YNYN-M675)

     We have to pay $40 a trip, one each month.  (VA/DC-0-YNYN-M719)
                                   B-13

-------
      [Re 5] No, because he insists on picking up each month.  I do not
fill  the container he leaves in a month.  I have to pay his fee for him
to pick up a 1/3 or 1/2 filled container.  Also, dry cleaning machines
contain 4 filters.  His containers hold 6 filters.  He really needs some
competition.  Small quantity generators are not interesting to him.
(AZ/DC-U-YNYN-M659)

      As I am a small generator (my maximum waste less than 100 kg), there
are months that I have no pickup and am charged $40 (minimum) for the
pickups when I have zero waste.  I do not think this is fair.  I would
prefer to arrange for pickup dates when I do have waste, reducing my
costs.  My hauling firm is [Transporter X].  (Ny/DC-U-YNYN-MllO)

      I pay on a monthly basis whether I have any pickup or not.  I believe
this  new ruling is a real injustice to the dry cleaning industry.  (UT/DC-
0-YNYN-M727)

      This company has a dictatorial attitude, with fee per month whether
waste is picked up or not.  Some other arrangements must be made for the
very  small generators.  (NY/DC-U-YNNN-M863)

      Charge minimum even if no pickup.  (NY/DOS-YNYN-M974)

      Must pay even when there is no waste; removes incentive to limit
amount of waste generated.  [Re 3] Only one of which I am aware.  (NJ/DC-
U-YNYN-M116)

      They come monthly and charge a minimum fee.  I do not have waste for
them  to take each month.  If they don't come monthly, they double the
fee.  (NY/DC-U-YYYN-M114)

      There is only one company, [Transporter X],  They schedule 13 pickups
a year at a minimum of $40 a visit, with or without a pickup.  Why can't
they  come when we call?  (NY/DC-U-YNYN-M102)

      Petroleum - I put out about 2 gallons of still bottom a week, 8
gallons a month.  Pickup is once a month and only 1/2 of a  16-gallon
drum.  Service refuses to come only every other month, effectively doubling
the cost of waste disposal for me.  (NC/DC-U-YNYN-M222)

     We change filters every two and a half months.  If we  choose
"unscheduled pickup," it is too expensive.  On  the other hand, if  we  go
by "scheduled pickup," which is picking up every  fourth week,  we sometimes
have  to pay for coming without giving any hazardous waste.   So both pick
up programs seem to be too expensive and inconvenient to our company.
(MD/DC-U-YNYN-M237)

     We are being charged a minimum fee for each  month whether we  use
service or not.  (TX/DC-U-YNYN)
                                   B-14

-------
     Dirty  cans.  Lids don't  fit.  Lock rings missing.  Hauler charges
 $40  per month  regardless if we have any waste to pick up or not.
 Occasionally we hold half  a shipment  till  the next pickup to make it cost
 effective.* (IL/DC-U-YNNN-M996)

     [Transporter X] demands  a $40 per month maintenance fee or else
 charges double the  regular price and  demands that be COD.  (LA/DC-U-YNYN-M245)

     Started out at reasonable prices.  Have raised them several times.
 Leaves products not ordered.  Keeps coming one week earlier each month.
 Must pay even  if you have  no  waste.   Taking advantage of no competition.
 (TS/DC-U-YNNN-M273)

     Every  time the hauler stops he charges us $40.  We haven't sent any
 waste for six  weeks but we still must pay.  They know we send every two
 months.  (WI/DC-U-YNYN-M802)

     Monthly fee whether or not have  sufficient amount of waste to dispose
 of.  (LA/DC-U-YNYN-M205)

     His schedule is twice as often as I would need them.  Therefore,  I
 pay  for disposing of twice the waste  filters than I use.  (IA/DC-U-YNYN-M838)

     There  is  a per month  charge whether there is a pickup or not.  (NY/DC-
 U-YNYN-M125)

     Charged for a pickup  once a month whether you need it or not.  (NY/DC-
 U-YNYN-M98)

     1 am charged a fee even  if I do  not have any hazardous waste.  (FL/DC-
 U-YNYN-M97)

     They charge a monthly $40 even if I don't have any waste to remove.
 I don't think  this is fair.   I've raised my prices just because of the
 waste removal  and my customers are complaining.  I'm a very small cleaner
 and these new  laws are going  to put us out of business.  If it weren't
 for the small  business in  this country, this country wouldn't exist.
 (OH/DC-U-YNYN-M196)

     First  year of contract we called [Transporter X] as needed.  As of
 January 1987, hauler is making regularly scheduled 4-week stops.  On some
 regularly scheduled stops  we  have nothing  to be hauled away, but we are
 none-the-less  charged $40  for the stop.  We are also asked to buy cartridges
 or recycled perchloroethylene.  (PA/DC-U-YNYN-M137)

     [Transporter X] is taking advantage of its monopoly postion:  $40
 per month and may not need pickup as  often as six-month intervals.  (FL/DC-
U-YNYN-T956)
                                   B-15

-------
     I use jumbo filters.  I was first furnished with four barrels to
store four jumbos in.  When they picked up, the charge was $5 a barrel
and $20 for wasted jumbo filter.  I would have three pickups per year = 2
approximately $110 each pickup = $330 per year.  Now I have to have once-
a-month scheduled pickups, whether I have anything or not, and am charged
$40 per month which equals $480 per year plus what waste I have.  If I
don't get a regular schedule I would have to pay $85 per barrel which =
at three times a year approximately $1,020 per year unscheduled stops
(pickups).  [Transporter X] being the carrier:  What a scam!  (MO/DC-U-
YNYN-M971)

     When the hauler comes to my place there is a charge whether I have
any waste or not.  (NY/DC-S-YNYN-M972)

     We pay extra if more than two cartridges are picked up.  [Re 5] On
the high side.  We pay even if no pickup.  (NY/DC-U-YNYN-M939)

     Pay $40 per month whether or not pickup made.  Consider rates terrible
for small cleaners.  (SD/DC-U-YXXY-T952)

     Must be picked up every four weeks.  We do not generate enough waste
to fill their containers.  We must pay for full pickup when a six-week or
eight-week pickup would be adequate for our needs.  (NY/DC-U-YNYN-M935)

     I generate waste approximately every quarter.  My hauler stops every
month and charges a minimum fee.  (GA/DC-0-YNYN-M894)

     Hauler has minimum "stop" charges that far exceed my cost for disposal
and requires monthly pickups, so my monthly minimum charges may exceed my
normal waste costs by 300 percent or more.  (WI/DC-U-YNYN-M881)

     We feel our disposal service is taking advantage of us because they
are the only service in Colorado we know of.  We are being charged $40 a
month whether we need a pickup or not.  We have a barrel rental fee of $5
each plus an $11 cartridge fee.  We feel these charges are outrageous and
unfair.  If the EPA can recommend another company rather than  [Transporter
X], please inform us!  (CO/DC-S-YNYN-M1074)

     Have to pay hauler whether pickup or not.  (CT/DC-S-YNNN-T1062)

     I have to pay monthly rate even if I do not have waste.   (NY/DC-U-
YNNN-M1080)

     Our hazardous waste is less than 25 pounds per month and we  are
being charged a monthly rate whether a pickup is needed or not.   Some
other arrangement should be made for the very small user.   (NY/DC-U-YNYN-
M1083)
                                   B-16

-------
 Coercive  Product Marketing

      The  company who  picks  up  our waste also is putting pressure on us to
 buy  perc  and  cartridges  from them.  We did not so they went up on the
 price.  (VA/DC-U-YNNN-M88)

      Must have  a pickup  or  pay a miniumum charge of $40; every four weeks
 as stated by  the hauling company.  Also must buy their products to get a
 lower price.  (NJ/DC-0-YNYN-M118)

      Pressure to buy  other  products, inaccurate weighing, purposely
 inflated  billing.   (MD/DC-U-YNYN-M131)

      Since the  inception of hazardous waste disposal,  [Transporter X] has
 raised  their  prices by leaps and bounds.  When I have voiced concern,
 their attitude  has  been  "take  it or leave it."  Since  they are a monopoly,
 I have  no other choice.  Now they are trying to sell back the reclaimed
 solvent and giving  discounts to cleaners who do.  It looks like they will
 soon  be selling all types of supplies, trying to take business away from
 local suppliers, using hazardous waste pickup as leverage.  (MD/DC-S-YNYN-
 M347)

      Pressure is sometimes  applied from the haulter to purchase products
 from  them, such as  filters, reclaimed perc, and detergents.  Some of the
 products  are  of a very low  grade and not compatible in my business so I
 cannot  purchase them.  (KY/DC-U-YNYN-M186)

      Charge is  $40  per month,  whether or not pickup is made; actual cost
 for filter disposal is about $100 per month or about the same as the cost
 of filter  new.  Pickup service pressures clients to purchase supplies
 from  the  service, offering  discounts on disposal charges.  Tend to blame
 the government  for  this  non-competitive environment.   (MD/DC-U-YNYN-T979)

      Have  only  20 gallons generated per month but rate is $50 per month.
 [Transporter  X] is  insistant on purchase of materials  from transporter;
 materials  are not of  best quality.  (NY/DC-U-YNYN-T956)

      The  hauler wishes to sell his products (perc, filter cartridges) by
 reducing  his  waste  removal  prices.  (NY/DC-U-YNNN-M929)

      Company  started  off as hauler.  Now are competing with product
 companies.  When you  buy their products, you get discounted or cheaper
 rates for  hauling residue.  I  think this is unfair.  (IN/DC-S-YNYN-M883)

      If we do not purchase  the filter cartridges and solvent from the
hauler, then  the price for  pickups are way higher.  In other words, we
 are at  the mercy of this hauler only.  (TX/DC-U-YNYN-M880)

      [Transporter X]  is  the only hauler in this area.  Should they tell
me that I  have  to use only  their filters and perc?  (I presently order
 supplies  from an Oklahoma City company.)  I would consider taking my perc
 unit  off  the  line.  (OK/DC-U-YNYY-M837)

                                   B-17

-------
      I have been billed for pickups which were already paid.  I have
been billed for pickups which had not been picked up.  I have tried to
get another hauler, but none will respond to my inquiries.  My hauler,
 [Transporter X] continually tries to sell me their products as a way to
lower my hauling costs.  Prices have gone up and containers have been
made smaller at the same prices.  Totally undependable.  (TX/DC-U-YNNN-
M243)

     The cost to haul off cartridges is more than I pay for new cartridges.
The hauler also requires me to purchase perchloroethylene from him at a
much higher price than what I could purchase.  (GA/DC-S-YNYN-M200)

     Salesman with the hauling firm is very high pressure about selling
his other products to us.  We would choose another firm if there was
another option.  (TX/DC-S-YNNN-M704)

     [Transporter X] was our only choice.  They come every month whether
we need it or not - and charge for it!  (1) They have changed their
pricing structure three times in two years.  (2) They have been unusually
"pushy" about selling us recycled perc and filters.  (3) They currently
are using a cardboard box with a liner to pick up used cartridges.  The
county health and hazardous waste department isn't very pleased about
this.* (MO/DC-S-YNYN-M335)

     We use [Transporter X] and their prices are unreasonable.  They will
lower prices if you buy cartridges and perc from them.  I tried both and
found that they were selling below-standard products.  A monopoly if ever
I saw one.  (GA/DC-U-YNNN-M741)

     They insisted on buying their "recycled" products and other filters
or else they would not pick up the hazardous waste.  They also want to
charge us $40 each time they come to the store even if there is no waste
to be picked up.  (NY/DC-U-YNNN-M1053)

     We have contracted [Transporter X] to haul our hazardous waste for
us, and have not experienced many problems with scheduling,  service, or
even price with one exception.  [Transporter X] Charges $35.00 per 15
gallon drum of still bottom residue, a price I consider reasonable.  What
I strongly object to is the charge for hauling away used filter cartridges.
We own a Puritan 4000 SRS recovery system used only for the  recovery of
solvent from used filter cartridges.  We get an average of 30 gallons  of
solvent out of these 21 cartridges, and I feel that the Perc content  is
well below any reasonable allowance set by EPA.  I feel we should be
allowed to throw them away as junk (metal and paper) instead of paying
$11.00 each to have them hauled away.  This charge has doubled my cost of
filtration in the last 3 years.   [Transporter X] has developed their  own
filters which they sell at a reasonable market rate and give a discount
of $3.00 for each cartridge when  they are disposed and hauled away.   1
refuse to use their cartridge because they are not near the  quality,  in
my estimation, as the Puritan filters are.  After  trying  one set  of  the

                                   B-18

-------
 [Transporter X] filters in  the exact same conditions as the Puritan
 filters,  [Transporter X's]  filters completely fell apart and collapsed in
 the  filter housing.  I feel very fortunate that I did not pay out a lot
 of customer claims for ruined garments from that filter system.  A proper
 filter system is a must for a quality drycleaner, and our customers expect
 quality.* (IA/DC-S-YNYN-M762)

     Overcharging - Constant pressure to buy other products - Intimidation
 about pickups if you do not buy their products.  (MD/DC-U-YNNN-M717)

     A serious conflict of  interest exists since the hauler recently
 established a product line  for sale to our industry.  If we buy their
 chemicals and filter products we can receive discounts on waste disposal.
 Their route men receive commissions on sales and consequently provide
 better service to those customers who buy their products.*  (VA/DC-S-YNNN-
 M1060)

 High/Unreasonable Prices

     Costs have increase 30 times as compared to previous to use of this
 service, increasing inflation pressure significantly.  (PA/DC-U-YNYN-M102)

     Too excessive - expensive.  (PA/DC-U-YNYN-M106)

     Other cleaners place their waste in with their other trash.  Meanwhile
 the  cost of the time of paperwork and pickup must be reflected in my
 prices.  This places a burden on me and makes it difficult to do business
 in the New York City area.* (NY/DC-U-YNNN-M109)

     After a contract had been signed and all other companies went out of
 business, we have had several price increases and, of course, what can we
 do but pay for it!  (LA/DC-U-YYYN-M134)

     $40 per month, when we usually have 10 gallons, does seem high.  It
 is costing an excess of $12 per cartridge; that also seems high.  Special
 pickups at $85 is a considerable expense, one we did not have before.
 (PA/DC-U-YNYN-M155)

     [Re 5]  $120.60 per barrel.  (AZ/AM-S-YNNN-M157)

     [They]  say they can only pick up two containers a month.  We changed
 filters three months ago.  They are making up our rules, since only firm
 in town picking up.  We are actually storing hazardous waste because  they
 can't pick it all up at one time.  They are very bad, very expensive,
 very undependable.  Don't like this, but have to have it hauled off
because I want to do right by the law.  Bad situation.   [Re 3]  [Transporter
X] only - bad news.  [Re 4] Never know.  [Re 5] Absolutely not - very
 unreasonable.* (TX/DC-U-YNNN-M164)
                                   B-19

-------
     Since I do not know the hauler's problems or expenses, it is hard to
judge if his charges are in line.  The prices have just gone up and I
have to wonder about such large increases.  The whole problem is another
expense I do not need.  (OH/DC-UYYYN-M165)

     We get out the waste and still have to pay.  Others don't even strip
their cartridges.* (IN/DC-S-YNYN-M191)

     I am a very small quantity generator:  20-25 gallons/month still
residue and eight filter cartridges about four times a year.  I don't
think $40 a month plus disposal costs for each drum and filter is
reasonable.  (AL/DC-U-YNYN-M193)

     Price has doubled in two years.  (MO/DC-S-YNYN-M194)

     Why some cleaners have to pay to have it picked up and some don't.
We pay to have it picked up then they recycle it and sell it to the
industry.  That is not fair.  (IL/DC-X-YNYN-M988)

     In addition to the charge for hauling waste away, there is a drum
use charge and a state tax on 2/3 of the weight in addition to state
sales tax.  (NY/DC-S-YNNN-M980)

     We are being charged $5 for the drums, which are used twice then
discarded by our hauling firm.  We feel EPA's ruling on this should be
reduced somewhat.*  (IA/DC-U-YNYN-M968)

     Need relief.  (TX/DC-U-YNYY-M964)

     [Transporter X] is the only hauler that I know of in our area.
Their prices to get our filters hauled off are as much or more than new
filters cost.  With few locations, our monthy cost is in excess of $500.
Small operators like myself need some relief.  (TX/DC-U-YNYN-M981)

     $43.20 per month is unreasonable.  (NY/DC-YNYN-T957)

     Paid $280 per year for less than 100 gallons paint disposal.  Need
more competition and simplified procedures.* (NY/AM-U-YNYN-T955)

     $600/100 kilograms.* (TX/AM-U-YNYN-T953)

     We pay $40 a month plus $5 for rental of the storage drum (capacity
30 gallons)  before and cartridges are taken.  Then cost is an additional
$11 each cartridge.  We use [Transporter X].  (TX/DC-U-YNYN-M934)

     There is always something added to the bill that I did not have
picked up.  The company is [Transporter X].  (LA/DC-U-YNYN-M936)
                                   B-20

-------
      Constant  changes  of prices, how pickups will be handled, and what is
 required of me.*   (1L/DC-U-YNYN-M932)

      Have contract with  [Transporter X].  Recently they changed their
 method  of pickup which,  in my opinion, increased their cost and lowers
 their level of  service.*  (MA/DC-U-YYNY-M930)

      It costs  me more  to dispose of a spent cartridge than it costs me to
 buy  a new one.* (VA/DC-S-YNYN-M925)

      Has added  additional expense of $2,000 to $2,500 to my small business.
 Will  force many small  businesses out.  (IL/DC-S-YNXY-M915)

      We cook our cartridges Puritan and have very little waste.  We think
 this  pickup, [Transporter X], is a waste of money.  It costs $11 each to
 have  these [filters] hauled away.  We could put them in our trash for
 nothing.  We have  21 a month.  Now the consumer pays in higher prices.*
 (IN/DC-U-YNXX-M911)

      Prices started good; keeps raising costs.  (TX/DC-S-YNYN-M905)

      As a single-plant dry cleaner we produce very small amounts of waste
 per month.  Since we cannot dispose of the hazardous material ourselves,
 we are  forced  to make  use of our hauler and pay $40 per month plus the
 cost  of the waste.  These costs are astronomical for us and it is very
 difficult to pass them on to our customers.  (CA/DC-S-YNXN-M909)

      [Transporter X] is a rip-off!  Please push for disposal of purged
 filters as non-hazardous waste.*  (CA/DC-U-YNYN-M902)

      [Re 5] Somewhat high.  (MN/DC-U-YNYN-M901)

      High cost  of disposal.  No reliable competition that fulfills the
 regulations.   (CA/DC-S-YNYN-M898)

      He more or less is trying to sell and wants you to do all his work.
Filters are $11 each,  30 gallons waste $40, plus $4 each box, $5 30-gallon
pail.  (TX/DC-U-YNNN-M892)

      I think the prices are too high.  (CA/DC-U-YYYN-M882)

     Unscheduled pickups, plus the fact that the cost is as much as the
filters, have made our cost double what it has been in the past.  (CO/DC-
U-YNNN-M875)

      In the past year  there have been two price increases.  The way prices
keep going up,  the cost of the new filters will be the same as the cost
to have them hauled away.  (PA/DC-U-YNYN-M866)
                                   B-21

-------
     There have been three price increases in the past year.  #5:  yes,
because I have nothing to compare them to.  (IL/DC-U-YNNY-M853)

     [Re 5] We are being ripped off.  (CA/DC-U-YNXN-M861)

     Pay same minimum price regardless of generation rate.  Average cost
is $120 per month.  Container charges ridiculous.  Need ideas on compactors
to compress filter cartridges so more can be put in each hazardous waste
container.  (TN/DC-U-YNYN-M848)

     Cost was highly underestimated at the beginning.  It has become a
major expense.  (FL/DC-S-YYY-M840)

     Rather expensive, $100 per pickup.  (PA/DC-U-YNYN-M830)

     Price for small generator like myself is unreasonably high compared
to what large generators pay.  I paid $40 each for a small 15-gallon drum
in 1986. and in 1987 have to pay $90 each for the same size container for
perc cooker residue.  This may not be much money, but for a real small
business every dollar paid out hurts.  (OH/DC-0-YNNN-M822)

     Cost recovery.  (CA/AM-S-YYYY-M816)

     Cost of doing business has increased dramtically.  (TX/DC-U-YNYN-M814)

     Charges have escalated sharply since the original quote for hazardous
waste pickup and it appears they will be increasing sharply again.
Charges for cartridge filter pickup are unreasonable and consideration
should be given to revising the standards for filters.* (GA/DC-U-YNYN-M809)

     Quoted one price with a written agreement then hauler changed price
without notice.  (LA/DC-S-M797)

     I wrote out a check in full to [Transporter X] representative for
$295 - to remove my paint thinner two times a year.  They never  came,
even after numerous phone calls.  (NJ/AM-U-YNNN-M10)

     No other problems, but we could question their pricing practices.
(NC/DC-S-YNYN-M280)

     The two out here are out to get each other at any cost.   I  pay too
much and feel they and California have my back to the wall.  The way I
look at it soon there will be only, one hauler and it will cost so much a
small business like me will have to sell out.  [Re 3] In a way - there
are only two out here.  (CA/DC-U-YYYN-M270)

     From the initial time to-date the prices keep constantly  going up as
they are the only game in town.  (FL/DC-U-YNYN-M254)
                                   B-22

-------
     We  comply  thoroughly with all guidelines concerning our wastes, but
 the  EPA  has  to  license or provide alternative to open this area of our
 industry for more  competitive rates for disposa^.  Although we will
 continue to  handle our waste disposal according to the laws no matter
 what the cost.   Some  smaller cleaners with  the depressed economy may have
 to resort  to other means of disposing their wastes if something isn't
 done about the  ever increasing costs, and this will snowball into increased
 costs to the governments by having to regulate and monitor the proper
 disposal of  these  wastes.  Aside from the fact that I think everybody
 wants their  children  to be able to drink the water and enjoy our lakes,
 streams, and rivers in this great country without being poisoned.  Thank
 you  for  lending an ear for this growing problem.*  (TX/DC-S-YNYN-M211)

     At  the  present time we are using [Transporter X] to remove our
 hazardous  waste only  because they are the only service available in our
 area, by eliminating  all competition.  Our  cost for disposal is the same
 as our cost  for filter purchases which to us seems excessive.  We dry our
 filters  prior to disposal and they only weigh about three quarters of the
 weight stated by [Transporter X], which in  turn effects our volume of
 generated hazardous waste.  We also feel that the largest percentage of
 that weight  is  paper  and metal binders.  If we were able to report only
 our  actual "hazardous waste" there is no doubt in our mind that we would
 be well  below the  one hundred kilograms per month, which obviously would
 eliminate  this  exorbitant expense.  We want it very clear that we are
 aware of the need  for the proper disposal of "hazardous waste" and are
 more than willing  to dispose of properly.   However, we feel we are paying
 a lot of money  to  dispose of paper and metal.  I personally feel, but can
 not  prove that  [identity deleted] is receiving monies (kick-back) from
 [Transporter X] which in turn is affecting  our cost.  We would appreciate
 hearing  from you regarding this matter.  (NY/DC-S-YNYN-M267)

     The Kansas law has taken the Federal law and cut .it in half, therefore
 less than 50 kgs in any month is a violation of Kansas' laws.  Pick up is
 most difficult  and  getting storage containers almost impossible.  The
 cost is  prohibitive and just about put me out of business.*  (KS/DC-YYNN-M261)

     Properly purged cartridges leaving less than one percent perchloroethylene
 should be disposed  of in local land fills.  This would cut the present
 high cost Co dry cleaners and not damage the environment.  This choice is
 not  available now.  Therefore, we are at the mercy of one hazardous waste
hauler.*  (WI/DC-S-YNYN-M257)

     This is a  very good questionnaire.  I  hope you will see how the dry
 cleaner  is being held up!  We reclaim every ounce of solvent before our
waste is hauled away.  (IA/DC-U-YNNN-M253)

     Costs more to  pick up than buy new cartridges.  (RI/DC-X-XNNN-M238)
                                   B-23

-------
     Pickup situation here is out of control.  [Transporter X]  has law on
their side, has a monopoly, is charging exorbitant prices, and  is using
coercive tactics.  Two of largest cleaners here have recently dumped
them; what they are doing with waste, I don't know.  Disposal must be on
a practical basis or dumping/lawbreaking will become rampant.  They want
$40/month with or without pickup need plus $5-$6 for new drum each trip.
Will reduce pickup by $3 and waive drum charge if we buy their  products.
Products are inferior to Puritan, which we have been using.  EPA should
call moratorium on law NOW till solution is provided.*  (NC/DC-S-YNYN-
T216)

     [Re 3] I use [Transporter X] and I'm not sure anyone else  comes into
this small west central Alabama town.  [Re 4] Adequate:  we haven't been
on the once a month schedule long enough to know.  [Re 5] $45.00 per
month for 4 cartridges and use of one drum.  I've had a lot of  problems
with the servicemen making out the billing - they like to charge twice or
more for everything.  They play dumb and hope not to have their hand
called.  With a lot of letter writing, it is much better now - with the
straight $40.00 + $5.00 per month charge.  (AL/DC-U-YXXX-M212)

     Our plant is small and in Houston.  Only one company [Transporter X],
picks up the waste and requires us to be a member with unreasonable fee
(set up fee $100.00 + monthly fee + filters picked up as waste).  We
wonder what we are going to do in this case.  Please advise.  (TX/DC-U-
NNNN-M215)

     Pickups are scheduled on the last day of the month, at hauler's
option.  He will charge extra to make a special trip.  Usually they will
come a day- or two before a filter change.  It takes another day or two  to
cook the cleaning fluid out of the filters.  The filters then remain in
the plant for most of a month waiting to be picked up.  My company spends
thousands of dollars complying with hazardous waste disposal while
numerous other companies simply throw their hazardous waste in the
dumpster.  Who is enforcing the law?*  (TX/DC-U-YNNN-M209)

     Waste disposal has increased our operating expenses 3% ($2,000)
annually.  The basic costs to this firm are:  $5/waste container for each
15 gallons of still residue or 4 cartridges and $33/15 gallons of residue
and $1 I/cartridge.  While we are concerned with the drycleaning effects
on our environment and follow all regulations, how can we compete with
the cleaner not doing so?  They can put the $2,000 in their pockets.
(CO/DC-U-YYYY-M203)

     $27 per jumbo filter.  Hauler will only allow one jumbo cartridge
filter per drum.  If we were able to remove the metal ends and metal
housing (Which should not be considered hazardous waste) we could put  3
or more filters in a drum.  (AZ/DC-S-YNYN-M199)
                                   B-24

-------
     $100 member's fee (required), $15 three boxes at $5 each (required),
 $11 per cartridge.  Each cartridge will average 11 pounds, 9 pounds new:
 11-9=2 pounds of dirt, oil, grease, etc., etc.  We cook and strip perc
 from same.  Two pounds at $5.50 per pound for dirt-oil-grease to be hauled
 away per cartridge.   [Re 3] Only one in this area.  (TN/DC-U-YNYN-M714)

     Very expensive.  For all practical purposes, there is only one
 company.  No chance to select or compare prices.  (CA/DC-U-YNYN-M705)

     My hauler charges $11 to pick up filter cartridges; that is $11 for
 each filter, and I think it is much too high.  I sure hope somebody comes
 up with a better way to handle filters, before it's too late for me.
 (AZ/DC-U-YNYN-M701)

     Appears that the cost is very high as it costs more to dispose as to
 purchase it new.  [Re 3] Only one firm to choose from.  [Re 5] How do you
 know when you have only one to choose from?  (IA/DC-S-YNYN-M702)

     [Re 5] Yes and No:  $45 per 15 gallon drum!  (UT/DC-U-YNYX-M696)

     HAULER'S PRICES KEEP GOING UP.  They have been given a license to
 steal.  (KS/DC-S-YNYN-M690)

     New charges, escalating charges, minimum charges.  No longer picks
 up when needed, but comes every so often whether or not we have anything
 since we must pay anyway.  (GA/DC-U-YYNN-M684)

     Cost to haul three jumbo filters:  1st filter $40, next two filters
 (2 @ $22/ea.) $44, use of three barrels (@ $5/ea.) $15 = $99.  (PA/DC-U-
 YNYN-M677)

     Not until January of 1987 were pickups reliable.  Hauler's prices
 too high, especially since we recover 99% of perc from our cartridges and
 still bottom waste.  (IL/DC-U-YNYN-M661)

     [Transporter X].  (KY/DC-U-YNNN-M653)

     Disposal of antifreeze is too expensive.  (CA/AM-S-YYYY-M565)

     [Re 5] Ridiculously high.  (IN/AM-U-YNYN-M520)

     This company won't pay for disposal.  (OH/AM-U-YYYN-M464)

     They used to pay us, now we pay them!  Do you think the average one-
man shop is going to pay someone?  No Way!!!  (PA/AM-U-YNNN-M423)

     We are very small, probably less than ten gallons per month; have  to
 pay to have it hauled.  (IA/DC-U-YNNN-M349)
                                   B-25

-------
     We are a very small generator and are forced to pay an annual fee,
regardless of amount we generate.  (NY/DC-U-YNYN-M351)

     $40 per month, when we usually have approximately ten gallons, does
seem high.  It is costing in excess of $12 per cartridge.  That also
seems high.  Special pickups at $85 is a considerable expense, one we did
not have before.  (PA/DC-U-YNYN-M320)

     Prices continue to rise; could become factor whether to stay in
business or not. (NC/DC-U-YNYN-M321)

     There is only one firm available in my market.  The hauler keeps
trying to sell me other very expensive services.  I expect that other
prices will go up soon.  [Re 5] Much too expensive.  (OH/DC-U-YNYN-M310)

     Hauler will not pick up all waste at one time without charging
substantially more; then they also charge the same amount when there is
no waste to pick up.   [Transporter X].  (MD/DC-U-YNYN-M296)

      Cost now at $1,500 a month and I just received another increase.
Twelve plants involved, with seven having "0" generated from time to time.
[Transporter X] used.*  (LA/DC-0-YNNN-M284-295)

     Expensive.  (CA/DC-U-YNYN-M744)

     Pricing structure is not fair to the small generator.  (IL/DC-U-YNNN-
M740)

     [Transporter X} charges an exorbitant amount to pick up our filters -
then recycles the perc and sells it.  We have filter charges plus barrel
charges for this pickup.  We are at the mercy of the carrier as far as
charges are concerned.  (GA/DOX-YNYN-M739)

     [Transporter X] is extremely expensive for a small dry cleaner.
(NC/DC-U-YNNN-M738)

     Have to ship still bottom oil, with only trace amounts of perc in
it, as hazardous waste.  Has to be shipped to Seattle in ocean-going
container all by itself, cost $2,000.  I only generate 55 gallons over
270 days.  End cost of about $2,500 for disposal of 55 gallons of still
bottom oil with only trace amounts of perc in it.   [Re 2] Alaska.*  (AL/DC-
S-NXXX-M734)

     [Re 3] No!  No! [Re 5] No!  No!  (PA/DOS-YNYN-M733)

     [Re Transporter X] small generators are suseptible  to  upcharging by
them.  (NY/DC-S-YNYN-M731)

     Charge too much.  (CA/DC-U-YYYN-M786)


                                   B-26

-------
      In  the  last  three years  I have been with four haulers.  When pickup
 was  first  required  there  were four companies in my area.  As each one was
 bought up  or went out of  business or was forced to close because of new
 regulations  or  insurance  costs, the price has gone from $25 per drum for
 pickup to  a  cost  now of $75 per drum plus an additional charge for still
 oil  of $2  per gallon.  My costs have gone from $25 total pickup to $125
 for  the  same amount.  If  costs continue at this rate all that will happen
 is the encouragement to have  more illegal dumping.*  (CA/DC-U-YNYN-M792)

      Were  with  [Transporter X],  We thought they kept raising prices and
 were unreasonable.  Switched  to [Transporter X].  (MN/DC-U-YYYY-M783)

      We  use  jumbo cartridges:  $34.95 new cost delivered.  It cost $31.50
 to get it  hauled  off, and we  sniff them dry, powder dry.  The cartridges
 (4 jumbo)  go in the tube  at 35 Ibs. each; they only weigh 65-70 Ibs. each
 after reclaiming  and removal.  That is only 140 Ibs. of waste, but we are
 still considered more than 100 kilograms of hazardous waste.  (TX/DC-S-
 YNNN-M760)

      It  would help a lot  if we could at least dispose of our cartridges
 in regular garbage pickup if  we have them down to 5% or less perc content.
 We have  to pay  $11 for each cartridge to be hauled.  I think somebody is
 trying to  end the dry cleaning business.*  (UT/DC-S-YNYN-M753)

      Costing more to dispose  of wast than to buy original material.
 (MD/AM-U-YYNN-M6)

      $1.20/gallon paint and $1.80/gallon antifreeze.  (MD/AM-U-YNYN-M7)

      Prices  will be high  because this is a required task.  (WI/AM-S-NXXX-M15)

      [Re 5]  About the same as the others, all expensive.  (MD/AM-S-YNYX-M20)

      Between hazardous waste  and right-to-know I'd guess we will spend
 easily $15,000  in one year.   (OR/AM-S-YNYY-M34)

      To 5:   believe the price charged at the site is unreasonably high.
 (NY/AM-S-YYYN-M35)

      Expensive  - is clear out of line.  (MD/AM-S-NXNN-M42)

     Only two reliable firms.  Cost is extremely high.  Gives initiative
 to simply dump  waste.*  (MI/AM-U-YYNN-M49)

      Price of hauling keeps going up.  To get a competitive prices you
have  to spend $200-$300 for sample testing.  (CT/AM-S-YNYX-M52)

     Very expensive to comply, with margins on business down already.
 (TX/AM-S-YNNN-M54)
                                   B-27

-------
      [Re 5] $160 per drum plus the drum; our body shop has no way to
recover expense because insurance companies will not pay a hazardous
waste charge.  (OH/AM-U-YNXY-M60)

     It costs well over $200 to haul one 55-gallon drum!  (OR/AM-U-YNYN-
M61)

     Waste hauling conditions [cost] are bad now and getting worse!*
(PA/AM-YN1}N-M67)

     Bids received so far are unreasonable.  (PA/AM-S-NXXX-M70)

     Paid $550 in Janurary 1986 for two pickups in that year.  They never
picked up until February 1987.  [Transporter X] is name of company.
(TX/AM-U-YNNN-M73)

     A bit high but OK till more competition gets on line.*  (CA/AM-U-
YYYY-M1045)

     Very expensive - Not necessary - The haulers dictate the forms.
(IA/DC-U-YNYN-M1034)

     My business expenditures on hazardous waste disposal for year to
date (10 months) is $1,266.84.*  (CO/DC-U-YNYN-M1006)

     [Re 5] Pretty high.  (KY/DC-U-YNYN-M991)

     Cost approximately some price to remove filters and sludge as it
does to buy new ones.  (X/DC-U-YNYN-M192)

     No, considering they can sell the recycled solvent.  (CA/DC-S-YYYN-M1025)

     For what they're getting out of our perc the price should be lower.
(X/DC-U-YYYN-M852)

     Oil only.  Previously I was paid $25 per 1000 gallons.  Now I pay
$150 up for less than 1000 gallons.  (NC/AM-S-YNYN-M77)

     It costs me almost as much to dispose of my used cartridges as it
costs me to buy new cartridges*  I don't feel that they are  that hazardous
after I strip the perc out of them.*  (CA/DC-S-YNYN-M1073)

     His prices are probably reasonable for him but are high for a small
generator because of minimum charges.  (FL/DC-U-YNYY-M1061)

     It seems that $5 for a cardborad box to place dry spent cartridges
in is a bit overpriced and a $5 charge on a reusable drum is ridiculous.
(IL/DC-U-YNYN-M1057)
                                   B-28

-------
      $110 sign-up fee,  $5  per  15-gallon drum (I must buy the drum for $5
 to  give  to  them  to haul away), $40 per month for 0-1 drum (I pay $40 if I
 don't  have  any waste),  $45 for each drum thereafter.  My only waste is
 split  filter.  (AZ/DC-U-YNYN-M1081)

      Since  there are no hazardous waste land fills in our area, we are
 forced to ship filter cartridges, a small number per drum, at exhorbitant
 prices.  These filters  are steam stripped and carbon absorbed to 3-4
 pounds their original weight.  Any hazardous waste left would have to be
 infinitesimally  small,  but the cost is ridiculous!  I don't have any
 problems with proper hazardous disposal of still bottoms even though it is
 ridiculously expensive  in  "rural" areas.*  (UT/DC-U-YNNN-M1076)


 Equitable Pricing Uncertainty

      [Re 5] Nothing to  compare.  (X/DOU-YNYX-M158)

      [Re 5] Nothing to compare.  (X/DC-S-YNYX-M973)

      [Re 5] Nothing to  compare.  (PA/DC-U-YNYX-M920)

      [Re 5] Don't have any comparison.  (TX/DC-S-YNNX-M322)

      [Re 5] ? Don't have anything to compare with.  (TX/AM-S-YNYX-M403)

      [Re 5] What should I use to compare?  (NC/DC-U-YNYX-M642)

      [Re 5] Have nothing to compare prices to.  (LA/DC-S-YNYX-M651)

     In answer to #5, what is reasonable?  (WI/DC-S-YYYY-M671)

      [Re 3] I guess; it was arranged through our local dealer's association
in Cinncinatti.  (OH/AM-L-YYNN-M51)

     [Re 5] Who knows what is reasonable?  They both charge same price.
Anti-trust?  (NJ/AM-S-YYYX-M17)

     [Re 5] I don't know.  (NY/DC-S-YNXX-M1015)

     [Re 5] Have no way to compare.  They are better than the previous
arrangement with city sanitation.  (WA/DOU-YNXX-M751)

     We do not know what other haulers are charging, since we do not have
any other firms with a price.  Can not answer #5.  (SD/DC-S-YNYX-M756)

     [Re 5] With only one hauler, how would you know?  (OH/DC-U-YNYX-M768)

     [Re 5] What is reasonable?  (CA/DC-U-YYYX-M729)

     [Re 5] What is competitive?  (CA/DC-X-YNNX-M716)

                                   B-29

-------
     [Re 3] I guess.  It was arranged through our local dealer association
in Cinncinatti.  (OH/AM-L-YYNN-M64)

     [Re 5] Nothing to compare.  (CO/AM-U-YNNX-M820)

     [Re 5] Having no one to compare to it is hard to tell.   (CA/DC-U-
YNNY-M851)

     [Re 5] Who Knows?  (WA/DC-U-YYYX-M877)

     [Re 5] Hard to judge.  No rates to compare charges.  (NJ/DC-U-YNYX-M179)

     [Re 5] Don't know.  (NY/AM-U-YNNO-M111)

     [Re 3] Through Neighborhood Cleaners Association.  [Re 5] Not sure.
(CT/DC-0-YXYX-Ml12)

     [Re 5] ? (NJ/DC-U-YNYX-M119)

     [Re 5] No way to tell.  (NY/DC-U-YNXX-M135)

     [Re 5] ? (M1/DC-U-YXYX-MH3)

     [Re 5] ? (TX/AM-U-YYYX-M408)

     [Re 5] ? (PA/AM-U-YYYX-M439)

     [Re 5] Unkown.  (OR/AM-S-YNNX-M57)

     [Re 5] ? (IN/AM-0-YNNX-M63)

     [Re 5] ? (OR/AM-U-YNNX-M75)

     [Re 5] ? (NH/DC-S-YNYX-M1000)
                                   B-30

-------
                        TRANSPORTER  SERVICE RENDERED


      [Transporter X]  is very  professional and precise in  their work.  (CA/DC-S-
 YYYY-M896)

      A serious  conflict of  interest exists since the hauler has recently
 established  a product  line  for  sale to  our industry.  If  we buy their
 chemicals and filter  products we  can  receive discounts on waste disposal.
 Their route  men receive commissions on  sales and consequently provide
 better service  to those customers who buy their products.*  (VA/DC-S-YNNN-
 M1060) ,

      [Transporter X]  does a fine job.   Customer service is prompt and
 courteous.   Mr.  [   ],  who  picks  up and services our plant is a very
 fine  young man.  (IL/DC-U-YNYY-M233)

      Hauler's service  very  satisfactory from our standpoint.  (VA/DC-S-
 YNYY-M676)

      Our average per  plant  is 230 pounds per month.  We have nine plants.
 We  use  [Transporter X].  There  are no other good firms.   (MO/DC-S-YNYN-
 299-306)

      Pickup  is made on  the  date promised.  [Transporter X] is our hauler.
 (MN/DC-S-YNYN-M910)

      Currently  using  [Transporter X]; no problems with service.   [Re 5]
 Have  no one  else to compare.*  (PA/DC-S-YNYX-M922)

      None; use  [Transporter X].   (NY/DC-S-YYYY-M924)
                                        /
      Waste hauling conditions are bad now and getting worse!
 (PA/AM-U-YNNN-M6 7)

      [Transporter X] -  Terrible service.  (MA/DC-U-YNNX-M694)

      No one seems to be sure  what they  are doing and what form goes where!
KIS - Keep It Simple!  Please!*  (NY/AM-L-YNNN-M81)

     Everyone we have dealt with is very arrogant.  (FL/DC-U-YNNN-M104)

     Carriers will attempt  to haul off  all waste (including those not
classified as hazardous - cartridges  from petroleum machines) and charge
me for  them.  This is in my mind a misrepresentation of the law.  (TX/DC-
U-YNYN-M784)

      [Transporter X] used.  [Re 4] I've been cited once due to his
(hauler's) failure.*   (LA/DC-0-YNNN-M284-295)
                                   B-31

-------
     Has no drum to leave when picks up and may go weeks before brings
one.  Nowhere to hold waste.  [Transporter X] is hauler.  (FL/DC-U-YNNN-
M207)

     Hauler records weight of filter cartridge as a standard weight
regardless if much of the solvent has been removed.  This could run me
over 100 kg. in one month if in that month 1 have unusual maintenance/repair
that may increase waste solvent disposal.  (WA/DC-U-YNNY-M763)

     We find that the [Transporter X's] manifested weights and actual
weights differ greatly.  We presently utilize the Puritan unit to strip
our cartridges and in no way does the actural weight compare to the
[Transporter X's] "standard" weight.  This inaccuracy shows that I am
producing more waste than I really am.  (PA/DC-U-YNNN-M345)

     They charge for drums, but drums they bring are always rusted or
crunched.  They are not safe for containing hazardous waste, in our point
of view.  (MD/DC-U-YNYN-M237)

     Storage containers are made of cardboard.  [Transporter X] first
suggested I store the cartridges (spent) in our boiler room next to our
gas burners.  The representative was completely unaware of any natural
gas/perc interaction problems.  Then he suggested I keep the cartridges
in my finishing room where the cartridges would be near my employees.
[Transporter X] is the largest waste disposal agency in the nation.  They
have not educated their representatives well enough.  (VA/DOS-YNYN-M925)

     Dirty cans.  Lids don't fit.  Lock rings missing.  Hauler charges
$40 per month regardless if we have any waste to pick up or not.
Occasionally we hold half a shipment till the next pickup to make it cost
effective.*  (IL/DC-U-YNNN-M996)

     Hauler has substituted cardboard containers for drums - with heavy
plastic liner - for cartridge filters.  This creates a space problem
because they can not be placed outside in rainy weather, etc.  (GA/DC-
S/YNNY-M252)

     [Transporter X] was our only choice.  They come every month whether
we need it or not - and charge for it!  (1) They have changed  their pricing
structure three times in two years.  (2) They have been unusually  "pushy"
about selling us recycled perc and filters.  (3) They currently are using
a cardboard box with a liner to pick up used cartridges.  The  county
health and hazard waste department isn't very pleased about this.*  (MO/DC-
S-YNYN-M335)

     Containers are delivered bearing waste from previous use, ill-fitted
lids, and without labels.  Confirmation of arrival at destination  is
sometimes not returned.  (VA/DC-0-YNNN-M893)
                                   B-32

-------
     We are not getting our copy back from hauler saying that the job was
 completed.  (AZ/DC-0-YNYN-M758)

     Changed haulers; reallability was questionable on what was happening
 to waste thinners and prices have increased five times.*  (OH/AM-S-YYNN-
 M458)

     Prices and procedures always changing.  No competition.*  (GA/DC-U-
 YNNN-M917)

     We feel that because of the monopoly that exists in our area (Northwest
 Indiana)  our hauler is taking advantage of us with high prices and poor
 service.*  (IN/DC-S-YNYN-M322)

     My hauler's pickup schedule is as reliable as the weatherman's
 forecast.  (SC/DC-S-YNNN-M658)

     Do not pick up on scheduled dates.  Have to call them to pick up.
 (CA/DC-U-YYNY-M801)

     Not always reliable - Question 4 is really yes and no.  (MA/DC-U-
 YNYN-M766)

     [Transporter X] is usually one to two weeks behind.  (TX/DC-U-YNNY-
 M727)

     [Transporter X] is too high and very unreliable.  They have no
 competition, they charge what they want, and they come when they want.*
 (NC/DC-U-YNNN-M163)

     [Re 4] This is biggest problem.  (ME/DC-S-YYNX-M799)

     Sometimes the company has to be called as many as three times to get
 a pickup.  (TN/DC-U-YNNY-M703)

     Phone calls to get pick ups.  (FL/DC-S-YNYN-M644)

     [Re 4] Always too soon.  (NJ/AM-U-NNNN-M482)

     [Re 1] Only motor oil.  (MI/AM-S-YYYY-M509)

     Changing present pickup times.  (MN/DC-S-YYYN-M311)

     Pickups are scheduled on the last day of the month, at hauler's
option.  He will charge extra to make a special trip.  Usually they will
come a day or two before a filter change.  It takes another day or two  to
cook the cleaning fluid out of the filters.  The filters then remain  in
the plant for most of a month waiting to be picked up.  My company spends
 thousand of dollars complying with hazardous waste disposal while numerous
other companies simply throw their hazardous waste in the dumpster.   Who
is enforcing the law?*  (TX/DC-U-YNNN-M209)

                                   B-33

-------
      [Re 4] Not scheduled.  (TX/AM-U-YNXY-M367)

      Infrequent pickup - nonhazardous waste only.  (TX/AM-0-YXNN-M369)

      Recently they have been more reliable on a schedule basis than they
have  in the past.  But you have to be a large generator to sustain a
reliable servicing relationship with [Transporter X].  (NY/DC-S-YNYN-
M731)

      Storage of drums since pickup by [Transporter X] is not as scheduled.
(NC/DC-U-YNNN-M738)

      Sometimes I have to call, but they do come.  (NE/DC-S-YNXN-M754)

      [Re 4] Comes on an as needed basis.  (AR/DC-U-YYYX-M761)

      Very unreliable in picking up.  Very unorgainzed when calling about
any question or problems we have.  (MD/DC-S-YNNN-M242)

      1 have had three different companies in the past year due to government
regulations.  Two companies have stopped servicing dry cleaners.  The
company I have now has a pickup every four weeks but never keeps to their
own schedule.  (NY/DC-U-YYNX-M138)

      [Re 4] For most part.  (OH/AM-U-YNXN-M60)

      Irregular in pickup.  Only one in the State of New Mexico and they
won't come to Farmington.   We have to get one out of Colorado.*  (NM/AM-
U-YNNN-M76.)

      [Re 4] No way to tell; sometimes yes - sometimes no.  (NY/DC-U-YNXX-
M135)

     We need a pickup every six weeks.  Sometimes we don't have any after
one month but can't go two months.  [Re 4] Yes, but not convenient.
(CA/DC-U-YNYN-M9 7 7)

     Hauler's schedule doesn't fit my schedule.  (UT/DC-U-YNYN-M887)

      [Re 4] Only recently.  (NC/DC-U-YNYY-M151)

     Have contract with  [Transporter X].  Recently they changed their
method of pickup which, in my opinion, increased their cost  and lowers
their level of service.*   (MA/DC-U-YYNY-M930)

     Constant changes of prices, how pickups will be handled,  and what  is
required of me.*  (IL/DC-U-YNYN-M932)
                                    B-34

-------
      [They] say they can only pick up two containers a month.  We change
filters three months ago.  They are making up our rules, since only firm
in town picking up.  We are actually storing hazardous waste because they
can't pick it all up at one time.  They are very bad, very expensive,
very  undependable.  Don't like this, but have to have it hauled off
because I want to do right by the law.  Bad situation.  [Re 3] [Transporter
X] only - bad news.  [Re 4] Never know.  [Re 5] Absolutely not - very
unreasonable.*  (TX/DC-U-YNNN-M164)

      I must call transporter when our tank is full.  (OH/AM-S-YNNY-M26)

      West Virginia Auto Dealers Association found reliable company to do
these forms.  (WV/AM-S-YYYY-M33)

      [Transporter X], first hauler, has drums which they will not pick
up.  We are having to store them, which is inconvenient in small stores.
(CA/DC-S-YNYX-M805)

      [Re 4] Yes, once we got our EPA number.  Before that we had a big
problem because a company went out of business and left us hanging with
wastes on hand.*  (CA/DC-U-YNYY-M1002)

      It's becoming increasingly difficult for him to remain in business.
We won't know where to go next!!  (PA/AM-S-YNYN-M36)

     Our only waste is engine oil and antifreeze.  (CA/AM-U-NXXX-M593)

     No collection for waste other than oil.  (CO/AM-U-YNNY-M551)

      [Re 1] Used motor oil.  (PA/AM-U-NXXX-M432)

      [Re 1] Old engine oil.  (TX/AM-U-YNNN-M395)

     I call them when I need them.  (PA/AM-U-YNYN-M426)

     Our paint supplier picks up waste and recycles it for our use.
(CO/AM-U-NXXX-M550)
                                   B-35

-------
                          COMPLIANCE/ENFORCEMENT
     We have a very small plant.  We only need  [Transporter X] to pickup
our filters every six weeks.  They come once a month whether we need them
to stop or not.  For this we are charged $40 each visit.  I have written
to protest this type of charging when we don't need them to stop by.
Their man comes to the door - says "hi," asks if we need pick up.  We say
no.  He leaves and sends a bill for $40.  I feel like we are being robbed.
If I protest, they could refuse to service us at all and then we would be
in trouble with EPA.  Our government has created a monster.  It's like
paying protection money.  It's NOT FAIR.* (WI/DC-U-YNYN-M657)

     Pick up situation here is out of control.  [Transporter X] has law
on their side, has a monopoly, is charging exorbitant prices, and is
using coercive tactics.  Two of largest cleaners here have recently dumped
them; what they are doing with waste, I don't know.  Disposal must be on
a practical basis or dumping/law breaking will become rampant.  They want
$40/month with or without pickup need plus $5-$6 for new drum each trip.
Will reduce pickup by $3 and waive drum charge if we buy their products.
Products are inferior to Puritan, which we have been using.  EPA should
call moratorium on law NOW until solution is provided.* (NC/DC-S-YNYN-
T216)

     I think the government should be responsible for waste.  What is
their purpose?  They should help us.  We are not making millions of
dollars selling chemicals.  Chemical companies make these poisons, not
me.  The price to dispose is a joke.  I'm responsible for producing
hazardous wastes?  I did not manufacture these chemicals, a big chemical
company did.  I thought the government was here to help us.  The poor pay
as the rich play.  (FL/AM-U-NNXN-M542)

     Upon everthing else the government charges us for, this is just
another one.  People throw more waste down their sinks in a single city
block in a week than cleaners generate in a year.  It's ridiculous what
they want us to do.  (TX/DC-U-YYYN-M226)

     So many taxes and regulations, there is not much time left to make a
profit.  (AR/AM-S-YYYY-M619)

     In the last three years I have been with four haulers.  When pickup
was first required there were four companies in my area.  As each one was
bought up or went out of business or was forced to close because of  new
regulations or insurance costs, ... my costs have gone from  $25 total
pickup to $125 for the same amount. . .If costs continue at this rate all
that will happen is the encouragement of more illegal dumping.*  (CA/DC-U-
YNYN-M792)

     Since the hazardous waste guidelines have  changed over the  past 2-3
years, all the previous waste haulers have dropped out of this area  of
business.* (MI/DC-U-YNNN-M793)

                                   B-36

-------
     Not enough  competition  to bring rates down.  New EPA guidelines have
 forced many  carriers out of  business.  Remaining companies can charge
 whatever they  please.  There should be some form of controls to establish
 reasonable rates.*  (CA/DC-U-YNYN-M978)

     No one  seems to know what the total requirements are.* (CA/DC-U-YNNY-
 M868)

     Knowledge of what is waste.  (FL/AM-S-YNNN-M815)

     No one  seems to be sure what they are doing and what form goes where!
 KIS  = Keep It  Simple! Please!* (NY/AM-L-YNNN-M81)

     The hazardous  waste department has trouble answering antifreeze
 matters,  (TX/AM-U-YYYY-M411)

     Total confusion by everyone as to what constitutes hazardous waste.
 (NY/AM-S-YNNN-M43)

     We need more direction  as to what is legal and what to do with new
 hazardous materials on list.  (MD/AM-S-YNYO-M20)

     It is our understanding that all used oils (motor oil and transmission
 fluid) are considered "hazardous waste."  (MI/AM-S-YNYY-M353)

     Need quidelines for selecting hauler.  Outline other practical ways
 of disposing and how long they will be legal.  (IN/AM-U-NNXN-M521)

     It would  be nice to have a set of rules and regulations in manual
 form for all car dealers.  Sure beats DER surprises.  (FL/AM-L-YYYY-M31)

     Cannot get consistent answers on what wastes I generate are hazardous.
 In particular, coolant. (TX/AM-U-NXXX-M656)

     Is old antifreeze from  car radiators considered a hazardous waste?
What about old car  battery storage, pending sale or core return?  (OH/AM-
U-YYYY-M628)

     We generate less than 110 kg per month.   By law EPA530-SW86-019 we
are a conditionally exempt small quantity generator.  But my hauler asked
 us to apply for EPA number,  manifest	as we are a large generator.*
 (WA/DC-U-YNNN-M747)

     I have not received an  EPA ID number though I applied over nine
months ago.  (TX/DC-U-YNYN-M784)

     We are being charged $5 for the drums, which are used twice then
discarded by our hauling firm.  We feel EPA's  ruling on this should be
reduced somewhat.*  (IA/DOU-YNYN-M968)
                                   B-37

-------
     Pacific Coast Lacger classifies "waste" as raw material for open
products, getting around (legally!) the hazard issue.  (CA/AM-X-YNYY-M600)

     Why are quick oil change kits sold at the stores?  We all know they
go in the regular trash.  (CA/AM-U-YNYN-M609)

     Have dry cleaning located at inside of GP Building.  Waste generated
by dry cleaning shop is 10-12 gallons a month.  According to law (EPA
regulations), less than 220 pounds or 1/2 of 55 gallon drum won't be
necessary to report.  Let me know; do I have to report or not?  Dry
cleaning fluid is vaclene, not perchloroethylene, I wait response. (GA/DC-
U-NXXX-M1018)

     Recycling is not the answer!  What do you do with all the thinner?
(MN/AM-U-NXXX-M499)

     My difficulty has been in getting my EPA identification number
changed to a proper Arizona number.  I have contacted EPA numerous times
with no luck.  (AZ/DC-U-YNYY-M806)

     We use waste burners for all except antifreeze (not burnable).
(NY/AM-U-NXNX-M55)

     [Re 1] Oil.  [Re 5] Self.  (X/AM-X-NNXX-M1047)

     We moved into this building and acquired the equipment October 1986.
Since we do only museum quality textiles and costumes, our poundage is
very small.  It will be quite awhile before we will have any waste to
dispose of.  (X/DC-U-NXXX-M1001)

     I cook down my filters and when I change them I do not exceed 120
pounds.   (MT/DC-U-NXXX-M662)

     [Re 2] We're getting a recycler (ordered).  (MI/AM-U-NXXX-M506)

     Paperwork!  We don't keep records.* (OH/AM-U-YYY-M460)

     [Re 2] Previously but not at present.  (NJ-U-NNNN-M482)

     We comply thoroughly with all guidelines concerning our wastes, but
the EPA has Co license or provide alternative to open this area of our
industry for more competitive rates for disposal.  Although we will
continue to handle our waste disposal according to the laws no matter
what the cost, some smaller cleaners with the depressed economy may have
to resort to other means of disposing their wastes if something isn't
done about the ever increasing costs, and this will snowball into  increased
costs to the government by having to regulate and monitor the proper
disposal of these wastes.  Aside from the fact that I think everybody
wants their children to be able to drink the water and enjoy our  lakes,
streams, and rivers in this great country without being poisoned.  Thank
you for lending an ear for this growing problem.* (TX/DC-S-YNYN-M211)

                                   B-38

-------
      This  problem of waste disposal and liability has become very difficult.
 (ND/AM-S-YNNN-M41)

      The question of eternal liability is heavy on our minds.  It is
 difficult  for me to understand how, when we release and pay for waste
 disposal to a licensed firm, that we might be held partially responsible
 for its cleanup many years later if it were not disposed of properly.
 After it leaves our plant we have no control and have no choice in who we
 hire  to dispoae of it.  (TX/DC-U-YNNN-M689)

      Our insurance company said we have no coverage for spills or hauling.
 (MD/AM-S-YNYX-M20)

      Insurance is high.* (TX/AM-U-YNYN-T953)

      Lack  of enforcement.  I'm complying the best I know how, but other
 cleaners are doing absolutely nothing at all and getting away with it.
 (WI/DC-S-YNNN-M3)

      I see cleaners throwing in garbage pails instead of having proper
 pickups.   I called EPA and local health department to show the filters
 just  left  outside back doors for months and no one ever comes or does
 anything about violators.  Violators should be written about in local
 papers and driven out of business!!  (NY/DC-0-YYYY-M95)

      I am  located in New Orleans, LA.  The price has increased dramatically
 lately.  I understand the reason for this is because most plants are just
 putting their hazardous waste in dumpsters instead of using proper disposal
 methods covered by Louisiana law.  This loss of business has run the cost
 of my hazardous waste hauler and recycler because of the loss of distributing
 the cost.  Even though I do not cheat, I understand that most cleaners
 are breaking the law and getting away with it.* (LA/DG-U-YNYN-M647)

     Better do something about all the hazardous materials that are used
 in the auto body shops*  Many of the materials are washed down the drains
and blown  into the air.  Some shops are filled with the fumes and men
must breath the overspray.  About our used thinners:  we are storing in
drum and throwing some in the dumpster.  I know a lot of shops are throwing
the used paint and thinners back of the shops unto the ground.  Most
shops do not belong to an auto body association and don't know the law on
hazardous  waste.  (PA/AM-X-XXXX-M640)

     Changed haulers:  reliability was questionably on what was happening
to waste thinners and prices have increased five times.* (OH/AM-S-YYNN-M458)

     When  there is only one firm supplying a service, such as  [Transporter
X], then our prices will never be competitive.  This is creating an even
bigger problem than before [Tranporter X], since some dry cleaners may
dispose of waste in an illegal manner.* (SC/DC-U-YNYN-M229)
                                   B-39

-------
     Pickups are scheduled on the last day of the month, at hauler's
option.  He will charge extra to make a special trip.  Usually they will
come a day or two before a filter change.  It take another day or two to
cook the cleaning fluid out of the filters.  The filters then remain in
the plant for most of a month waiting to be picked up.  My company spends
thousands of dollars complying with hazardous waste disposal while numerous
other companies simply throw their hazardous waste in the dumpster.  Who
is enforcing the law?* (TX/DC-U-YNNN-M209)

     If costs continue at this rate all that will happen is the encouragement
to have more illegal dumping.* (CA/DC-U-YNYN-M792)

     We are spending money here and many of our competitors are not.
(CT/DC-U-YNYN-M107)

     Other cleaners place their waste in with their other trash.  Meanwhile
the cost of the time of paperwork and pickup must be reflected in my
prices.  This places a burden on me and makes it difficult to do business
in the New York City area.* (NY/DC-U-YNNN-M109)

     No way of verifying handling of waste. . .Pay companies to properly
dispose of waste and then they take them to the regular dumps.* (CA/DC-S-
YNYN-M891)

     Our information is that all of the available haulers have been cited
for improper procedures.  (MD/DC-0-YYNN-M5)

     Have little confidence that disposal procedures are being properly
followed.  (MI/AM-S-YNNN-M18)

     Only two reliable firms.  Cost is extremely high.  Gives initiative
to simply dump waste.* (MI/AM-U-YYNN-M49)

     How do I determine if these hauling companies are disposing of their
materials as they tell me they are?  (SC/AM-S-YNNN-M79)
                                    B-40

-------
                               REGULATIONS

      We have heard  that  the EPA Administrator may change the classification
 of  our dry  cleaning solvent (perchloroethylene) from a "C" to "B" even
 though the  Science  Advisory Board of the EPA found that the evidence
 presented by the  Cancer  Assessment Group did not warrent a change in
 classification.   If the  classification was changed, that would be a real
 problem.  Then  the  survey would be meaningless, because dry cleaners
 could not meet  the  new standards of disposal.* (UT/DC-S-YNYN-M813)

      Our legislators may put us out of business with their idea of perc
 classification.   Then we can all wear disposable garmets.* (MI/DC-U-YNYX-
 M824)

      Possibility  of perc classification from "possible" to "probable"
 carcinogen  would  cause serious problems and lead to the closing of our
 business of dry cleaning.  (ME/DC-S-YYNX-M799)

      I started at age 26 in the dry cleaning business; most of this time
 around a transfer unit very low milage.  My age is 65 and no indication
 of  any perc related disease or cancer.  How many of my friends have been
 dead  for years  that worked outside this industry?  All.  How can perc be
 carcinogous?  I still work a transfer machine.  Granted, I don't drink
 the stuff;  I just inhale it five days a week.  (CA/DC-U-YNYY-M796)

      The EPA:  Why  is it that the EPA wants to eliminate perchloroethylene
 use in the  United States when every study they have funded, no matter how
 biased it is in their favor, has shown that perc does not cause cancer.
 The EPA's actions are arbitrary, capricious, and frivolous.  (TX/DC-U-
 YNNY-M728)

      From the conclusions reached by the "Science Advisory Board's" study
 on  perc, I  feel that the EPA is unjustified in its degree of regulation
 on  perc. (SC/DC-S-YNNN-M658)

      Perc as a class "B" carcinogen is wrong!  It should be rated "C."
 Before this is passed, further studies should be done.  (NC/DC-U-YNYX-M642)

      If EPA changes the  class of perc from "possible" carcinogen to
 "probable"  carcinogen the resulting regulations will probably get so
 unreasonable that most dry cleaners will not be able to operate.  (TN/DC-
 S-YYYY-M239)

      If any further regulation is proposed (perc probable carcinogen)
 please inform us well in advance; after all, this is our livelihood.
 Please send information  now if available.  The undersigned has been
subjected to much liquid and perc gas during the past 25 years.  I am now
 67 years of age.  I smoke 3 packs of cigarettes daily.  Mo cancer as yet.
 I believe myself much, much stronger than a mouse and challenge any
government  bureaucrat to arm wrestling.

     Other alternatives  for conditionally exempt generators are not
clearly set forth.  Perc should stay Class C.  (NC/DC-U-YNYN-T1004)

                                   B-41

-------
     I appreciate this opportunity to express my views on the requirements
of hazardous waste treatment/removal.  As with any other waste generator,
the new laws have had a major impact with my company.  I consider Imy
firm] to be one of the larger plants in the country, we clean an average
of 10,000 pounds per week.  We have contracted [Transporter X] to haul
our hazardous waste for us, and have not experienced many problems with
scheduling, service, or even price, with one exception.  [Transporter X]
charges $35 per 15 gallon drum of still bottom residue, a price I consider
reasonable.  What I strongly object to is the charge for hauling away
used filter cartridges.  We own a Puritan 4000 SRS recovery system used
only for the recovery of solvent from used filter cartridges.  We get an
average of 30 gallons of solvent out of these 21 cartridges, and I feel
that the Perc content is well below any reasonable allowance set by EPA.
I feel we should be allowed to throw them away as junk (metal and paper)
instead of paying $11.00 each to have them hauled away.  This charge has
doubled my cost of filtration in the last 3 years.
     [Transporter X] has developed their own filters which they sell at a
reasonable market rate and give a discount of $3.00 for each cartridge
when they are disposed and hauled away.  I refuse to use their cartridge
because the are not near the quality, in my estimation, as the Puritan
filters are.  After trying one set of the [Transporter X] filters in the
exact same conditions as the Puritan filters, [Transporter X's] filters
completely fell apart and collapsed in the filter housing.  I feel very
fortunate that I did not pay out a lot of customer claims for ruined
garments from that filter system.  A proper filter system is a must for a
quality drycleaner, and our customers expect quality.
     To summarize, I feel that any drycleaner that uses a Puritan 4000
SRS system, or any other system that can strip cartridges as efficiently,
should be able to dispose of the cartridges themselves, without paying
someone $11.00 each for disposal.  The EPA should randomly select companies
and check to ensure proper limits are being adhered to as far as the
maximum allowable residue left in the cartridge.  Again, thank-you for
giving me this chance to voice my opinion, and I hope you will consider
this carefully.  I believe stripping cartridges properly is a logical
step in helping to keep the costs of hazardous waste disposal under
control without damaging the environment.  If you can find the time, I
urge you to talk to other cleaners who use the Puritan 4000 SRS, as well
as the engineers of the system, and others in the industry.  I think
you'll find they will convey the same message.* (IA/DC-S-YNYN-M762)

     I have spent $1,000 on a cooker that brings the cleaning fluid -
"perc" - down to less than 2% surrounded by the filter's bed of clay and
carbon which makes it NOT a danger to the environment.  Some states say
it is fine for normal trash disposal and some states say it is not.
Laboratory tests say the cooked filters are not a danger and the law
should allow cooked filters to be disposed of with normal trash.  (CO/DC-
U-YNYN-M323)
                                   B-42

-------
      I  would  buy  a  purging  unit,  reducing solvent content in filters to
 less  than  one percent,  if less  than one percent would be considered non-
 hazardous,  as it  is in  three  states.  As the present law stands, there is
 no  incentive  to purchase this equipment.  My business expenditure on
 hazardous  waste disposal for  year to date (10 months) is $1,266.84,
 (CO/DC-U-YNYN-M1006)

      One 15-gallon  drum 3/4 full  each month, still residue 14 cartidges
 approximately each  3 months.  Cartridges are forced-air dryed to almost
 original weight over 30-day period.  Fumes  or vapor picked up by sniffer
 charcoal reclaimer.  (CO/DC-U-YNYN-M749)

      We are able  to cook out  our  cartridges to minimum perc remains and
 still have  to use a hauler  to dispose of them.  Costs are very high and
 lack  of competition gives us  no choice.* (CO/DC-S-YNYN-M707)

      We get out the waste and still have to pay.  Others don't even strip
 their cartridges.*  (IN/DC-S-YNYN-M191)

      We cook  our  cartidges  Puritan and have very little waste.  We think
 this  pickup,  [Transporter X], is  a waste of money.  It costs $11 each to
 have  these  [filters] hauled away.  We could put them in our trash for
 nothing.  We  have 21 a  month.   Now the consumer pays in higher prices.*
 (1N/DC-U-YNXX-M911)

      Please push  for disposal of  purged filters as non-hazardous waste.*
 (CA/DC-S-YNXN-M902)

      Charges  for  cartridge  filter pickup are unreasonable and consideration
 should  be given to  revising the standards for filters.* (GA/DC-U-YNYN-M809)

      It would  help  a lot if we  could at least dispose of our cartridges
 in  regular  garbage  pickup if we have them down to 5% or less perc content.
 We  have to  pay $11  for  each cartridge to be hauled.  I think somebody is
 trying  to end  the dry cleaning  business.*   (UT/DC-S-YNYN- M753)

      After  cartridges are stripped there is so little waste left they
 should  be disposed  of in regular  land fill  dump.  Stripping amounts to 6-8
 hours,  after which  the  core is  clean enough to absorb impurities again.
 (FL/DC-U-YNYY-M338)

      I  have a  dry-to-dry 30 pound dry cleaner, Puritan filters, and
 Puritan still  that  strips perc  from cartridges.  My waste is mostly the
 used  cartridges.  I change  them about three times a year, and only need
 the muck picked up  once a year  but can only keep it 180 days.  I need to
 have  longer to hold the muck, or  they need  to compensate for less than a
 full  drum.   [Re 3] We need  a choice!  We have none.* (MS/DC-0-YNYN-M1030)

      I cannot  see why cleaners  cannot cook  down our cartridges and then
 throw them  away.  We could  get  our solvent  back and present little danger
 to  the community/public.  Chemical companies dispose of chemicals in our
 waterways daily, as I have  observed firsthand as a member of the USCG (R)
 Port of Houston.  Our cooked cartridges cannot amount to 1/10 of the
garbage they discharge.  (TX/DC-U-YNYY-M132)

                                   B-43

-------
     EPA should approve a machine that will strip filters for regular
land disposal.  (CO/DC-U-YNNN-M96)

     Should be permitted to dispose of filter cartridges in dumpster if
purged by Puritan still and subsequently air dryed in a Hoyt Cartridge-
Miser (cabinet connected to sniffer) for a month.  This should reduce
perc to acceptable levels.  (CA/DC-U-YYYN-M862)

     Properly purged cartridges leaving less than one percent perchloroethylene
should be disposed of in local land fills.  This would cut the present
high cost to dry cleaners and not damage the environment.  That choice is
not available now.  Therefore we are at the mercy of one hazardous waste
hauler.* (WY/DC-S-YNYN-M257)

     Have to ship still bottom oil, with only trace amounts of perc in it
as hazardous waste.  Has to be shipped to Seattle in ocean-going container
all by itself, cost $2,000.  I only generate 55 gallons over 270 days.
End cost of about $2,500 for disposal of 55 gallons of still bottom oil
with only trace amounts of perc in it.  [Re 2] Alaska.* (AK/DC-S-NXXX-M734)

     [Transporter X] will probably pull out of Washington state if Puritan-
type cartridge strippers are OKed for land fill.* (WA/DC-U-YXYY-M967)

     Using Dayton Crystal Clear Filter - No changing of cartridges.
[Re 2] When called for still residue.  (CA/DC-0-YXXX-M752)

     Our tested waste is 0.005% [after] cook downs.  (MI/DC-U-NXXX-M683)

     They got us over a barrel.  With no competition in a situation which
we must obey, the government should regulate prices, or allow us to use
stripping'machines to do a lot of the work ourselves.* (PA/DC-U-YNYN-M710)

     Tend to blame government for this non-competitive environment.*  (MD/
DC-U-YNYN-T979)

     $40 per month, actually $100 per month, or about original of filters
for pickup.  Am pressured to purchase from pickup.  Am unhappy with
government for this situation.* (MD/DC-U-YNYN-T1003)

     Since the majority of us have only one choice for hauling waste,  I
feel that these people should be regulated - similar to phone and utility
companies.* (CO/DC-S-YNNN-M665)

     Outrageous rules and regulations for the small businessman.  Example:
contingency for emergency procedures - familiarize hospitals - make
arrangements with hospitals about waste - drills with employees and local
authorities.  These are totally unreasonable and impossible  to follow.   I
am begging you, please STOP!  I feel like I am in Russia.   I am afraid  to
give you my name.  I never felt like this before.  I guess Big Brother
is watching us.  Thank you Mr. Florio.  He will  never get my vote.
Anonymous.  (NY/DC-U-YNNN-M120)

                                   B-44

-------
      It  hurts  to think  that  we  all  pay  taxes  so  regulatory agencies like
 EPA,  OSHA,  etc. , can  regulate us  right  out  of business.  I employ 46
 people and  at  this  point  I would  just as  soon sell out and let someone
 else  worry  about hazardous wastes,  a ban  on a solvent that 82% of all
 drycleaners use, etc.   (TX/DC-U-YNNN-M129)

      Pretty soon everthing will be  a hazardous waste, i.e., waste oil,
 thinners, paint, tires, batteries.  Where does it stop?  (MA/AM-S-YYNN-M130)

      REGULATION  - TOO MUCH/TOO  FAST.  Give  our industry  time to develop
 the technology to deal  with  this  problem.   (KS/DC-S-YNYN-M690)

      Disposal  of hazardous waste  is too large and serious a problem to do
 more  than pay  "lip  service"  to  environmental  problems.   (MA/DC-0-YNNN-M121)

      If  the government  requires us  to haul  off the filters, we should at
 least have  some  competitive  hauling companies in Kentucky.* (KY/DC-S-YNYN-
 M180)

      I have had  three different companies in  the past year due to government
 regulations.   Two companies  have  stopped  servicing dry cleaners.* (NY/DC-
 U-YYNX-M138)

      We  feel our industry is being  unjustly penalized for hazardous waste,
 based upon  dollar of  volume  (retail) and  amount  of participate or hazardous
 waste incurred.   I  think  the evaluation formula  should be reviewed and
 allow some  knowledgable cleaners  to participate  in decisions. (WA/DC-U-
 YNXX-M75)

      Problem is:  There is no competition in  the hauler-pickup firms.
 Only  one company is available.  He  sets his own  terms in regard to prices,
 etc.   We need  some  kind of government agency  to  oversee  the pricing of
 the hauling service since there is  no competition.*  (0/DC-S-YNYN-M266)

      The problem is the government:  EPA.   It's  a little ridiculous
 picking here,  picking there, don't  know how to earn  all  that money we are
 paying them.   Look, smell, breath all the damn cars  on the streets, and
 they  have to pick on dry  cleaners.  Every day gas stations accidently
 spill  oil down their drives  to city sewers.   And dumpers* AHs are all
 over  town - back  yards.  Just take  the  buses  on  the  street, don't count
 cars  - it's enough  to kill anyone.  Why isn't the EPA doing something
 about  that?  The  money allocated  increases  every year and they feel guilty
 not earning it.   Get off our "ozone" backs  and jump  on the cars' fumes
 that  break  down  ozone, causing skin cancer  from  the  sun; it's not the dry
 cleaners and our  recycled perc.  We'll  go back to petroleum.* (FL/DC-U-
YNYN-M1016)

      Pickup situation here is out of control.  [Transporter X] has law on
 their  side, has  a monopoly, is charging exorbitant prices, and is using
 coercive tactics.   Two of largest cleaners  here  have recently dumped
 them;   what  they  are doing with waste, I don't know.  Disposal must be on
 a practical basis or dumping/lawbreaking  will become rampant.  They want

                                    B-45

-------
 $40/month with or without pickup need plus $5-$6 for new drum each trip.
 Will reduce pickup by $3 and waive drum charge if we buy their products.
 Products are inferior to Puritan, which we have been using.  EPA should
 call moratorium on law NOW till solution is provided.* (NC/DC-S-YNYN-T216)

     We comply thoroughly with all guidelines concerning our wastes, but
 the EPA has to license or provide alternative to open this area of our
 industry for more competative rates for disposal.  Although we will
 continue to handle our waste disposal according to the laws no matter
 what the cost, some smaller cleaners with the depressed economy may have
 to resort to other means of disposing their wastes if something isn't
 done about the ever increasing costs, and this will snowball into increased
 costs to the government by having to regulate and monitor the proper
 disposal of these wastes.  Aside from the fact that I think everybody
 wants their children to be able to drink the water and enjoy our lakes,
 streams, and rivers in this great country without being poisoned.  Thank
 you for lending an ear for this growing problem.* (TX/DC-S-YNYN-M211)

     Too much paperwork required by New York State Department of
 Environmental Conservation and the EPA.  No incentive to produce smaller
 volume of waste.  (NY/DC-S-YNYY-M697)

     State of Washington designated dry cleaning machines as recycling
 plants, i.e., solvent dumped to the still for reclaiming is hazardous
 waste.  This runs up waste fees and discourages recycling efficiencies.
 Only waste actually disposed of should be designated as waste.  (WA/DC-U-
 YYYY-M763)

     All regulations should be the same - federal and state.* (TX/AM-U-
 YNYN-T953)

     First the federal EPA, then the state EPA, then the county, now the
 damn city.  None of whom are helpful.  (CA/AM-S-YNNY-M613)

     Paperwork is a pain - We have to send manifests to both New York and
Massachusetts for each shipment.  (MA/DC-U-YNYY-M283)

     City standards more strict than county, county more strict than
 state, state more strict than Fed!! (CA/AM-U-YNYY-M1043)

     Everyone has different regulations:  city, county, state, federal.*
 (C A/AM-U-YYYY-M1045)

     The Kansas EPA law has taken the Federal law and cut  it in half,
 therefore less than 50kgs. in any month is a violation of Kansas laws.
 Pickup is most difficult and getting storage containers almost impossible.
 The cost is prohibitive and just about put me out of business.*  (KS/DC-
YYNN-M261)

     Confusion on laws:  They seem to change very often and are  also
 inconsistent between state and federal.  (WA/AM-U-YYYY-M377)
                                   B-46

-------
      Regulations  very  complicated and difficult for small business to
 understand.   (KY/DC-U-YNYN-M991)

      I  am  an American.   Quit  speaking kilograms; speak pounds and ounces.
 (IN/DC-U-YNYN-M886)

      Need  to get  regulations  in English  that can be understood.  (WA/AM-U-
 YNNN-M372)

      Paperwork  for manifesting, labeling, and record keeping is confusing
 and  complicated.  (OH/DC-U-YYYN-M4)

      Paperwork!   We don't keep  records.*  (OH/AM-U-YYYY-M460)

      Too much paper work and  file keeping for requirements of EPA.
 Ridiculous.   (FL/AM-U-YNYN-M46)

      Too many regulations producing too much paper work taking too much
 unnecessary  time.  (MD/AM-S-YYYN-M80)

      Your  forms are written as  only a government person can understand
 them.   We  speak English, not  governmenteeze.  (NY/DC-U-YNYN-M127)

      Make  the laws simple and everyone will comply with them.  (TX/AM-U-
 YYNY-M362)

      Paperwork complicated for  such a small amount of waste.  (NY/DC-U-
 YNNN-M136)

      Manifest and documents just add paperwork, for what real important
 purpose?   (NY/DC-U-YNYX-M900)

      Understanding the EPA laws!  (FL/AM-U-NXXX-M541)

      Lack of  consistent interpretation of regulations by EPA officials
 and guides.   (MI/AM-U-YYYY-M507)

      1  believe there would be more firms  in the business, making prices
more  reasonable, if the government regulations would not be so hard and
expensive to  comply with.* (IN/DC-U-YNYN-M1054)

      Determining what is or is not hazardous waste; information is vague
and sometimes conflicting.  (OK/AM-U-YNYN-M456)

     The law  should allow small generators to pool their waste for a one-
time  pickup.  (NY/AM-U-YNYN-M16)

     You have two problems:   (1) waste removal (EPA), (2) unsafe operating
environments  (OSHA).   [Answer:]  "Thermal Incineration."  (OH/DC-Equipment
Manufacturer-Mi05)
                                   B-47

-------
     Recycling looks interesting.  How about local co-ops?  (PA/AM-U-YNYN-
M68)

     Workers right-to-know law regarding posting of all possible hazardous
substances. (PA/AM-U-YYYN-M434)

     Liability insurance from site to dumping facility.  (IL/AM-U-YYYY-M527)

     My big worry is that ten years from now the rules will change and
I'll have a liability I can't handle.* (CA/DC-S-YNYY-M1002)

     As long as we live, we have problems.  Problem is how we solve, how
we manage the problems.  We want best environment, yet we want better
living, too.  We have to face the facts of all the industries:  agriculture,
electrochips, toxic industries.  Why our country goes down, debts, debits.
We have to meet compromise point, where saturation point, boiling point,
ends.  (CA/DC-U-YYYN-M1017)

     Why can't we dispose of filters in city trash if we use the Puritan
Stripper?  Tests show that only 0.2% of the perc in them in the beginning is
left after the procedure.  (X/DC-U-YNYN-M181)

     Filter cartridges when stripped have no perc left in them and should
not be classed as hazardous waste.  (X/DC-U-YYYN-M865)

     Three months storage limit is too short and not practical; should be
at least six months, with no harm to anybody.  (CA/DC-U-YYYY-M1072)

     It costs me almost as much to dispose of my used cartridges as it
costs me to buy new cartridges.  I don't feel that they are that hazardous
after I strip the perc out of them.* (CA/DC-S-YNYN-M1073)

     Since there are no hazardous waste land fills in our area, we are
forced to ship filter cartridges, a small number per drum, at exhorbitant
prices.  These filters are steam stripped and carbon absorbed to 3-4
pounds their original weight.  Any hazardous waste left would have to be
infinitesimally small, but the cost is ridiculous!  I don't have any
problems with proper hazardous disposal of still bottoms even though it is
ridiculously expensive in "rural" areas.* (UT/DC-U-YNNN-M1076)

     In this state there is a lot of confusion regarding disposal of
hazardous waste.  The state law supercedes federal law and definitions or
interpretations are difficult to understand.  (WA/DC-U-NNXX-M1082)
                                   B-48

-------