530SW85901
REGULATORY ANALYSIS
FOR
PROPOSED REGULATIONS
UNDER RCRA FOR
SMALL QUANTITY GENERATORS OF
HAZARDOUS WASTES
Prepared for:
U.S. Environmental Protection Agency
Office of Solid Waste
Prepared by:
Industrial Economics, Inc.
2067 Massachusetts Avenue
Cambridge, Massachuetts
July 1985
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INTRODUCTION CHAPTER 1
This report presents an analysis of the costs, benefits and
economic impacts of alternative regulatory programs which could
be imposed on small quantity generators of hazardous wastes, and
describes the basis for selection of the proposed regulations.
Regulations affecting the practices of establishments generating
between 100 and 1,000 kg per month of non-acutely hazardous
wastes are being proposed under the authority of the Resource
Conservation and Recovery Act (RCRA), as amended by the Hazardous
and Solid Waste Amendments (HSWA) of 1984. The rules will
redefine small quantity generators (SQGs) subject to reduced
requirements under 40 CFR 261.5 from the current standard
(generation of less than 1,000 kg per month) to a new standard
(generation of less than 100 kg per month). Therefore,
generators of between 100 and 1,000 kg per month will be affected
by the proposed rule. For convenience, these affected generators
are referred to as SQGs in this report, although after imposition
of the proposed rule these establishments will no longer be
regulated as SQGs under 40 CFR 261.5.
This report presents the results of the regulatory analyses
undertaken by EPA to comply with the requirements of Executive
Order 12291 for the proposed rule. This chapter
o describes the legal basis for the proposed
regulations,
o summarizes the applicable requirements of
Executive .Order 12291,
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o provides an overview of the regulatory
requirements considered by EPA and describes the
proposed rule,
o summarizes the results of this regulatory
analysis, and
o describes the organization of the report.
LEGAL BASIS FOR THE PROPOSED RULE
Under the Resource Conservation and Recovery Act, as amended
(RCRA), EPA is authorized to promulgate such regulations as are
deemed necessary to protect human health and the environment from
the improper management of hazardous wastes. Regulations
promulgated on May 19, 1980 (40 CFR 261.5) conditionally exempted
generators of less than 1,000 kg of hazardous waste (or less than
1 kg of acutely hazardous waste or 100 kg of residue from a spill
of acutely hazardous wastes) in a calendar month from most RCRA
requirements. To be exempted from most RCRA Subtitle C
requirements, such generators of non-acutely hazardous wastes
(generally referred to as small quantity generators) must
determine whether their waste is hazardous, store no more than
1,000 kg on-site at any time, and ensure that wastes are managed
in a facility (on- or off-site) which is regulated under Subtitle
C of RCRA or approved by a State to manage industrial or
municipal solid waste.
This exemption was based on administrative feasibility. At
the time, EPA estimated that generators of less than 1,000
kg/month represented over ninety percent of all generators but
accounted for only one percent of the total quantity of hazardous
waste generated per year. The original exclusion was intended to
focus limited EPA and State implementation and enforcement
resources on those establishments generating 99 percent of all
hazardous waste. The Agency stated that it would initiate rule-
making within 2 to 5 years to phase-in expanded Subtitle C
coverage of small generators down to those generating more than
100 kg/month of hazardous waste.
Section 3001 (d) of RCRA, as amended by the Hazardous and
Solid Waste Amendments (HSWA) of 1984 now requires EPA to
establish standards for the generation, transportation,
treatment, storage, and disposal of hazardous waste generated by
establishments producing between 100 and 1,000 kg/month of
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hazardous waste. The HSWA establish certain minimum requirements
for such wastes, but in general provides that standards applied
to generators of less than 1,000 kg/month may differ from the
existing Subtitle C requirements as long as the standards are
"sufficient to protect human health and the environment." The
legislation requires that such standards be promulgated by March
31, 1986. If this deadline is not met, a set of requirements
specified in the legislation (the "hammer" provisions) will take
effect. In addition, the legislation requires that, no later
than 270 days after enactment, any off-site shipment of hazardous
wastes by a generator of between 100 and 1,000 kg/month be
accompanied by a partially-completed copy of the EPA Uniform
Hazardous Waste Manifest.
This Regulatory Impact Analysis (RIA) addresses EPA's
proposal for rules to be promulgated in final form by March 31,
1986. The analysis does not consider the effects of requirements
imposed by the HSWA prior to implementation of "final standards",
nor does it address the effects of the "hammer provisions"
(should they take effect). The proposed standards impose new
requirements only on generators of more than 100 kg/month of non-
acutely hazardous waste. While EPA has the authority to
promulgate requirements for generators of less than 100 kg/month,
it is not doing so at this time. Throughout this report, the
term "small quantity generators" (or SQGs) is used to refer to
generators of between 100 and 1,000 kg/month. (Generators of more
than 1,000 kg/month are referred to as "large quantity
generators" or "LQGs".)
REQUIREMENTS OF EXECUTIVE ORDER 12291
This RIA was prepared to comply with the requirements of
Executive Order 12291. That order requires that the Agency
prepare an analysis of the costs and benefits of proposed
regulations for any "major rule". A major rule is one that is
likely to result in:
o an annual effect on the economy of $100 million or
more;
o a major increase in costs or prices for consumers,
individual industries, federal, state or local
government agencies, or geographic regions; or
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o significant adverse effects on competition,
employment, investment, productivity, innovation,
or the ability of United States-based enterprises
to compete with foreign-based enterprises in
domestic or export markets.
Because of the large number of establishments affected by the
proposed rule, EPA expected that one or more of the criteria for
a major rule might be met, and therefore undertook a full RIA.
The Executive Order requires that an RIA contain the
following:
o a description of the potential benefits of the
rule (including benefits that cannot be quantified
in monetary terms), and identification of those
likely to receive the benefits;
o a description of the potential costs of the rule,
and identification of those likely to bear the
costs;
o a determination of the potential net benefits of
the rule;
o a description of alternative approaches that could
achieve substantially the same regulatory goal at
lower cost (including an analysis of the benefits
and costs of such alternatives), and a discussion
of the legal reasons why such alternatives could
not be proposed.
Guidelines issued by OMB and by EPA suggest further that an
RIA should include the following specific topics.
First, the RIA should describe the need for and the
consequences of the proposal. In the case of the regulation
discussed in this report, this requires evaluating the risks to
human health and the environment resulting from current SQG waste
management practices, and evaluating how those risks would change
as a result of the proposed rule and alternatives to the proposed
rule.
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Second, the RIA should consider a range of alternatives for
achieving the desired objective, including alternative levels of
stringency, alternative effective dates, alternative methods of
ensuring compliance, and the alternative of no further Federal
regulation.
Third, the RIA should evaluate the benefits of each
approach, including human health and environmental benefits.
These benefits should be quantified to the extent possible, and
should consider relative uncertainties about the effects of
alternatives, potential intermedia transfers, effects on
individuals exposed to the maximum adverse effects (as well as
average exposures), and likely levels of compliance.
Fourth, the RIA must assess the costs associated with each
alternative. The analysis should consider all costs to society,
including costs incurred by the parties directly affected by the
regulation, costs incurred by Federal, State and local
governments to implement and enforce the regulation, losses due
to discontinued production of goods and services resulting from
the regulation, and adverse effects on productivity, innovation,
competitiveness in international markets, and market structure.
Finally, the RIA should compare the costs and benefits of
each alternative, considering the distribution of both benefits
and costs. The distribution of costs should be determined by
evaluating the economic impacts associated with the rule,
including effects on prices, profits, production levels, plant
closures and employment.
SUMMARY OF THE PROPOSED RULE AND ALTERNATIVES
The proposed rule would impose a subset of the requirements
that currently apply to LQG wastes on management of SQG wastes.
In particular, the proposed rule includes:
o reduced generator requirements under 40 CFR Part
262, including: management of wastes in Subtitle C
facilities, partial manifest requirements, EPA
identification numbers, elimination of the
biennial reporting requirements, and a limited set
of performance requirements for on-site storage of
wastes up to 180 (or in some cases 270) days; and
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o full Part 264 and 265 requirements for on- and
off-site facilities managing SQG wastes, with an
extension in effective date for on-site
facilities.
The Agency considered a number of alternatives to the
proposed rule, as well. These were primarily variations of the
existing LQG requirements, as described below.
The Agency considered imposing full Part 262 generator
requirements. Under this approach, SQGs would be required to
comply with full manifesting requirements, and would be required
to submit biennial reports, in addition to the proposed
requirements. The Agency also considered further reductions to
the existing generator requirements for SQGs, including
elimination of the EPA identification number requirement.
A variety of factors governed the selection of the proposed
rule. The Agency identified some cases in which full
requirements may not be necessary for SQGs. In particular, the
Agency has tentatively concluded that the tracking feature of the
full manifest is not required (given the existence of
notification and of reporting requirements for off-site
facilities) to monitor compliance with SQG regulations. However,
the Agency is specifically requesting comment on the merits and
drawbacks of eliminating the requirements for use of the full
manifest system. The Agency has also concluded that the
information provided by biennial reports from off-site facilities
receiving SQG wastes is sufficient to provide information on SQG
practices, and that the biennial reporting requirement should
therefore be eliminated for the SQGs themselves. This conclusion
is based on an expectation that most SQG wastes will be managed
at off-site facilities, and therefore that only a small portion
of SQG wastes would be excluded from the biennial reports
provided by others.
The Agency also concluded that the smaller quantities of
waste generated per establishment by SQGs would result in lower
risk when stored for. short periods, since the total amounts in
storage at any one time are correspondingly lower for SQGs than
for LQGs. Therefore, the Agency believes that allowing a 180- or
270-day period for on-site storage (as required by the HSWA)
without complying with full Part 264 and 265 storage requirements
is protective.
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Other than storage for 180 (or 270) days, however, the
Agency did not find that the risks posed by on-site treatment,
storage, or disposal practices are sufficiently linked to the
quantity of waste generated to justify reduced requirements for
non-exempt on-site management by SQGs. The total quantities of
waste potentially causing damages are smaller for SQGs than for
LQGs, and hence (other things being equal) would present lower
total risks to human health and the environment. However, risks
are a complicated function of waste characteristics, management
practices, location, and characteristics of surrounding
populations, as well as of waste quantity. The wastes generated
by SQGs exhibit the same ranges in hazard as wastes generated by
LQGs, and cannot be considered less hazardous based on their
intrinsic characteristics. Further, SQGs tend to be located in
populated areas where the consequences of mismanagement may be
greater than would result in more isolated locations. SQGs may
also be more likely to mismanage wastes in the absence of
explicit requirements than many LQGs, because they are less
likely to be familiar with the hazardous nature of their wastes
and may lack the technical expertise to manage those wastes
properly on-site. Further information would be needed to
determine how these factors affect the relative risk from SQG and
LOG wastes, and to characterize the risks from SQG practices more
fully. Thus, the Agency could not conclude at this time that SQG
practices would consistently result in less risk to human health
and the environment than LQG practices, if subject to less
extensive regulatory requirements. However, as noted above, the
Agency is requesting comment on whether particular Part 264 and
265 requirements could be reduced for SQGs without increasing
risks to human health and the environment significantly.
OVERVIEW OF RESULTS
The analysis presented in this report suggests that the
proposed rule will not impose significant burdens on most SQGs.
Cost increases are moderate in most cases because the quantities
of waste requiring management are small, because many current
practices can continue with only minor changes, and because
regulatory requirements are limited for many likely SQG
activities. A large portion of the estimated costs for most SQGs
result from the time required to review and understand the
regulations, to select appropriate management methods, and to
label and manifest waste shipments, and from following basic
requirements for safe management during storage prior to
treatment or disposal. The analysis described in Chapter 8 shows
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that only 25 of 289 model plants developed to represent SQGs are
potentially subject to significant impacts. Of those, the SQGs
most likely to experience significant burdens include:
o SQGs generating waste for which alternative
management practices will be required and for
which such alternative management is relatively
expensive (e.g., drycleaning filtration residues
or ignitable wastes); and
o SQGs who are currently earning very low profit
margins.
While costs for individual generators are not likely to pose
significant burdens in most cases, the aggregate costs of the
proposed rule are large because a large number of generators are
affected. The proposed rule is expected to impose aggregate
costs to society of $69 million per year. Of this total, $58
million per year represents the costs borne by SQGs in complying
with the regulations, and $11 million per year represents costs
to the government to implement and enforce the proposed
requirements. The proposed rule is therefore not expected to
constitute a "major rule" according to the $100 million-per-year
aggregate cost criterion specified in Executive Order 12291.
(This conclusion is subject to uncertainties in the aggregate
cost analysis described in Chapter 6.) The rule also does not
appear likely to cause significant price increases, reductions in
employment, reductions in profit or plant closures in any
industry, as discussed in Chapter 8.
The benefits of the proposed rule are difficult to quantify
in many cases, and this RIA does not present aggregate estimates
of potential reductions in health risk or other benefits of the
rule. However, the various types of benefits expected to accrue
from the rule are evaluated qualitatively in Chapter 7, and some
aspects of changes in risk are analyzed quantitatively. To
ensure that the proposed rule would not have perverse effects on
risk, lEc explicitly considered cases where risks might be
increased under the proposed rule (due to increased
transportation or storage of wastes and increased disposal to
POTWs). We concluded that the rule is likely to result in net
reductions in risk from current practices such as inadequate
storage, disposal via garbage trucks, disposal in sanitary
landfills, and unlabelled shipments of waste in general. It also
appears that increased transportation and disposal to POTWs is
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not likely to offset the likely risk reductions to any
significant degree. We were not able to judge how total risks
from storage of SQG wastes would change, and were not able to
quantify net effects on risks in the aggregate.
One aspect of potential benefits that was analyzed
quantitatively concerns discontinued disposal to Subtitle D
landfills. The preliminary results of this analysis suggest that
cancer risks are likely to decrease in the aggregate, in large
part due to the fact that wastes will no longer be sent to
numerous Subtitle D facilities, but instead will be concentrated
in fewer, better managed Subtitle C facilities. The analysis
also suggests that some non-threshold health effects could
increase with less dispersed management of SQG wastes, but the
initial results of the analysis are not believed to provide an
accurate measure of these effects.
The analyses of costs, impacts and risks described in this
report draw heavily on work performed by other contractors. This
work is described more extensively in other reports, which should
be consulted in conjunction with this document to evaluate the
results of the analysis fully.
ORGANIZATION OF REPORT
The remainder of this report is organized as follows:
o Chapter 2 describes alternative approaches for
regulating SQGs.
o Chapter 3 describes the population affected by the
proposed rule and characterizes their current
practices.
o Chapter 4 provides a detailed description of the
requirements imposed on management of wastes
generated by SQGs under the proposed rule and
under alternatives.
o Chapter 5 discusses a number of factors that are
likely to affect SQGs1 responses to the proposed
re-gulations. This chapter provides useful
background for evaluating the costs of alternative
responses to the regulations.
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Chapter 6 summarizes the results of the cost
analysis for the proposed rule and alternatives.
This analysis is presented in a separate report.
The summary provided here includes estimates of
the aggregate costs to regulated parties and to
the government associated with alternative
regulatory approaches, and a discussion of the
costs associated with alternative generator
requirements.
Chapter 7 discusses the benefits expected to
result from the proposed regulation and
alternatives. This chapter characterizes the
risks associated with various practices, and
discusses the changes in overall risk that will
result from the proposed rule.
Chapter 8 assesses the economic impacts resulting
from the proposed rule. This chapter summarizes
the results of an economic impact analysis
presented in a separate report, and identifies
those SQGs that may experience significant
reductions in profits, plant closures, reductions
in employment, changes in competitive structure,
or price increases as a result of the proposed
regulation.
Chapter 9 compares the costs and benefits of
alternative regulatory approaches, and discusses
the basis for the Agency's choice of the proposed
approach.
Appendix A provides a selected list of the parties
contacted by lEc in preparing this RIA.
Appendix B presents a list of references reviewed
by lEc in support of this RIA.
Appendix C provides detailed tabulations of
current SQG practices by industry and by waste,
which are based on the results of a recent survey
of small quantity generators.
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Appendix D documents assumptions and methods used
to analyze the costs of transporting and storing
SQG wastes under a variety of conditions. (These
issues are discussed in Chapter 5.)
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REGULATORY ALTERNATIVES CHAPTER 2
This chapter describes the alternative strategies the Agency
has considered for regulating small quantity generators, and
describes the strategy being proposed. Chapter 4 describes in
greater detail the specific provisions considered under each
regulatory approach.
BASIS FOR DEFINING REGULATORY ALTERNATIVES
The Agency must consider statutory requirements in
developing regulations for SQGs. The HSWA place two specific
constraints on the types of regulations the Agency may impose for
SQGs.
First, all off-site shipments from SQGs must be accompanied
by a Uniform National Manifest form, with the following items
completed: the generator's name and address, the Department of
Transportation (DOT) description of the waste, the number and
type of containers, the quantity of waste being transported, and
the name and address of the destination facility. This
requirement goes into effect 270 days after the enactment of the
legislation, or August 5, 1985, and must be incorporated into the
final SQG regulation being considered in this report. These
manifest requirements are less extensive than those currently
applied to LQG shipments. Additional manifest requirements are
to be considered only if the Agency determines that such
requirements are necessary to protect human health and the
environment.
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Second, the legislation requires the final regulations . to
allow treatment, storage or disposal of SQG wastes only at
facilities permitted under Subtitle C of RCRA or operating under
interim status in compliance with the requirements of Subtitle C,
with one exception. SQGs may store wastes on-site without
complying with Part 264 and 265 storage requirements up to 180
days, or if they must ship wastes more than 200 miles they may
store up to 6,000 kg of waste for 270 days.
Beyond these specific minimum provisions, the legislation
requires that the Agency promulgate regulations covering the
generation, transportation, treatment, storage, and disposal of
wastes from SQGs that are "sufficient to protect human health and
the environment" (the same basic standard that applies for other
regulations under RCRA). If the Agency does not promulgate such
regulations for SQGs by March 31, 1986, the legislation imposes
additional provisions (referred to in this report as the "hammer
provisions"). The legislation specifically states that these
hammer provisions are not to be taken as minimum or maximum
requirements for the regulations promulgated by EPA. In addition
to the two minimum requirements described above (partial manifest
and Subtitle C management), the hammer provisions would require
semi-annual submission of exception reports (reports on any
shipments for which manifests are not returned by off-site
destination facilities) and retention of signed manifests
returned by destination facilities for three years.
The HSWA state that the Agency may promulgate Subtitle C
requirements for SQGs that differ from those applicable to LQGs,
as long as the standards are sufficient to protect human health
and the environment. The legislative history specifically
suggests that because of the small quantity of wastes involved,
and because many SQGs are likely to be small businesses, EPA
should consider "whether it is possible to simplify, reduce the
frequency of, or eliminate the existing reporting and
recordkeeping requirements and still provide adequate protection
of human health and the environment." Thus, although the
legislation. does require management under Subtitle C
requirements, the Agency potentially has substantial latitude to
tailor the requirements to be applied to SQGs. Given this
latitude, the Agency has considered a range of alternative
regulations for SQGs.
In defining alternative regulatory approaches, the Agency
took as a reference point the Subtitle C requirements that
currently apply to large quantity generators of more than 1,000
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kg/month. These regulations include management standards for
generators, transporters, storers, treaters, recyclers, and
disposers of hazardous wastes, and have been promulgated by the
Agency based on the need to protect human health and the
environment. The Agency then reviewed specific provisions of the
LQG regulations, to determine whether the cost savings from
reducing particular requirements for SQGs outweighed any
increases in risk to human health or the environment that might
result.
In reviewing the specific Subtitle C requirements, the
Agency applied two tests to determine whether reduced SQG
requirements should be considered:
o Is the risk which the provision is designed to
prevent different in nature or kind for SQG wastes
than for wastes from LQGs?
o Is the cost of the provision significantly higher
for SQGs than for LQGs, such that regulatory
. burdens would be increased substantially without
significantly reducing risks to human health and
the environment?
Applying these criteria necessarily involved use of
judgement, since the link between many of the requirements and
reductions in risk to human health and the environment is
indirect. For example, recordkeeping and reporting requirements
do not directly result in reductions in risk, but rather support
other aspects of the regulatory program that have a more direct
effect on risk. Further, for many of the requirements that are
more directly related to risk, the Agency has not yet analyzed
the effects of the LQG requirements fully. For example, the
Agency has not completed a comprehensive analysis quantifying the
reductions in risk associated with requirements for container
storage. Therefore, it is difficult to estimate precisely the
differences in risk that would result from reductions in many of
the Subtitle C requirements.
After reviewing the components of the Subtitle C
requirements, the Agency has defined a set of regulatory
alternatives for analysis. Three set's of alternatives are
described in the remainder of this chapter, based on separate
standards for generators, transporters and treatment, storage and
disposal facilities (TSDFs).
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ALTERNATIVES FOR GENERATOR REQUIREMENTS
Generator standards currently established for LQGs in 40
CFR Part 262 include the following provisions:
o determining whether wastes are hazardous, by
referring to the list of hazardous wastes in 40
CFR 261 Subpart D, by testing the wastes according
to criteria defined in 40 CFR 261 Subpart C, or by
simply certifying that the wastes are hazardous;
o retention of any waste analysis or waste
determination records for at least three years;
o notification to obtain an EPA identification
number;
o shipment of wastes off-site only to a permitted or
interim status Subtitle C facility and only by a
transporter with an EPA ID number;
o manifest requirements for generators sending
wastes off-site, including full completion of the
Uniform National Manifest/ filing of exception
reports when signed manifests are not returned by
the destination facility, and retention of copies
of manifests and exception reports for a minimum
of three years;
o describing, packaging, labelling and placarding of
all waste shipments in accordance with Department
of Transportation (DOT) regulations;
o biennial reports to the Regional Administrator for
wastes shipped off-site (including generator
identification, lists of facilities and
transporters receiving wastes during the period
covered by the report and description and
quantities of wastes shipped off-site) and
retention of copies of these reports for three
years (TSDFs are also required to submit biennial
reports for the wastes managed); and
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o storage of wastes on-site in tanks or containers
for up to 90 days subject to a limited subset of
the requirements applicable to tank or container
storage facilities (storage in surface
impoundments or waste piles is not eligible for
reduced requirements during the 90-day period;
storage for more than 90 days in tanks or
containers is subject to the full Part 264 and 265
requirements for storage facilities).
The Agency is not considering changing the extant
requirement that the generator determine whether his waste is
hazardouSf since that requirement is a necessary first condition
for the generator to know that he is subject to the RCRA Subtitle
C requirements, and since SQGs are already subject to this
requirement. As will be discussed in Chapter 5, many SQGs appear
to be unaware that their wastes are hazardous, however, and may
have difficulty interpreting and applying the criteria for
determining whether a waste is hazardous. The Agency is
developing an education program to assist SQGs in determining
whether they generate a waste regulated by RCRA and to clarify
the RCRA requirements applicable to those wastes. Since the
generator does not have to conduct waste analyses, but instead
can simply certify that wastes are hazardous where other
information suggests that this is the case, the generator
requirements do not necessarily impose significant testing costs
on generators. The major problems will arise (1) where SQGs
generate unusual wastes not identified by any educational
material as hazardous (since the generator will still be liable
for determining whether such wastes meet the criteria) , and (2)
where SQGs certify wastes to be hazardous without testing and
where wastes do not in fact meet the criteria (since the SQG will
bear the cost of managing the wastes as hazardous unnecessarily).
It is impossible to say how often these conditions might arise.
The Agency believes that the potential for widespread evasion of
responsibilities under RCRA would be increased significantly,
however, if SQGs were not liable for determining whether their
wastes are hazardous, and therefore has decided not to consider
waiving or reducing this requirement.
In addition, the Agency has not analyzed extensively any
requirements that would be less stringent than those required by
legislation. That is, all options considered for generators
include, at a minimum, use of a partial manifest and management
of wastes at Subtitle C facilities, with provision for storage
on-site up to 180 or 270 days without the need to obtain interim
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status or a permit. This limitation in the range of alternatives
studied was based primarily on the Agency's belief that less
stringent requirements would not comply with the legislation.
However, it is likely that these minimum requirements would be
shown to be justified if analyzed more extensively. First, the
costs associated with a partial manifest are expected to be
minimal, and the requirement provides the minimum level of
notification to others needed to ensure that wastes are not
mismanaged due to lack of information about their hazardous
character. Second, analysis described in Chapter 5 suggests that
although some SQGs might prefer to store longer than the 180- to
270-day period allowed for unpermitted storage before shipping
off-site, they would not significantly reduce their costs by
doing so. Hence, allowing longer storage periods would not
significantly reduce burdens on SQGs. Finally, the requirement
that wastes be managed at Subtitle C facilities is consistent
with tailoring of requirements should they be found to be
justified since the legislation specifically allows for
tailored Part 264 and 265 standards for SQGs. The requirement
ensures that SQG wastes are managed at facilities that are
designed to handle hazardous wastes and are subject to regulatory
requirements appropriate to hazardous waste management.
The Agency has therefore identified the following options
for SQG generator requirements:
o Option G.l; Full Part 262 Regulations
Requirements identical to those imposed on LQGs,
with the exception of the longer allowance for on-
site storage without a storage facility permit.
o Option G 2: Minimum Generator Requirements
Minimum requirements imposed in the statute
(a partial manifest and Subtitle C management)
plus notification to obtain an EPA ID number,
retention of waste analysis documents, and a
limited set of performance standards for on-site
storage for the allowed 180 or 270 days.
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o Option G 3; Minimum Requirements Plus Full
Manifest
The minimum requirements imposed in Option G 2
plus additional manifest requirements (including
exception reports/ and retention of manifests and
exception reports for a minimum of three years.)
Options G 2 and G 3 eliminate requirements for biennial
reporting. In addition, Option G 2 simplifies the manifest
requirements by requiring only one copy of the manifest (instead
of the three copies required for LQGs), eliminating the
requirements that generators receive signed copies of manifests
back from destination facilities and investigate and notify EPA
when such signed copies are not received, and eliminating the
requirement that exception reports and copies of manifests be
retained for at least three years. This partial manifest
requirement is more extensive than the minimum requirements
specified in the HSWA, in that SQGs would be required to complete
all portions of the Uniform National Manifest except the manifest
docket number (including generator and TSDP EPA identification
numbers). Under Option G 2, the manifest system would serve only
to notify transporters and destination facilities about the
nature of the wastes shipped, while under Options G 1 and G 3,
the manifest system would provide a tracking system designed to
ensure that wastes are delivered to appropriate facilities, as is
intended for LQGs.
Full DOT requirements apply to any shipment accompanied by a
manifest. Therefore, the fact that SQGs must provide manifests
for their shipments automatically subjects any transporters
handling such shipments to DOT requirements. Further, the SQG
must comply with applicable DOT regulations for marking,
packaging, labeling and placarding. As described below, the RCRA
Part 263 regulations require transporters to notify EPA, obtain
an EPA identification number, and clean up and report any
releases of wastes in transit. In addition, transporters are
allowed to store wastes up to 10 days without a storage permit
and are prohibited from mixing wastes of different types unless
they comply with the generator standards for the mixed wastes.
For reasons discussed in the next section, the Agency is not
proposing reductions in many of these requirements.
Chapter 4 describes the differences among the generator
regulatory options in more detail. Chapter 6 estimates the
differences in costs imposed by the alternative generator
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requirements, and Chapter 7 discusses the effect of the
alternatives on risks to human health and the environment. The
Agency is proposing Option G 2, which simplifies some
requirements for SQGs storing wastes on-site prior to shipping
wastes off-site or prior to further management of wastes on-site,
eliminates the biennial reporting requirements, and imposes
partial rather than full manifest requirements. The rationale
for selecting this option is summarized in Chapter 9.
ALTERNATIVES FOR TRANSPORTER REQUIREMENTS
As noted above, the requirement that SQGs use a manifest
automatically subjects any off-site shipments of hazardous wastes
to DOT requirements for hazardous materials shipments. These
requirements include packaging, labelling, marking and placarding
requirements. Reductions in these requirements for SQG wastes
would require changes to the DOT hazardous materials regulations,
which the HSWA specifically caution the Agency to avoid.
Part 263 also imposes requirements on the transporter
related to the manifest system. These requirements are a
necessary part of ' the manifest tracking system, and must be
revised for SQG shipments to reflect the fact that SQGs will
provide only one copy of the manifest under the proposed system.
(The Part 263 requirements state that the transporter must sign
the manifest received from the generator, retain a copy and
deliver the remaining copy to the receiving party.)
Further, Part 263 requires that transporters deliver wastes
to the parties designated on the manifest, or contact the
generator if the wastes cannot be delivered. Transporters are
allowed to store manifested shipments of properly-packaged wastes
at a transfer facility for ten days without a storage permit.
Finally, transporters must take immediate action to protect human
health and the environment in the event of any discharge of
wastes during transportation. The first and last of these
requirements impose basic standards for proper management of
shipments that could not be waived without substantially
increasing potential risks to human health and the environment.
The ten day period for waiver of storage permit requirements
at transfer stations could conceivably be lengthened for SQG
shipments. This waiver is relevant only to commercial
transporters who consolidate shipments from a number of sources.
It is unlikely that storage of SQG shipments at transfer points
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poses risks that are in any way different than the risks
associated with LQG shipments. However, different implications
for transporter costs might justify a more lenient standard for
SQG wastes. Allowing a longer storage period for SQG shipments
might allow transporters who handled numerous SQG shipments more
time to accumulate more economic loads for long distance shipment
to commercial TSDFs. (One transporter interviewed by lEc
indicated that it is increasingly difficult to operate as a
commercial transporter with a transfer station without obtaining
a storage permit, and he has applied for such a permit.) lEc's
analysis of transportation costs (discussed in Chapter 5, see
Exhibit 5-1) illustrates that the capacity utilization of the
truck used to transport wastes to a TSDF can have a significant
effect on the annual costs incurred by the generator. While
lower utilization rates always result in increased costs to
generators, generators who ship relatively infrequently are more
significantly affected. As Exhibit 5-1 shows, a generator who
makes two shipments a year pays nearly twice as much in annual
transportation costs if the capacity utilization is 50 percent
rather than 100 percent. However, our conversations with
transporters indicate that, in general, they rarely operate at
such low utilization rates, and therefore, the potential for
increased costs for below-optimal utilization rates is likely to
be low. In addition, allowing a longer storage period for SQG
wastes would require transporters and enforcement personnel to
distinguish SQG shipments from others, which might be
administratively difficult and might make enforcement of
transporter requirements more difficult. The Agency is inviting
comment on the need for and appropriateness of a longer
transfer/storage period for SQG waste.
With the possible exceptions noted above, the Agency has not
identified any of the transporter requirements imposed by RCRA
that can reasonably be reduced for SQG shipments. In a recently
completed study of alternatives for the transportation of SQG
wastes, the Agency concluded that the existing requirements
already allow for flexibility in hazardous waste transportation
by allowing self-transportation (provided generators comply with
Part 263 and applicable DOT requirements) and by allowing
transporters to assume many of the generator's manifest
responsibilities.
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REGULATORY ALTERNATIVES FOR
ON-SITE TREATMENT, STORAGE AND DISPOSAL
The Part 264 and 265 requirements for treatment, storage and
disposal facilities include numerous provisions. The Part 265
requirements impose "interim status standards" (ISS) that apply
to facilities operating prior to receiving a full permit under
the provisions of 40 CFR 270. The Part 264 requirements apply to
fully-permitted facilities, and incorporate all of the Part 265
requirements. The Part 264 requirements generally add technical
standards for specific waste management activities to the
administrative, financial, reporting and recordkeeping,
monitoring, inspection and basic operating standards specified in
Part 265.
As noted above, EPA has the option under the HSWA to reduce
Part 264 and 265 requirements for SQG wastes where the reduced
requirements would be protective of human health and the
environment. The Agency believes that waiver of any of the Part
264 and 265 requirements for off-site facilities handling SQG
wastes is not justified, (1) because the hazards posed by SQG
wastes are not likely to be different in kind than the hazards
posed by LQG wastes, and (2) because facilities managing SQG
wastes (even those managing only SQG wastes) are likely to handle
large quantities of diverse wastes. Therefore, the Agency has
only considered reduction of the facility requirements for SQGs
managing wastes on-site.
Many of the Part 264 and 265 requirements impose significant
costs that are proportionally greater for facilities managing
smaller quantities of wastes. EPA has reviewed the requirements
to identify cases in which it is likely that special burdens will
be placed on smaller facilities. The Agency has also evaluated
whether waiver or reduction of requirements would result in
significant increases in risk to human health and the
environment. This review has in many cases required
distinguishing between requirements that have a direct effect on
risks from SQG practices (such as prohibitions on certain
practices), and those that are less directly-related to risk but
which involve documenting, monitoring, and enforcing other
provisions of the regulations. Although there are numerous
requirements imposed by the Part 264 and 265 standards, the
Agency was able to identify only a few instances in which
reduction in requirements might be justified for SQGs. This is
because many of the most costly requirements (such as
groundwater monitoring, use of liners, or corrective action
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requirements) are also those that most directly bear on the risks
from SQG waste management practices. The requirements that might
be less critical to controlling risk often impose relatively low
costs. That is, it is generally the basic costs of managing
wastes properly that will impose the greatest increase in costs
for SQGs, and not the costs of the associated requirements that
support monitoring, reporting and enforcement of compliance with
these basic requirements.
A critical consideration in evaluating alternatives for
regulations governing on-site management by SQGs is whether the
reduced costs would significantly increase the possibility of on-
site management by SQGs. It could be that on-site treatment,
recycling, or disposal by SQGs in some cases presents little risk
to human health or the environment, but would be discouraged by
the high fixed costs of on-site management. If the risks of on-
site management were less than the risks associated with
transporting wastes to off-site facilities for management, more
stringent Part 264 and 265 requirements could even have perverse
effects on total risks in these cases. However, reducing some
Part 264 and 265 requirements for SQGs will have little effect on
SQGs1 costs and on risks, if other provisions of the regulation
make on-site management uneconomic in any case. The cost
analysis presented in Chapter 6, as well as factors affecting
SQGs1 decisions discussed in Chapter 5, suggest that SQGs are
unlikely to manage wastes on-site in most cases, even if some
Part 264 and 265 requirements were reduced. In particular,
corrective action requirements are likely to discourage on-site
management in most cases irrespective of any reductions in the
Part 264 and 265 requirements.
The Agency has identified three basic sets of facility
regulatory requirements for consideration:
o Option F 1; Full Part 264 and 265 Standards
Requirements identical to those imposed on on-site
management by LQGs.
o Option. F 2: Full Standards with Extended
Effective Date
All Part 264 and 265 requirements, with extensions
in effective dates for SQGs.
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o Option F 3: Tailored Part 264 and 265 Standards
with Extended Effective Date
Reduction of some Part 264 and 265 requirements,
in conjunction with the extended effective date
specified in Option F 2.
Chapter 4 identifies specific provisions that would apply
under each option. Chapter 6 assesses the differences in costs
associated with each set of options, including reductions in
costs imposed on SQGs and costs to the government. Chapter 7
discusses the differences in risks to human health and the
environment associated with the regulatory requirements. The
Agency is proposing Option G 2 (minimum generator requirements)
and Option F 2 (full facility standards with extended effective
date). The basis for selecting this option is summarized in
Chapter 9.
The next chapter describes the SQG population that will be
affected by the proposed regulation, and characterizes the
practices that are currently used to manage wastes and that will
be regulated or prohibited under the proposal.
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CHARACTERISTICS OF AFFECTED POPULATION CHAPTER 3
INTRODUCTION
This chapter describes the population that will be affected
by the proposed changes in the SQG exclusion. The primary source
of information on the affected population is a survey recently
conducted for EPA by Abt Associates, Inc. This survey sought
responses from nearly 50,000 establishments that were considered
potential SQGs, and took place between January 1983 and October
1984. Respondents were asked to describe their activities for
the calendar year 1982. More information on the survey
methodology and the overall results is reported in National Small
Quantity Hazardous Waste Generator Survey. March 1985 (referred
to in this RIA as the Survey Report). (Reference 2).
The discussion in this chapter is based primarily on survey
tabulations presented in the Survey Report. This source was
supplemented in some cases using special tabulations prepared to
support the risk analysis described in Chapter 7. Throughout,
this chapter considers only those SQGs generating more than 100
kg of non-acutely hazardous waste in a calendar month on average
during 1982. Generators of less than 100 kg/month will not be
affected by the regulations discussed in this RIA, and hence are
excluded from all analyses described herein. Small volume
generators of acutely-hazardous waste are subject to the extant
requirements, and are also not affected by this rule.
The survey results provide an overview of SQG waste
generation rates and current (pre-regulation) waste management
practices. The remainder of this section discusses some of the
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characteristics of the survey results that should be considered
when .reviewing the profile of the affected population presented
in this chapter.
First, the analysis in this chapter is based primarily on
the industry and waste profiles presented in Appendices D and E
to the Survey Report. These profiles include only those
industries that were included in the survey (the "primary
industries"), and do not include a number of industries whose
practices are expected to be similar to those of one of the
surveyed industries but that were not included in the survey (the
"secondary industries analyzed by analogy" and other industries
with "incidental" generators.) Therefore, the true number of
generators and waste quantities affected is understated in much
of the discussion in this chapter. The percentages of waste
reported for various waste management practices are assumed to be
representative of the practices of all SQGs, however.
The Survey Report does not provide the tabulations needed to
estimate the actual number of secondary industry establishments
or incidental generators generating between 100 and 1,000
kg/month. For all generators of less than 1,000 kg/month, Abt
estimates that there are approximately 85,000 generators in
secondary industries (or approximately 19 percent of the
estimated 450,000 establishments in primary industries), and
between 65,000 and 125,000 incidental generators in other
industries.
In addition, the results reported in this chapter apply only
to those wastes for which respondents were asked to provide
quantitative information on practices. For each surveyed
industry, specific wastes (those expected a. priori to De-
generated by that industry) were selected for detailed responses.
Respondents were also asked to identify other potentially-
hazardous wastes that are generated, but no information on
quantities or management practices was requested for these
wastes. Therefore, the wastes considered in this chapter include
only the "targeted" wastes. Because a portion of the wastes
actually generated may be excluded from the survey results, the
reported numbers of SQGs generating over 100 kg/month may not
provide an accurate measure of the true population affected by
this regulation. Whether the population is over- or understated
is not known. If both targeted and non-targeted wastes were
considered, some generators reported to generate less than 1,000
kg/month might in fact be LQGs, while others reported to generate
less than 100 kg/month in the survey results might be found to be
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subject to the proposed rule. Wastes which were reported by a
substantial number of industries as non-targeted wastes include:
all forms of heavy metal wastes (including paint wastes
containing heavy metals), all forms of pesticide wastes, acids
and alkalies, photographic wastes, used batteries, waste
formaldehyde, wastes with ammonia, and spent solvents. The
Survey Report estimates that the non-targeted wastes reported by
the primary surveyed industries represent less than 200,000
MT/year.
Third, as described in the Survey Report, a substantial
quantity of the wastes for which quantitative results are
available is accounted for by used lead-acid batteries. Ninety
percent of these batteries are currently recycled. The recently-
promulgated Definition of Solid Waste specifically excludes lead-
acid batteries that are recycled, as well as any batteries that
are returned to the manufacturer, from the quantity determination
used to identify SQGs subject to Subtitle C requirements (40 CPR
261.5 (c)) (see Chapter 4). Therefore, a substantial portion of
the targeted wastes reported in the survey will not in fact be
subject to regulation and do not count toward the 100 kg/month
minimum that will subject generators to SQG requirements. Only
two types of generators were targeted for batteries in the survey
vehicle maintenance and motor freight terminals. However,
nearly all industries reported some batteries as non-targeted
wastes.
It is reasonable to expect that all used batteries can be
recycled and that they will be when the SQG regulations go into
effect, since failure to recycle would subject the generator to
RCRA requirements for these wastes. Therefore, the survey results
have been adjusted where possible to exclude batteries. The
preliminary adjustments of the survey results were not detailed
enough to identify generators who would no longer exceed the 100
kg/month limit if batteries are excluded. Therefore, the number
of generators exceeding 100 kg/month in the two affected
industries may be substantially overstated, although in most
cases the quantities of waste reported have been adjusted to
exclude batteries.
A similar problem applies to other types of wastes that will
not be subject to regulation for generators if recycled and that
are not included in the determination of SQG status. These
include (1) recycled industrial ethyl alcohol, (2) recycled used
oils that exhibit a characteristic of hazardous wastes and used
oils burned for energy recovery in boilers or industrial
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furnaces, (3) spent materials and by-products that are hazardous
solely because they exhibit a characteristic of hazardous waste
and that are burned for energy recovery (unless stored in a
surface impoundment), (4) wastes that are used or reused as
feedstocks or substitutes for commercial products (except where
the use involves placement on the land), and (5) characteristic
sludges and by-products that are reclaimed. Adjustments have
not been made to the survey results to exclude such wastes from
the totals, although the quantities reported in the survey that
would fall into one of these categories are not likely to be
large. The cost analysis in this report considers recycling (with
associated reductions in RCRA requirements) as one of the
management options for these wastes. However, we do not exclude
these wastes from the analysis because (unlike our assumption
about used batteries) it may not be possible to recycle all of
these wastes.
Subject to the limitations in the survey results discussed
above, the SQG survey provides the following estimates of the
size of the affected population. The Survey Report estimates
that there are about 630,000 generators of less than 1,000
kg/month, accounting for 940,000 MT/year of hazardous wastes.
Of these totals, an estimated 175,000 generators produce between
100 and 1,000 kg/month and account for approximately 740,000
MT/year. Within this category SQGs in primary industries with
targeted wastes (those wastes for which information on quantities
was requested in the survey) comprise 113,000 of the total and
produce 490,000 MT/year of targeted wastes.
The remainder of this chapter discusses the survey results
for the surveyed primary industries and the targeted wastes. We
first provide an overview of the affected industries, then
describe the wastes reported by the survey respondents, and
finally provide an overview of the management, storage and
transportation practices reported by the survey respondents. All
tabulations reflect weighted data for the surveyed industries.
Appendix C to this report presents more detailed tabulations of
the survey results by industry and by waste.
DESCRIPTION OF SQG INDUSTRIES
This section describes the industry groups potentially
affected by the change in the SQG exclusion. By "industry
group", we refer to those groups of industries (defined by
Standard Industrial Classifications) surveyed together in the SQG
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survey. In some cases, such as "textile manufacturing", . the
survey groups correspond to actual industries. In most cases,
however, the survey groups are in fact based on processes or
practices that were expected to generate similar wastes. For
example, the survey group "vehicle maintenance" includes
respondents from a number of different industries, such as crop
harvesting, highway and street construction, trucking, water
transportation, auto and mobile home dealers, gasoline service
stations, vehicle renting and leasing, and auto repair shops.
Exhibit 3-1 shows the estimated number of SQGs generating
more than 100 kg/month of targeted hazardous wastes in the
surveyed industry groups. This exhibit shows the dominance of
the vehicle maintenance group in the number of generators.
(Wastes other than batteries reported by this group account for
26 percent of the targeted wastes reported by SQGs.) As noted
above, some of the 82,500 generators in this group will not in
fact generate more than 100 kg/month, and hence will not be
affected by the proposed regulations, once batteries are excluded
from the survey tabulations. (Exhibit 3-1 indicates that, on
average, vehicle maintenance generators generate 49 kg/month of
targeted non-battery hazardous wastes, suggesting that a
significant number of these generators in fact generate less than
100 kg/month.)
Of the survey groups other than vehicle maintenance, a
variety of metal manufacturing generators account for the next
largest number of affected generators (9.8 percent of the total),
and an even larger portion of targeted wastes (31.0 percent of
the total). Other groups reporting substantial numbers of
affected generators are (in descending order of importance):
printing, photography, laundries, miscellaneous services,
pesticide applicators, and laboratories. These groups account
for 12.4 percent of the relevant generators and 30.2 percent of
the affected wastes. The remainder of the generators and wastes
are distributed among 14 other survey groups, which together
account for only 12.8 percent of the targeted wastes.
Since most of the survey industry groups themselves
represent multiple industries, which are often dissimilar in
characteristics other than waste generation, it is clear that a
large and diverse set of generators make up the affected SQG
population. The population includes both manufacturing and non-
manufacturing establishments, with services dominating the latter
category. No single industry dominates overall, although metal
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finishing, printing, photographic, cleaning and vehicle
maintenance processes appear to account for a large portion of
the affected population.
DESCRIPTION OP AFFECTED WASTES
Exhibit 3-2 shows the numbers of generators reporting each
waste, and the quantities of each waste reported, for the
targeted wastes. This exhibit excludes used batteries, as do all
following exhibits in this chapter. However, we have not been
able to adjust the estimates of number of generators to exclude
those that generate only batteries or that generate other wastes
in quantities less than 100 kg/month. Therefore, the numbers of
generators may be overstated by the figures shown in this and
following exhibits. Exhibit 3-2 shows that spent solvents are
the largest single category of targeted wastes, accounting for 46
percent of the total quantity reported. The next largest
category is acid and alkali wastes, accounting for 14.8 percent
of the total. The remainder of the wastes are distributed among
23 waste categories, no one of which accounts for more than 10
percent of the total.
Exhibit 3-3 shows the targeted wastes reported by each
survey industry group. This exhibit shows that virtually every
survey industry group reports spent solvents as a targeted waste.
Note that 41 percent of the reported spent solvent wastes are
reported by vehicle maintenance generators; these wastes will
not be subject to regulation for any generator that does not
exceed the SQG quantity cutoff with batteries excluded. Vehicle
maintenance generators also account for substantial portions of
the total acids and alkalies and other ignitable wastes reported.
These two waste groups are also reported as targeted wastes by a
large number of industries, as are ignitable paint wastes and
solvent still bottoms. Other wastes tend to be reported by only
a few industries, reflecting the £ priori expectations about what
each industry would be likely to generate.
The survey target waste categories may in some cases include
wastes with diverse characteristics. While some waste groups
(such as formaldehyde, wood preserving wastewater treatment
sludges and dry cleaning filtration residues) are relatively easy
to characterize, other groups are difficult to characterize
precisely. For example, the two largest waste groups spent
solvents and acids and alkalies are generated by numerous
industry groups and contain widely varying constituents.
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The diversity of the wastes generated by SQGs, as well as
the diversity of the SQGs themselves, makes it difficult to
generalize about the effects of regulations on SQGs. In this
report, we have attempted to report results separately for groups
that are affected differently, and to qualify general statements
where necessary to note important exceptions. Readers are urged
to use caution, however, in assuming that general statements
about the SQG population as a whole are applicable to a
particular industry group or type of waste.
DESCRIPTION OF MANAGEMENT PRACTICES
This section describes the management practices reported by
the surveyed industry groups for the targeted wastes. The
nature of current practices determines both the risks to human
health and the environment posed by SQGs and the changes that
SQGs will have to make as a result of the proposed regulations.
Appendix C provides detailed tabulations of the survey results
that support the discussion in this section. Throughout this
section, we have excluded batteries from waste quantities, but
have included all vehicle maintenance and motor freight terminal
generators and the non-battery wastes generated by these groups.
The survey results reported in this section must be
interpreted carefully because of multiple responses for a single
waste stream. Respondents were asked to indicate as many
management practices as applied for each waste. To develop
estimates of quantities managed in different ways, it was
necessary to assume that the entire quantity reported for each
waste was managed by each of the methods reported for that waste.
For example, if the respondent reported generating 15 MT of a
specific waste and the respondent reported both on-site treatment
and off-site disposal for that waste, then the survey tabulations
would include 15 MT for on-site treatment and 15 MT for off-site
disposal.
Where multiple practices are reported, total quantities
reported by practice may be over- or understated for two reasons.
First, the respondent may use one practice for the particular
waste on some occasions and another on other occasions. The
method used to assign quantities to practices assumes that both
practices are used for the full amount of the reported waste, and
thus will overstate quantities for the individual practices.
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Second, for sequential practices (e.g. for treatment prior
to disposal), the method used to assign quantities to practices
does not take account of potential changes in waste quantities
resulting from intermediate practices. For example, evaporation
to dewater aqueous wastes might substantially reduce volumes
prior to disposal in a landfill. However, if a respondent
reported both evaporation and landfilling for a particular waste,
the entire quantity of waste generated would be reported in the
survey tabulations as landfilled. Intermediate practices that
increase waste volume (such as dilution or solidification) also
may not be accounted for properly in the quantities reported for
the final disposal practices.
Respondents may also have been inconsistent in their
reporting of treatment residuals. For example, some respondents
may have reported both neutralization and discharge to sewers for
a given waste, even though the neutralized waste discharged to
sewers is not likely to be hazardous. In these cases, total
quantities of hazardous wastes being discharged to sewers will be
overstated. In other cases, respondents might report treatment
(e.g. filtration) that generates a hazardous waste, but might not
report management of the hazardous residuals as targeted wastes
elsewhere in the survey.
The survey results are difficult to interpret, then,
for wastes subject to some kind of treatment and wastes for
which multiple practices are reported. The results reported in
this section should be interpreted as the quantities of wastes
that are ultimately managed (or are sometimes managed) by the
reported practices.
Exhibit 3-4 provides an overview of SQG waste management
practices. That exhibit shows that nearly 120,000 MT per year
of targeted wastes are managed in some form off-site, and 79,000
MT of wastes are managed per year on-site. Of the total of
188,000 MT of targeted wastes generated per year, only 79,000 MT
per year are reported as ultimately disposed 32,000 MT off-
site and 47,000 on-site. This reflects substantial use of
recycling (62,000 MT of wastes for off-site recycling and 29,000
MT of wastes for on-site recycling), and more limited on-site
treatment (19,000 MT/year). Respondents reported that they did
not know the destination of wastes sent off-site for another
36,000 MT of target wastes per year. (Based on conversations with
respondents, Abt Associates believes that most of this amount is
disposed in solid waste landfills.) The sum of reported
treatment, recycling, and disposal exceeds the total reported
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generated (less the amount going to unknown destinations) by
only 25 percent (189/000 MT per year vs. 152,000 MT per year),
suggesting that treatment or recycling prior to the reported
disposal practices is the exception rather than the rule.
Exhibit 3-5 provides the same overview of practices by
waste. Practices by waste were summarized only for the five
largest quantity waste categories in the Survey Report: spent
solvents, acids and alkalies, photographic wastes, ignitable
paint wastes, and other ignitable wastes. To support analyses of
costs, special survey tabulations were prepared which report
specific waste management practices for 24 of the 25 waste
streams on the basis of numbers of generators, rather than waste
quantity.!/ lEc used these estimates of numbers of generators to
estimate the quantities of wastes managed by each specific
treatment, disposal, or recycling practice for 19 of the 24 waste
streams. The procedure used to estimate quantities by practice
applied estimated average quantities per generator for each waste
adjusted to reflect differences in average quantities managed
by practice based on averages for all wastes to the number of
generators reporting each practice for each waste. This
procedure does not provide precise estimates of the distribution
of quantities by practice for each waste, but does provide a
rough measure of quantities by practice. The waste values
reported for the 5 waste streams summarized in the Survey Report
were used when possible to characterize the different management
practices. However, a number of practices reported in the
tabulations prepared for the cost analysis were not accounted for
in the Survey Report. In these instances., lEc applied the
previously described methodology to derive the missing waste
quantity for that particular management practice for the top five
wastes.
Five of the waste streams account for 75 percent of the
total quantities of waste reported. Of these, spent solvents are
managed primarily by recycling (62,000 MT, of which nearly 40,000
MT are reclaimed) and by hazardous waste incineration (5,200 MT) .
The disposal method used most often for acids and alkalies is
discharge to sewers (7,600 MT) followed by recycling (4,000 MT,
of which 2,800 MT are reclaimed). Disposal to sewers is also
the most prevalent management practice for photographic wastes
I/ Only total quantities of waste were reported for the "paint
wastes with metals" waste category.
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(12,000 MT or 84 percent of all photographic wastes). The
greatest amounts of dry cleaning filtration wastes are managed in
solid waste landfills (3,400 MT) or are disposed of in sewers
(1,500 MT) . Wastes containing silver are most often recycled
(5,300 MT), either by use/reuse or reclamation, or are disposed
of in sewers (3,600 MT). As shown in Exhibit 3-5, nearly equal
amounts of all 25 waste streams are managed on and off site. More
wastes are managed by recycling (47 percent) than by disposal (42
percent). A much smaller portion of the wastes are managed by
treatment (10 percent).
Recycling is reported as a management practice for nearly
every waste stream. Only wastes with ammonia and formaldehyde
wastes are not reported recycled in some manner. More than twice
as much waste is recycled off site (60,000 MT) as is recycled on-
site (27,000 MT). Spent solvents are recycled in the greatest
quantity: nearly 62,000 MT, accounting for over 70 percent of
all waste streams recycled. The majority of these spent solvents
are recycled off-site. Wastes containing silver (6 percent of
all recycled wastes) and acids and alkalies (4 percent) are the
other wastes that are most often recycled. Of the six off-site
recycling methods reported, reclamation is reported most often
(50 percent of all wastes recycled). Use/reuse is the next most
common type of method reported for off-site recycling (17
percent of all recycled wastes.) For on-site recycling,
reclamation and use/reuse are the methods reported most often.
Disposal is reported for 42 percent of all SQG wastes.
Disposal occurs somewhat more on-site (47,000 MT) than off-site
(30,000 MT). The prevalence of on-site disposal is attributable
to the large quantities disposed to sewers. Nearly 39,000 MT or
50 percent of all wastes disposed are managed by disposal to
sewers, which accounts for 21 percent of all wastes disposed,
treated, or recycled. Three wastes account for nearly two-thirds
of all wastes disposal to sewers: photographic wastes (12,000
MT), followed by acids and alkalies (8,000 MT), and formaldehyde
(5,000 MT) . Other waste streams that are disposed to sewers in
quantities greater than 2,000 MT/year include spent solvents,
wastes containing silver, and spent plating wastes. Only three
of the waste streams are not reported to be disposed in sewers:
waste inks with solvents and metals, arsenic wastes, and other
heavy metals.
A smaller portion of all waste streams are managed in
sanitary and hazardous waste landfills. More than 12,000 MT (7
percent of all wastes) are disposed of in sanitary landfills,
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most of which are located off-site. Dry cleaning filtration
residues account for the greatest portion of wastes landfilled in
Subtitle D facilities (27 percent or 3,400 MT). Spent solvents
are also frequently landfilled (2,700 MT), as are other ignitable
wastes (2/000 MT) . Fifteen other waste streams are disposed in
somewhat smaller quantities in sanitary landfills. Nearly equal
quantities wastes (11,000 MT) are disposed of in hazardous waste
landfills. Spent solvents are the wastes most commonly disposed
of in Subtitle C facilities (4,300 MT). Other wastes disposed of
in hazardous waste landfills include dry cleaning filtration
residues (1,100 MT) and spent plating wastes (less than 1,000
MT) .
Very few SQG wastes are managed either by incineration or by
disposal to septic systems. Most incineration at hazardous waste
facilities take place off-site, whereas incineration at solid
waste facilities occurs both on- and off-site. Spent solvents
are the wastes most often incinerated, both at hazardous waste
facilities (5,200 MT) and solid waste facilities (1,100 MT) .
Eighteen waste streams are reported as being disposed of in
septic systems (3,600 MT) . Nearly half of the wastes disposed of
in septic tanks are acids and alkalies.
Nearly ten percent of all wastes (18,000 MT) are subject to
some kind of treatment. Most treatment occurs on-site. Acids
and alkalies are treated in the largest quantities (6,400 MT) ,
followed by spent solvents (2,300 MT) and spent plating wastes
(1,300 MT). The most prevalent methods of treatment for all
wastes treated are neutralization (45 percent), evaporation (21
percent), and filtration (19 percent). These first two practices
may often be used as pretreatment processes prior to disposal in
sewers. Numerous other practices are used to manage the
remaining 8,000 MT of treated wastes.
It is important to note that it is not known how nearly
20,000 MT (11 percent) of wastes are managed. By far, the
greatest proportion of these wastes are spent solvents (17,000
MT). As discussed previously, Abt Associates reports that most
of this amount is likely to be disposed in solid waste
landfills.
Exhibits 3-6 through 3-9 provide summaries of the on- and
off-site management practices. These exhibits are based on
survey tabulations by industry based on results from the Survey
Report, rather than the estimated results by waste reported in
3-11
-------
Exhibit 3-5. These exhibits provide more accurate measures of
total quantities managed by different methods than the totals
shown in Exhibit 3-5.
Exhibit 3-6 shows the distribution of on-site disposal, and
confirms that on-site disposal is dominated (in terms of quantity
disposed) by disposal to sewers, followed by disposal to septic
systems. Other forms of on-site disposal are not used
extensively.
Exhibit 3-7 provides detailed information on the forms of
on-site treatment reported. Although on-site treatment
represents a relatively small part of SQGs1 waste management
practices, the treatment methods used are numerous.
Neutralization accounts for the largest quantities treated, and
for the largest percentage of on-site treaters. Evaporation and
filtration are also relatively common, accounting for
approximately 4,000 MT/year in both cases.
The survey results do not specify whether treatment takes
place in tanks, surface impoundments, or other types of
facilities. The regulation of on-site treatment practices will
vary depending on the type of treatment "receptacle". It is
likely that some of the reported neutralization, evaporation, and
biological treatment takes place in surface impoundments, while
other types of treatment are more likely to be performed in tanks
or other types of units.
Exhibit 3-8 reports the types of recycling performed on-
site. Various forms of use or reuse of wastes is practiced most
frequently, although reclamation accounts for a larger portion of
the wastes recycled on-site. (Recall that certain wastes that
are used or reused will not be subject to the proposed
regulations.) An estimated 5,000 MT/year is burned for energy
recovery directly, with insignificant quantities being blended to
produce fuels. Recycling involving application to the land is
also practiced in only a relatively few cases.
Exhibit 3-9 provides information on off-site management
practices. The results reported in this exhibit for disposal
were derived by summing results for the specific forms of
disposal reported in the Survey Report, whereas the Survey Report
provided totals for recycling and treatment directly. These
results confirm that off-site recycling accounts for a
substantial portion of off-site management, and that a
significant number of SQGs (16 percent of those reporting off-
3-12
-------
site management) do not know where their wastes are ultimately
managed or how. (These generators account for 18 percent of the
waste quantities managed off-site and possibly more.)
Appendix C to this report presents more detailed information
on the practices discussed above, by industry group and by waste.
DESCRIPTION OF STORAGE PRACTICES
This section provides a brief summary of the survey results
on SQG storage practices. Exhibit 3-10 presents information on
the extent to which SQGs are currently storing wastes. More than
half of the wastes managed on-site are not stored prior to
treatment, storage or disposal undoubtedly reflecting the
common use of disposal to sewers and septic tanks. Approximately
one-quarter of the wastes managed off-site are reportedly also
not stored. The quantities not stored together account for 40
percent of all wastes generated. (Note that storage could become
more common if the SQG regulations require greater use of
practices that involve accumulation of wastes on-site prior to
ultimate treatment, recycling or disposal.)
Of the quantities of wastes reported stored, 85 percent is
stored for less than 180 days. The proportion stored less than
180 days is nearly the same for wastes managed on- and off-site.
Note, however, that these results are uncertain, because the
Survey Report did not distinguish between SQGs storing for an
average of one to seven days and those not storing at all.
Therefore, lEc developed estimates of the minimum extent of
storage for less than 180 days.
Exhibit 3-11 reports the types of storage used. The largest
quantities of waste are stored in closed metal drums. This
practice accounts for more than one-third of the quantities being
managed off-site. A substantial percentage (40 percent) of the
SQGs managing wastes off-site also store wastes in piles,
although this practice is used only for 18 percent of the wastes
managed off-site. Storage in closed metal drums is also common
for wastes managed on-site, as (to a lesser extent) is the use of
above ground tanks. Use of open drums and pails is substantially
less common.
3-13
-------
DESCRIPTION OF TRANSPORTATION PRACTICES
Exhibit 3-12 provides information on the types of
transportation used by those SQGs sending their wastes off-site
for management. An estimated 77 percent of these SQGs transport
in contracted trucks (accounting for 71 percent of the wastes
sent off-site.) Company-owned trucks are used by 13 percent of
the SQGs (for 9 percent of the wastes managed off-site.) Public
trucks are used by fewer SQGs (nine percent of those shipping
off-site) for 9 percent of the wastes going off-site.
Ninety percent of the respondents shipping off-site report
notifying transporters that the wastes shipped are hazardous.
Exhibit 3-13 reports the methods used to notify shippers.
Approximately one-quarter of the respondents shipping off-site
use more than one method. The most common method used is verbal
notification providing no guarantee that the destination
facility is notified about the properties of the wastes. Twenty-
one percent report labelling containers (for 29 percent of the
wastes going off-site.) Relatively few (7 percent) report using
EPA manifests and/or DOT shipping papers, although these methods
are used for 30 percent of the wastes shipped off-site.
3-14
-------
- Exhibit 3-1
SUMMARY: SQGs GENERATING 100-1000 KG/MONTH BY INDUSTRY
NO. OF GENERATORS
Number Percent
WASTE QUANTITY*
MT/Year Percent
INDUSTRY GROUP
Pesticide End-Users
Pesticide Applicators
Chenical Manufacturing
Wood Preserving
Formulators
Laundries
Other Services
Photography
Textile Manufacturing
Vehicle Maintenance
Equipment Repair
Metal Manufacturing
Construction
Motor Freight Terminals
Furniture Mfg/Refinish
Printing
Cln. Agents/Cosmetics
Other Manufacturing
Paper Industry
Laboratories
Education/Voc. Shops
Wholesale/Retail Sales
TOTAL** 113,086 100.0% 187,804 100.0%
* Waste quantities exclude used lead-acid batteries.
** Total number of SQGs by industry exludes 7 SQGs not identified
by industry.
Source: SQG Survey; includes only surveyed primary industries and
targeted wastes.
231
1,660
391
107
395
2,515
2,409
2,817
124
82,528
269
11,076
1,117
45
579
3,420
265
946
83
1,286
241
575
.2%
1.5%
.3%
.1%
.3%
2.2%
2.1%
2.5%
.1%
73.0%
.2%
9.8%
1.0%
.5%
3.0%
.2%
.8%
.1%
1.1%
.2%
.5%
918
6,451
2,223
688
2,145
8,272
6,891
16,095
602
48,899
650
58,159
2,974
59
3,100
13,178
1,454
4,871
496
5,909
888
2,882
.5%
3.4%
1.2%
.4%
1,1%
4.4%
3.7%
8.6%
.3%
26.0%
.3%
31.0%
1.6%
1.7%
7.0%
.8%
2.6%
.3%
3.1%
.5%
1.5%
AVERAGE
Q/MONTH
(Kg/mo.)
331
324
474
536
453
274
238
476
405
49
201
438
222
109
446
321
457
429
498
383
307
418
138
-------
Exhibit 3-2
NUMBER OF SQGs AND QUANTITY OF WASTE BY WASTE STREAM*
WASTE STREAM
Spent Solvents
Solvent Still. Bottoms
Dry Cl. Filtrat. Res.
Acids and Alkalies
Photographic Wastes
Ignitable Paint Wastes
Other Ignitable Wastes
Paint Wastes w/ Metals
Heavy Metal Dusts
Heavy Metal Solutions
Heavy Metal - Other
Cyanide Wastes
Other Reactive Wastes
Waste Pesticides
Pesticide Containers
Pesticide Solutions
Wood Pres. WWT Sludge
Ink Sludges w/Chromium
Wastes cont. Ammonia
Wastes cont. Silver
Formaldehyde
Spent Plating Wastes
Arsenic Wastes
Waste Inks w/Solvents
& Metals
WWT Sludges w/ Metals
TOTAL
NUMBER
OF SQGs
33,475
738
2,540
10,480
4,949
3,122
2,873
156
40
30
117
1,384
497
990
1,963
1,747
108
83
100
2,648
2,014
1,422
19
718
790
113,086**
QUANTITY
OF WASTE
(MT/year)
85,923
1,863
8,509
27,821
14,023
4,872
7,576
7
163
52
537
2,129
1,090
857
2,366
5,022
693
127
271
7,981
5,396
5,275
104
1,359
2,216
187,804***
AVERAGE
PER MONTH
(kg/month)
214
210
279
221
236
130
220
4
340
144
382
128
183
72
100
240
535
128
226
251
223
309
456
158
234
138
Excludes used lead-acid batteries.
**
Sum of number of generators reporting specific waste streams is
only 73,003. This suggests that a minimum of 40,083 SQGs, and
possibly more, reported only lead-acid batteries and/or non-
targeted wastes.
*** Type of waste not reported for 1,572 MT/year of waste.
Source: SQG Survey; includes only surveyed primary industries and
targeted wastes.
-------
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Exhibit 3-4
OVERVIEW OF SQG MANAGEMENT PRACTICES
STORAGE METHOD*
TOTAL SQG POPULATION:
Number of SQGs = 113,086**
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES CN-SITE MANAGING WASTES OFF-SITE
Number of SQGs Quantity of Waste Number of SQGs Quantity of Waste
Total Mgmt.
Disposal
Treatment
Recycling
Don't Know
f
27,354
17,767
5,824
11,420
%
24.2%
15.7%
5.2%
10.1%
MT/yr
79,408
47,286
18,573
28,583
%
42.3%
25.2%
9.9%
15.2%
*
99,252
14,596
439
75,733
16,143
%
87.8%
12.9%
.4%
67.0%
14.3%
MT/yr
119,857
32,267
1,064
61,979
35,785
%
63.8%
17.2%
.6%
33.0%
19.1%
* Waste quantities exclude lead-acid batteries.
** Total number of SQGs is not equal to the sum of on-site and off-site generators
because it includes SQGs that manage wastes both on-site and off-site.
SOURCE: SQG Survey; includes only surveyed primary industries and targeted wastes.
-------
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-------
Exhibit 3-6
OVER/TEW OP SQG MANAGEMENT PRACTICES:
ON-SITE DISPOSAL*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES ON-SITE
Number of SQGs** Quantity of Waste
# % MT/yr %
Total Disposing 17,724 100.0% 47,286 100.0%
Subtitle C 104 .6% 238 .5%
Incinerator
Subtitle CO 0
Landfill
Subtitle D 869 4.9% 760 1.6%
Incinerator
Subtitle D 78 .4% 70 .1%
Landfill
Sewer 8,278 46.7% 28,421 60.1%
System
Septic 1,342 7.6% 2,407 5.1%
System
Don't Know 50 .3% 79 .2%
Not Reported 7,046 39.8% 15,311 32.4%
* Waste quantities exclude used lead-acid batteries.
** Number of SQGs managing wastes on-site may also include those who
manage off-site.
Source: SQG survey; includes only surveyed primary industries and
targeted wastes.
-------
Exhibit 3-7
OVERVIEW OF SQG MANAGEMENT PRACTICES:
ON-SITE TREATMENT*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES ON-SITE
Number of SQGs Quantity of Waste
f % MT/yr %
Total Treating 5,824 100.0% 18,573 100.0%
Neutralization 1,429 24.5% 7,003 37.7%
Evaporation 1,268 21.8% 4,318 23.2%
Triple Rinse 325 5.6% 506 2.7%
Other Physical 47 .8% 70 .4%
Biological 15 .3% 90 .5%
Thermal 354 6.1% 513 2.8%
Electrolysis 253 4.3% 1,103 5.9%
Filtration 687 11.8% 4,144 22.3%
Dilution 34 .6% 30 .2%
Not Reported 1,412 24.2% 826 4.4%
* Waste quantities exclude used lead-acid batter.ies.
Source: SQG survey; includes only surveyed primary industries and
targeted wastes.
-------
Exhibit 3-8
OVERVIEW OF SQG MANAGEMENT PRACTICES;
ON-SITE RECYCLING*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES ON-SITE
Number of SQGs Quantity of Waste
f % MT/yr %
Total Recycling 11,420 100.0% 28,583 100.0%
Use/Reuse 5,189 45.4% 9,955 34.8%
Reclaimed 4,142 36.3% 11,930 41.7%
Blended for Fuel 5 11
Burned as Fuel 712 6.2% 5,097 17.8%
Applied to Land 139 1.2% 338 1.2%
Not Reported 1,233 10.8% 1,252 4.4%
* Waste quantities exclude used lead-acid batteries.
** Number of SQGS managing wastes on-site may also include
those who manage wastes off-site.
Source: SQG survey; includes only primary industries and
targeted wastes.
-------
Exhibit 3-9
OVERVIEW OF SQG MANAGEMENT PRACTICES;
OFF-SITE MANAGEMENT*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES OFF-SITE
Number of SQGs Quantity of Waste
* % MT/yr %
Total 99,252 100.0% 119,857 100.0%
Total Reported 14,596 14.7% 32,267 26.9%
Disposal
o Subtitle C:
. Landfill 2,831 2.9% 11,218 9.4%
.Incinerator 1,782 1.8% 6,679 5.6%
o Subtitle D
.Landfill 9,793 9.9% 13,937 11.6%
.Incinerator 191 .2% 433 .4%
Total To 625 .6% 1,064 .9%
Treatment
Total To 75,733 76.3% 61,979 51.7%
Recycling
Don't Know 16,143 16.3% 35,785 29.9%
* Waste quantities exclude used lead-acid batteries.
Source: SQG survey; includes only primary industries and
targeted wastes.
-------
Exhibit 3-10
OVERVIEW OF SQG STORAGE PRACTICES:
PERIOD STORED
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES CN-SITE MANAGING WASTES OFF-SITE
Number of SQGs Quantity of Waste Number of SQGs Quantity of Waste
t % MT/yr % * % MT/yr %
Total 27,354 24.2% 79,408 42.3% 99,252 87.8% 119,857 63.8%
<180 Days** 9,482 8.4% 27,072 14.4% 64,961 57.4% 81,416 43.4%
>=180 Days 2,973 2.6% 4,866 2.6% 7,186 6.4% 6,622 3.5%
No Storage 14,899 13.2% 47,470 25.3% 27,105 24.0% 31,819 16.9%
* Waste quantities exclude used lead-acid batteries.
** Minimum values; actual values may be higher. Calculated as larger number of (1) number
storing 8 - 180 days or (2) number storing all wastes less number storing more than 180
days.
Source: SQG survey; includes only primary industries and targeted wastes.
-------
Exhibit 3-11
OVERVIEW OF SQG STORAGE PRACTICES:
STORAGE METHOD*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES ON-SITE MANAGING WASTES OFF-SITE
Number of SQGs Quantity of Waste Number of SQGs Quantity of Waste
i % MT/yr % f % MT/yr %
Total
Storing
Bulk Waste
Container
Pails/
Garbage Cans
Piles
Metal Drums:
Closed
Open
Fiberboard
Drums:
Closed
Open
AtxKre-Ground
Tanks
Underground
Tanks
Surface
Impoundments
27,354
317
998
1,720
3,465
439
35 '
1,090
198
35
100.0%
1.2%
3.6%
6.3%
12.7%
1.6%
.1%
4.0%
.7%
.1%
79,408
1,000
1,917
1,945
12,079
1,044
142
7,223
190
187
100.0%
1.3%
2.4%
2.4%
15.2%
1.3%
.2%
9.1%
.2%
.2%
99,252
5,596
1,334
39,560
13,389
908
96
8
868
10
2,059
100.0%
5.6%
1.3%
39.9%
13.5%
.9%
.1%
.9%
2.1%
119,857
4,843
3,385
21,629
42,030
2,112
373
16
3,748
64
16,336
100.0%
4.0%
2.8%
18.0%
35.1%
1.8%
.3%
3.1%
.1%
13.6%
* Waste quantities exclude used lead-acid batteries.
Source: SQG survey; includes only primary industries and targeted wastes.
-------
Exhibit 3-12
OVERVIEW OF SQG TRANSPORTATION PRACTICES:
TRANSPORTATION METHOD*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES OFF-SITE
Number of SQGs Quantity of Waste
f % MT/yr %
Total 99,252 100.0% 119,857 100.0%
Contracted 76,005 76.6% 85,253 71.1%
Truck
Public 8,913 9.0% 11,342 9.5%
Truck
Company-Owned 12,618 12.7% 10,728 9.0%
Truck
Other 9,855 9.9% 15,838 13.2%
* Waste quantities exlcude used lead-acid batteries.
Source: SQG survey; includes only primary industries and
targeted wastes.
-------
Exhibit 3-13
OVERVIEW OF SQG TRANSPORTATION PRACTICES;
NOTIFICATION*
TOTAL SQG POPULATION:
Number of SQGs = 113,086
Quantity of Waste = 187,804 MT/Yr
MANAGING WASTES OFF-SITE
Number of SQGs Quantity of Waste
t % MT/yr %
Total 99,252 100.0% 119,857 100.0%
Transporting
Total Notifying 89,450 90.1% 107,298 89.5%
Transporter
o EPA Manifest 7,004 7.1% 36,139 30.2%
o DOT Shipping 1,254 1.3% 4,999 4.2%
Papers
o Labeled 28,375 28.6% 46,810 39.1%
Containers
o Other 73,664 74.2% 80,043 66.8%
Not Notifying 9,802 9.9% 12,559 10.5%
* Waste quantities exclude used lead-acid batteries.
Source: SQG survey; includes only primary industries and
targeted wastes.
-------
-------
REGULATORY REQUIREMENTS CHAPTER 4
INTRODUCTION
This chapter describes the requirements that will be imposed
on SQGs as a result of the proposed regulation, and alternatives
to the proposed regulation. We first provide an overview of the
changes that would be required for the various current SQG
practices described in Chapter 3. Then, we describe in more
detail the requirements applying to all generators of between 100
and 1,000 kg/month, to generators sending wastes off-site, to
generators storing wastes on-site for various periods, and to
generators treating and/or disposing of wastes on-site. For
convenience, we describe the requirements that would apply if
full large quantity generator (LQG) regulations were imposed for
SQGs in each section, and then discuss how alternative regulatory
strategies would differ from full application of the LQG
regulations. This chapter provides the basis for determining
incremental costs, as presented in Chapter 6, based on changes in
practices required to comply with the regulation.
EFFECTS ON VARIOUS SQG PRACTICES
The Agency proposes requiring that SQG wastes be managed in
Subtitle C facilities that is, in facilities that comply with
Part 265 requirements for storage, treatment and/or disposal
during the interim status period and that comply with full Part
264 standards when final Part B permits are issued. The HSWA
allow EPA to apply different Part 264 and 265 requirements to
SQGs (and presumably to off-site facilities that handle only SQG
wastes) where different standards would be protective of human
health and the environment.
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As noted in Chapter 2, the Agency is not considering any
reductions in requirements for off-site facilities receiving
hazardous wastes from SQGs. It will not be possible under the new
regulations for SQGs to continue sending wastes to off-site solid
waste landfills or incinerators. Any landfill or incinerator
facility currently accepting hazardous wastes from SQGs
generating more than 100 kg per month would have to comply with
full Part 264 and 265 standards to continue doing so. The same
applies to any off-site treatment facility. Off-site recycling
facilities receiving SQG wastes may be in compliance with RCRA
storage facility requirements already, since it is not likely
that many recyclers of hazardous wastes currently handle only
wastes from generators of less than 1,000 kg/month. These
recycling facilities are subject to requirements as storage faci-
lities for the hazardous wastes received for recycling, and to
generator and other Subtitle C requirements for any wastes gene-
rated by the recycling facility. However, currently there are no
RCRA standards applied on the recycling activities themselves.
In general, then, SQGs will no longer be able to send wastes to
off-site treatment, storage, disposal or recycling facilities
that do not comply with the applicable Subtitle C requirements.
This requirement in effect bans the practice of placing hazardous
wastes in dumpsters, otherwise sending hazardous wastes to sani-
tary landfills or open dumps, or sending wastes to solid waste
incinerators (e.g., municipal incinerators).
SQGs must also comply with applicable Subtitle C
requirements if they store, treat, recycle or dispose of wastes
on-site. In general, the LQG requirements impose "general
facility requirements" administrative, recordkeeping and
reporting, facility closure, financial assurance and liability
insurance, personnel training, contingency planning, waste
analysis, and general "good housekeeping" requirements for any
on-site treatment, storage or disposal facility (TSDF). Detailed
technical standards have been issued for storage activities, for
treatment in tanks, and for landfills, land treatment, surface
impoundments, and incinerator treatment or disposal. Treatment
that does not take place in or on the land or in tanks (thermal
treatment other than incineration, and possibly chemical,
physical or biological treatment) is subject to waste analysis,
inspection, closure and general operating requirements. Detailed
technical standards have not yet been issued for these other
types of treatment under Part 264. Subtitle C requirements are
described in more detail later in this chapter.
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The need for SQGs to comply with Subtitle C requirements to
continue on-site treatment or disposal may discourage SQGs from
continuing some practices. For example, a SQG discharging wastes
to a septic system is unlikely to comply with the general
facility requirements in order to be able to continue that
practice. Similarly, treatment that involves placing wastes on
the land such as neutralization in surface impoundments,
evaporation by spreading wastes on the land, and other such
practices would be subject to the appropriate landfill, land
treatment or surface impoundment requirements, and might be a
very costly waste management practice for SQGs once the proposed
regulations are in effect. While a number of SQG practices are
not prohibited, strictly speaking, the need to comply with
Subtitle C general facility and technology-specific practices
will make many if not most practices economically impractical.
Further, liabilities for corrective action associated with on-
site management (required by Section 206 of the HSWA and covering
the effects of past waste releases as well as releases from
current operations) is likely to discourage SQGs from becoming
permitted as TSDFs.
Certain SQG management practices are subject to different
requirements than other forms of treatment or disposal. These
include disposal to septic tanks, disposal to sewers, and
recycling activities of various types.
Septic tanks are regulated under the Underground Injection
Control (UIC) Program authorized by the Safe Drinking Water Act
and RCRA. A septic tank meets the definition of an injection
well because it is a bored, drilled or driven shaft, or a dug
hole, whose depth is greater than its largest surface dimension,
into which fluids (materials or substances which flow or move,
whether in a semi-solid, liquid, sludge, gas or any other form or
state) are injected. Operators of wells into which hazardous
wastes are injected are required to apply for permits under the
UIC Program, comply with detailed UIC Program requirements for
monitoring, recordkeeping and financial responsibility, and
comply with some RCRA facility standards such as personnel
training, maintaining a contingency plan and operating record,
and closure requirements. The proposed SQG rules do not require
SQGs discharging wastes to comply with the requirements for
injection wells. Rather, these standards are already applicable.
It is not known whether SQGs reporting disposal to septic systems
are complying with UIC requirements or are likely to. The cost
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analysis reported in Chapter 6 assumes that this practice
continues where it is reported, but in fact disposal to septic
tanks may effectively be banned by the UIC requirements.
Generators are not subject to RCRA Subtitle C requirements
for discharge of hazardous wastes to sewers, since those
discharges are subject to the requirements of the Clean Water Act
(PL 92-500). Under the RCRA provisions in 40 CFR 261.4, any
wastes that are mixed with domestic sewage that passes through a
sewer system to a Publicly-Owned Treatment Work (POTW) for
treatment, as well as any industrial wastewater discharges that
are point sources subject to regulation under Section 402 of the
Clean Water Act, are not subject to RCRA regulations. Any
treatment or storage of wastes prior to discharge to sewers would
be subject to applicable RCRA requirements, however, and
hazardous sludges from the pretreatment of such wastes would also
be subject to RCRA requirements. However, the discharge to
sewers of wastes that would otherwise have to be managed in
facilities subject to Subtitle C requirements is not prohibited
by RCRA for either LQGs or SQGs. (The risks potentially posed by
these discharges are discussed in Chapter 7.)
Under the new Definition of Solid Waste (published in the
Federal Register January 4, 1985), various provisions apply for
wastes that are recycled. Recycling may include use or reuse of
a waste material as a feedstock or as a substitute for new
products ("use/reuse"), reclamation of materials from a waste or
regeneration of wastes ("reclamation"), burning of a waste to
recover energy, or various forms of "use constituting disposal"
(use that involves placing wastes or products derived from wastes
on the land, such as use for fill, for fertilizers, or as dust
suppressants).
Under the new Definition, use constituting disposal of any
RCRA hazardous waste is subject to full land disposal
requirements for landfills or land treatment. Further, these
wastes are subject to all generator, storage and transportation
requirements prior to the use constituting disposal. Therefore,
SQGs currently applying wastes to the land for some reuse purpose
will have to comply with the full set of RCRA requirements to
continue doing so. These requirements will effectively ban the
reuse of wastes involving placement on the land (except where a
facility is already complying with the applicable regulations for
other reasons and the facility would not have to be expanded
significantly to continue use constituting disposal). The only
exception is a temporary exemption from RCRA requirements for
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wastes that are incorporated in a product or a commercial
fertilizer, where the waste undergoes some significant chemical
or biological change before being placed on the land.
Any wastes used or reused as is (without prior processing),
other than use constituting disposal, are not subject to any RCRA
requirements, as long as the wastes are used/reused within a
given period of time. As noted in Chapter 3, these materials
are not defined as solid wastes and therefore are not included in
determining whether a SQG exceeds the proposed 100 kg/month
limit.
Some hazardous wastes burned for energy recovery (or blended
to produce a fuel) are currently subject to generator, storage
and transportation requirements prior to burning. Other wastes
not currently regulated when burned for energy recovery
(characteristic spent materials and by-products), as well as the
process of burning itself, will be subject to new requirements
under a two-phase regulatory program for waste-as-fuel
activities. The HSWA allow for an exemption from RCRA
requirements for burning of "de minimis" quantities of hazardous
wastes, the regulations currently being considered by the Agency
may include such exemption based on quantities burned. If they
do not, any SQGs burning wastes for fuel, blending wastes to
produce a fuel, or sending wastes off-site for use as a fuel, may
be subject to requirements for that practice when the proposed
SQG regulations take effect.
Final action for the first phase of waste-as-fuel
regulations is expected in August 1985, which is before the
proposed SQG regulations will take effect. These initial
regulations extend generator, transportation and storage
requirements to all hazardous wastes burned as fuel. The
regulations will also ban burning of wastes as fuel in any non-
industrial boilers, pending promulgation of the second-phase
regulations. (Non-industrial boilers are devices which produce
steam for heating purposes and are not used as part of a
production process.) Thus, SQGs burning wastes in non-
industrial boilers will have to discontinue burning of wastes for
fuel, at least temporarily. Eventually, some of the SQGs may be
able to continue burning wastes as fuel, as long as they comply
with the technical requirements to be issued under the Phase II
regulatory package. (Final action for these regulations is
currently projected for August 1987.) The Phase II requirements
currently being considered by the Agency would impose the
equivalent of the incinerator requirements except for certain
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types of boilers, and will require use of air pollution control
devices if wastes contain metals exceeding specified limits.
While some SQGs may be able to continue burning once they comply
with these regulations, it is unlikely that many generators
burning small quantities will find it worthwhile to comply with
the technical requirements to continue doing so, in the absence
of a de minimis exemption. However, SQGs sending wastes off-site
for burning may continue doing so if they comply with the
generator, storage and transportation requirements for these
wastes. The cost analysis reported in Chapter 6 assumed that
SQGs' use of wastes as fuel continues under the proposed rule.
Hazardous materials that are reclaimed are subject to
different requirements, depending on the type of material
involved. Non-listed (characteristic) by-products and sludges
and commercial chemical products are not defined as solid wastes
when reclaimed, and hence (like materials that are used or
reused) are not subject to RCRA Subtitle C requirements and are
not included in the SQG quantity determination. All listed
wastes, as well as characteristic spent materials, are subject to
applicable generator, transporter, and storage requirements for
those wastes prior to reclamation. Therefore, a SQG reclaiming
wastes on-site would be subject to minimal requirements if wastes
destined for reclaiming were stored less than 180 days.
In summary, we assume for this study that any recycling
involving application to the land will be effectively (although
not literally) prohibited, because compliance with the
appropriate regulations would make these practices uneconomic.
On-site burning of wastes as fuel may be discontinued if
forthcoming regulations for this practice do not include a de
minimis exemption. This study assumes that such practices
continue. SQGs may also continue blending wastes to be burned as
fuel by others. SQGs might continue to treat, store and dispose
of wastes on-site, but in most cases will find on-site waste
management too costly (as discussed in Chapter 6). SQGs
recycling wastes either on- or off-site are likely to continue
doing so, since (except for burning wastes for energy recovery
and use in applications on the land) reclaiming and use or reuse
are subject to limited or no RCRA Subtitle C requirements,
respectively.
The next sections describe in more detail the requirements
that will apply for various SQG practices under the proposed
regulation and under alternatives, and discuss some of the
practical differences among alternatives.
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GENERATOR REQUIREMENTS
The individual generator requirements were listed previously
in Chapter 2. The major components of the requirements for which
alternatives were considered include:
o notification to obtain an EPA identification number;
o manifest requirements;
o use of hazardous waste transporters;
o biennial reporting;
o recordkeeping; and
o requirements for on-site storage in tanks and
containers during the allowed "accumulation"
period.
Each of these provisions is discussed below.
Notification
The regulations require generators (as well as TSDFs) to
notify EPA about their hazardous waste activities using a
standard form. That form requires information on the identity of
the generator, a list of the EPA wastes generated, and a very
general indication of regulated activities (generation,
treatment/storage/disposal, and/or transportation.) The
notification serves two functions: (1) it provides a mechanism
for assigning unique generator identification numbers that are
then used in completing manifests and in various reporting
activities, and (2) it alerts EPA and the States that an
establishment is engaged in hazardous waste activities, thereby
making inspections, education or "outreach" efforts, or
enforcement actions easier.
The Agency could require notification without then assigning
unique identification numbers, for some or all SQGs. For
example, the Agency might assign numbers only to SQGs managing
wastes on-site or only to SQGs sending wastes off-site (and hence
using manifests). The benefits would be reduced administrative
burdens for EPA, because the Agency would not have to keep track
of the assigned numbers. The drawback would be increased
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difficulties in using generator reports by the Agency. SQG
identification numbers are also be needed to complete the Uniform
Manifest, and may be needed to aid enforcement of those
provisions. For example, California has now proposed to require
use of identification numbers for SQGs because of the need to
monitor compliance with the state's manifest requirements. Use
of a unique identifying number is necessary for any type of
computerized data base using reporting or manifest information.
Several of the states contacted by lEc or discussed in the Cadmus
report (Reference 13) have computerized manifest information, or
are doing so. Therefore, if States want to computerize
information on SQGs, either from biennial reports from off-site
TSDFs of (if a full manifest were imposed) from manifests,
identification numbers would be needed.
*
Obtaining an EPA identification number is unlikely to impose
burdens on SQGs that are any greater than those involved in
current use of business identification numbers for tax purposes.
Therefore, the Agency is proposing to require notification to
obtain identification numbers for all SQGs under all options.
The Agency considered developing a simplified format and
procedure for the notification requirement for SQGs. In
particular, the Agency considered: (1) a form which would only
request the name, address and signature of the SQG, and not
require waste identification information or information on
regulated activities, and (2) a system which would enable a SQG
to obtain an identification number over the telephone. The
simplified form was rejected because it would not result in any
significant savings to the generator. For example, a simplified
notification form for SQGs might not require that the SQG list
the wastes generated. This would ease the SQG's burden in
completing the notification, to the extent that understanding of
the RCRA waste codes would not be required. However, as noted in
Chapter 2, SQGs are currently responsible for determining whether
wastes are hazardous (and determining the EPA codes for the
wastes), and the Agency is not considering changing the existing
standard. To comply with these requirements, the SQG must become
familiar with the RCRA waste classification system in any event.
Therefore, providing the information on the notification form
should not pose a significant additional burden. To assist SQGs
with this requirement, the EPA-sponsored education program will
help SQGs determine the proper EPA code for their waste. The
second alternative (notification by telephone) was rejected due
to administrative and technical drawbacks, and the Agency's
conclusion that a written notification is necessary to maintain
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an adequate database of hazardous waste generators. The Agency
also decided against requesting more information from SQGs than
the current notification requires. (Some states contacted by lEc
stated that they require information on waste quantities and/or
management practices at the time of notification.)
Manifests
EPA has considered several options for the manifest
requirement. The two major options were: (1) imposing the
minimum requirements for the manifest as described in the HWSA;
and (2) imposing the full manifest system requirements currently
applied to LQGs. The full manifest requirements include:
o completion of the Uniform National Manifest in
triplicate;
o generator retention of forms signed by destination
facilities and transporters for three years;
o generator investigation of cases where a signed
manifest is not returned to the generator within
35 days of shipment; and
o generator "exception reports" filed with the
Regional Administrator when a signed manifest is
not returned within 45 days of shipment.
Under full manifest requirements, the following information is to
be provided on the manifest form:
1. a unique manifest document number;
2. the generator's name, mailing address, telephone
number, and EPA identification number;
3. the name and EPA identification number of each
transporter;
4. the name, address and EPA identification number of
the designated facility and an alternate facility,
if any;
5. the DOT description of the waste;
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6. the total quantity of hazardous waste and the
number of containers;
7. signatures of the transporter(s) and destination
facility; and
8. a certifying statement signed by the generator.
The minimum requirements stipulated in the HWSA eliminate
all of the manifest system requirements for recordkeeping and
reporting; require completion of only one copy of the manifest;
and eliminate manifest information requirements 1, 3, and 7
(described above); and the requirement for identification numbers
for the generator and the destination facility.
The full manifest system serves three purposes: (1) it
allows regulators to track the disposition of wastes, (2) it
allows generators to track the disposition of their wastes in
order to monitor their regulatory liability, and (3) it provides
information to persons handling the waste en route to ultimate
disposal. The partial manifest serves only the third purpose,
since it need not be returned by destination facilities.
Potentially-difficult aspects of the full manifest for SQGs
include the need to keep records to identify unreturned
manifests, the need to file exception reports, and the need to
retain manifests for three years. The Agency is proposing to
eliminate these requirements, as part of Option G2. Because the
partial manifest requirements will not require destination
facilities to return signed manifests to SQGs, it does not
provide an automatic mechanism for generators to determine
whether their wastes were delivered as planned. Since generators
retain liability for damages for wastes that are mishandled off-
site, this feature of the partial manifest system could reduce
benefits as well as costs to generators (as well as to
regulators). However, SQGs who wish to have a signed copy
returned by the destination facility have the option of
completing three copies of the manifest, since the regulations
will require destination facilities to sign and return manifests
unless only one copy is received.
Describing waste using the DOT classification system may
also be difficult for SQGs. The DOT list of hazardous materials
is lengthy and some SQGs may have difficulty selecting the
appropriate description. However, lEc's conversations with
transporters indicate that transporters frequently help
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generators (both large and small) in selecting the appropriate
DOT waste descriptions. In addition, the education program
being developed to support the SQG regulations will include
information to help SQGs select DOT codes for their wastes to the
fullest extent possible.
Although .the HSWA does not require that SQGs complete the
full Uniform National Manifest, the Agency is proposing that all
information be completed on the manifest (as is currently
required for LQGs) with the exception that SQGs do not need to
assign a unique identifying number to each manifest. The purpose
of the identifying number is to enable the matching of the
generator's copy of the manifest with the copy of the signed
manifest which is received from the destination facility. Since
the Agency is proposing that generators complete only one copy of
the manifest, a signed copy of the manifest need not be returned
to the generator from the destination facility, eliminating the
need for a unique identifying number to be assigned to the
manifest. The Agency does not believe that requiring the name,
EPA identification number and signature of the transporter and
the EPA identification number of the destination facility will
pose significant additional burdens on the generator.
Although the Agency is proposing to reduce the full manifest
requirements for SQGs by eliminating the manifest recordkeeping
and reporting requirements, the Agency is seeking public comment
on the proposed manifest system. In particular, the Agency is
interested in determining (1) to what extent the existing
requirements to complete the Uniform National Manifest, retain a
copy of the manifest for three years, and file exception reports
are burdensome and unnecessary for SQGs; (2) whether the savings
from reduced manifest requirements are significant enough to
offset the potential confusion arising from different
requirements for SQGs and LQGs; and (3) whether implementing
different manifest requirements for SQGs will hamper the
implementation of the existing requirements for LQGs.
The Agency is also proposing an exemption from the partial
manifest requirements for SQGs who reclaim their wastes under
the following conditions: (1) the generator must have a written
reclamation agreement with a recycling facility to collect and
reclaim a specified waste and to deliver regenerated material
back to the generator at a specified frequency; (2) the vehicle
used to transport the wastes and the regenerated material must be
owned and operated by the reclaimer; and (3) either the generator
or the reclaimer must retain ownership of the waste at all times.
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The Agency believes that the notice function of the partial
manifest is unnecessary under such circumstances. However, in
cases where no manifest is used, documentation is required to
prove that the wastes are handled under the arrangements
described above. In particular, the following requirements must
be met:
1. a copy of the reclamation agreement must be kept
by both parties; and
2. the reclaimer/transporter must record (and keep
for a minimum of 3 years) the following
information:
o the name, address and EPA identification
number of the generator,
o the quantity of waste accepted,
o all DOT required shipping information,
and
o the date the waste is accepted;
3. this record must accompany the waste as it is
shipped from generator to recycling facility.
The Agency is requesting comment on the proposed exemption from
manifest requirements, and on other cases where reductions in
manifest requirements may be justified.
Use of Hazardous Waste Transporters
Any shipment, of hazardous waste which is accompanied by a
manifest, and any carrier transporting such-a shipment is subject
to requirements under 40 CFR Part 263, the Hazardous Materials
Transportation Act (HMTA), and the Federal Motor Carriers Act
(FMCA). In addition, some states impose additional requirements
(e.g., minimum insurance requirements). The requirements under
40 CFR Part 263 and the applicable requirements of the HMTA for
labeling, marking, packaging, and placarding the waste
(incorporated in 40 CFR 262 (c) are considered by the Agency to
be necessary to protect human health and the environment during
the transportation of hazardous waste.
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The Agency is not proposing to reduce any requirements for
transporters of hazardous waste from SQGs, except as is necessary
to conform with the proposed use of a single copy of a manifest.
The transporter will be unable to keep a copy of the manifest for
himself or to return a signed copy of the manifest to the
generator as is required under the LQG regulations. However, the
transporter will be required to sign the manifest which
accompanies the waste shipment to its ultimate disposition.
Although the Agency is not proposing to reduce or alter the
existing transportation requirements for SQG wastes, the Agency
is concerned about the availability of transportation services to
SQGs, and about the costs of transporting small quantities. It
appears that Congress was also concerned about these issues and
in the HSWA directed EPA to conduct a study of SQG transportation
issues, and in particular to investigate the possibility of
allowing transporters to assume many of the administrative
requirements associated with the manifest.
In a study recently completed by EPA (Reference 25), the
Agency concluded that the proposed transportation requirements
(including the modifications to accommodate the use of a single
copy manifest) allow flexibility in transporting hazardous waste,
and are sufficient to protect human health and the environment.
In particular, the proposed regulations do not preclude
transporters from assuming many of the administrative
requirements associated with the manifest, with the exception
that the generator must sign the manifest and retain all legal
liabilities for complying with the requirements. The proposed
regulations also do not preclude generators from transporting
their own wastes as long as the appropriate EPA and DOT
requirements are met. Existing federal regulations do not impose
additional significant cost burdens on SQGs who decide to
transport their own wastes, because special trucks and equipment
are not required for containerized wastes. Although the Federal
Motor Carrier Act does impose financial responsibility and
liability requirements on transporters of hazardous waste, since
SQGs are likely to be transporting sufficiently small waste
quantities and using sufficiently small trucks they are likely to
be exempt from these requirements. Some states may have stricter
financial responsibility or liability requirements which may
effectively preclude SQGs from transporting their own wastes,
however.
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The Agency has considered lengthening the allowable
unpermitted storage period at transfer stations (currently ten
days for LQG wastes). However, the Agency has concluded (as
discussed in Chapter 2) that the existing ten-day period is
sufficient in most cases to allow for economic shipments to
TSDFs.
Although the Agency is not proposing to reduce or alter the
existing transportation requirements, it is requesting comments
from transporters on this issue. In particular, the Agency is
requesting comment on the utility of a single copy manifest.
Biennial Reporting
The LQG requirements require biennial reports to the
Regional Administrator for wastes shipped off-site/ including the
generator's identification number, lists of facilities and
transporters receiving wastes, and descriptions and quantities of
wastes shipped off-site. On- and off-site TSDFs must file
reports that identify the source of wastes (if received from off-
site) and the methods used to manage the wastes. The Agency
proposes to eliminate this requirement for SQGs sending wastes
off-site. The need to prepare and submit a biennial report could
represent a burden for some types of facilities, requiring
tabulation and aggregation of information from manifests. The
Agency will receive information on the management of SQG wastes
from the biennial reports submitted by off-site TSDFs. Since
these reports will exclude only wastes managed by SQGs on-site
(much of which is likely to involve recycling) and wastes sent to
off-site recyclers (if they are not regulated as storage
facilities), most treatment and disposal of SQG wastes is likely
to be covered in the reports received from off-site facilities.
Recordkeeping
The LQG regulations require generators to retain copies of
each returned manifest, exception report, biennial report, and
any results of waste analysis or waste testing for a period of
three years. In the case of any unresolved enforcement action or
a special request by the Regional Administrator, generators may
be required to retain these records for longer periods. Since
the Agency is proposing to use a one-way manifest for SQG
shipments, and to exempt SQGs from exception and biennial
reporting requirements, SQGs will also be exempt from
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requirements to retain these records. However, the Agency is not
proposing to exempt SQGs from the requirement to retain copies of
any waste analysis or waste testing results, since SQGs must
still determine whether their wastes are hazardous and identify
the material. The Agency does not believe that retaining these
records for three years, or for longer periods as specified
above, will pose a significant burden for SQGs.
fiequirements for On-Site Accumulation
The LQG regulations impose a limited set of storage
standards for generators accumulating wastes in tanks or
containers for less than 90 days, prior to shipping wastes off-
site or to on-site treatment, recycling or disposal. (Generators
storing wastes for any period in surface impoundments or waste
piles are subject to full Part 264 and 265 requirements.) These
"short-storage" standards are a subset of the storage facility
standards, and include the following:
o containers must be marked with the date on which
accumulation began;
o containers must be labeled with the words
"Hazardous Waste";
o containers must be compatible with wastes, must
not be leaking/ and must be closed during storage;
o containers holding ignitable or reactive wastes
must be located at least 15 meters (50 feet) from
the facility's property line (the "buffer zone");
o wastes must not be mingled in storage with
incompatible wastes;
o container storage areas must be inspected at least
weekly for leakage and deterioration;
o uncovered tanks must ensure adequate freeboard,
containment or diversion capacity;
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o tanks must be inspected weekly for damage to or
deterioration of construction materials and
confinement structures, and daily for operation of
discharge control equipment, monitoring equipment
data and waste levels;
o wastes and residues must be removed at closure
from tanks and surrounding structures;
o ignitable or reactive wastes must not be placed in
tanks except under specified circumstances;
o facilities must be equipped with specified
emergency equipment, unless none of the hazards
posed by the wastes handled would require a
particular kind of equipment;
o emergency equipment must be tested and maintained;
o personnel must have access to internal
alarm/communication systems and/or to telephone or
radio;
o sufficient aisle space must be maintained to allow
for the unobstructed movement of personnel and
emergency equipment;
o arrangements must be made with local authorities
to prepare for response in the event of an
emergency;
o facilities must prepare and maintain copies of
contingency plans;
o facilities must conduct personnel training,
directed by a party trained in hazardous waste
management procedures, covering at a minimum
emergency procedures, equipment and systems;
o reviews of training must be conducted annually;
and
o records must be kept until facility closure (or
three years after end of employment) for each
employee, including job titles, job descriptions,
and records of training.
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Many of these requirements call for good operating practices
that could not be waived without directly increasing the risks
from SQGs1 storage practices. These include requirements for
management, inspection and handling of wastes, containers and
tanks, as well as local arrangements to prepare for emergencies
and inspection requirements. The Agency proposes retaining these
requirements for SQGs storing wastes less than 180 days (or 270
days for up to 6000 kg of waste if shipping more than 200 miles).
In addition, labelling requirements do not impose
substantial burdens and are required for enforcement and
monitoring of compliance, as well as to provide notice that
hazardous wastes are stored. Again, the Agency proposes to
retain these requirements.
The Agency is not proposing to exempt SQGs from preparedness
and prevention requirements (proper facility maintenance,
availability and maintenance of necessary emergency equipment,
maintenance of aisle space for unobstructed movement of emergency
equipment and personnel, etc.). These requirements are necessary
"good housekeeping" standards and may vary based on the type and
quantity of waste generated, as well as the size of the
establishment (e.g., an internal alarm is not necessary where all
workers could maintain voice communications with each other).
These requirements are not particularly burdensome to SQGs and
are necessary to ensure safe management of hazardous wastes.
In other cases, the requirements for LQG storage during the
accumulation period are more elaborate than may be needed to
control hazards from storage of relatively small quantities of
SQG wastes. The requirements for a formal training program, with
extensive documentation and recordkeeping, and for a formal
contingency plan are potentially burdensome to SQGs, and more
elaborate than necessary to control hazards from storage in
limited quantities.
The Agency proposes to replace the employee training
program, contingency plan, emergency coordinator and emergency
procedure requirements with simplified standards more appropriate
for smaller businesses. These standards include the following:
1. an emergency coordinator (someone familiar with
these requirements) or someone designated to act
in his place must be on-site or on-call at all
times;
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2. a telephone must be located on-site, and the
following information posted next to it:
o the name and telephone number of the
emergency coordinator,
o the telephone number of the fire
department, and
o the location of fire extinguishers and
spill control equipment;
3. the generator must ensure that all employees are
thoroughly familiar with proper waste handling and
emergency procedures; and
4. the generator or emergency coordinator must
respond to any emergency that arises and must file
incident reports with the Regional Administrator
as necessary.
These requirements are included in the proposed Option G 2.
They are expected to reduce burdens on SQGs by eliminating
unnecessarily elaborate procedures for small storage facilities
and by reducing burdens associated with recordkeeping and
preparation of formal plans. However, the Agency is requesting
comment on these proposed standards and on alternative means of
ensuring safe facility management.
Finally, the existing buffer zone requirements might present
difficulties for some SQGs, who are located in urban areas, since
they may not be able to locate storage containers as far as 15
meters (50 feet) from property boundaries. The Agency has
proposed more flexible buffer zone requirements for all
generators. The proposed requirements establish varying setback
distances based on the type of waste involved.
TSDF REQUIREMENTS
The requirements for treatment, storage and disposal
facilities (TSDFs) include the basic requirements described
above for short-term storage. In addition, a number of
financial, closure, recordkeeping and reporting, security, waste
analysis, and monitoring requirements apply for all TSDFs, and
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specific design and operating standards are applied for different
TSD technologies. These requirements can impose substantial
costs on generators managing wastes on-site, especially where
quantities managed are small and the costs of the requirements
are more or less fixed with respect to the quantity of waste
managed.
Some features of the current TSDF requirements automatically
tailor requirements to the type of facility. Premiums for
liability insurance may be lower for smaller and less complex
facilities. Waste analyses and waste analysis plans can be
relatively simple for a facility managing a single waste of
consistent composition on-site. Finally, the Agency has proposed
use of a class permit for facilities where storage in containers
or above-ground tanks is the only activity requiring a permit.
The class permit would use a standard application form providing
most of the information required to process the permit, in the
form of answers to questions. The application would be processed
as a regular permit application, but would be substantially
easier for facilities to prepare. The procedures may be limited
for above-ground tanks to facilities that choose to install
secondary containment, rather than conducting ground water
monitoring (since the latter requirements require more complex
information on permit applications.) The class permit would
apply only for wastes generated on-site, and is scheduled for
promulgation at the end of September 1985.
In most cases, however, complying with the Part 264 and 265
requirements will impose costs that are proportionally greater
for smaller facilities, because costs do not vary in proportion
to quantity of waste or size of facility. Two cases serve to
illustrate the potential burdens. The first are the financial
assurance requirements. Facilities must provide assurance that
they are financially able to pay for proper closure (and for land
disposal facilities, post-closure care) for facilities.
Facilities may use one of a number of financial instruments to
provide the required assurance, ranging at the low-cost end from
a simple test of financial strength to the higher cost options
such as trust funds. To some extent the costs of these
requirements are tailored to the size and complexity of the
facility automatically, because the closure costs for which
financial assurance must be provided will vary with facility
size. However, there are a number of fixed costs associated with
selecting financial instruments, and the options to smaller firms
are generally more limited and costly.
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Firms owning facilities are also required to purchase
liability insurance in specified amounts. As noted above, the
cost of such insurance should differ to some extent based on the
size and complexity of the facility. Nonetheless, the need to
purchase a policy of a specified size imposes a relatively high
fixed cost for SQG facilities, especially if they are not owned
by firms with multiple locations subject to the requirement. In
addition, such insurance coverage is currently not widely
available. The Agency has recognized the current difficulties in
obtaining the required insurance by phasing-in the requirements
for liability insurance, based on measures of financial strength.
As another example, any SQG which uses land-based storage,
treatment or disposal is required to conduct groundwater
monitoring, to clean up any contamination that is detected, to
close sites properly, and to maintain care of facilities for 30
years after site closure. These requirements involve technical
expertise and financial resources not likely to be available to
many SQGs.
Both examples reflect requirements that are likely to make
on-site waste management costly for most SQGs. The Agency
believes that these provisions generally impose minimum
requirements to ensure practices that will be protective of human
health and the environment. While many SQGs might have
difficulty complying with the full Part 264 and 265 requirements,
because of lack of financial capability or technical expertise,
they would for the same reason have difficulty managing wastes
on-site properly.
Further, the Agency expects that only a small number of SQGs
would consider on-site management, given the substantial
liabilities involved. Section 206 of the HSWA will make
facilities liable for corrective action for any contamination of
the site, whether due to current operations or due to past
practices by previous owners. EPA is required to promulgate
regulations requiring financial assurance for corrective action,
by Section 208 of the HSWA. Since past contamination of sites is
not directly related to current use of the site (including the
quantities of waste generated), the costs of such financial
assurance may be high relative to the quantities of waste
generated currently.
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In general, then, the Agency is proposing to retain the full
Part 264 and 265 requirements for on-site waste management.
However, the Agency is proposing to extend the effective dates
for these requirements to six months beyond the date of
imposition of the body of the SQG requirements as part of Option
F 2. This extended effective date will provide SQGs wishing to
manage wastes on-site more time to review the regulations,
to finance required improvements to equipment and sites, to
obtain technical support where needed, or to identify
alternatives to on-site management. The Agency is inviting
comments on alternatives to this proposal.
In addition, the requirements placed on commercial TSDFs for
handling manifests from SQGs will be modified from the existing
requirements for handling manifests from LQGs, to reflect the
proposal that SQGs need only use a single copy manifest. The
proposed regulations would exempt facilities that receive wastes
from SQGs from the requirements:
1. to sign copies of the manifest upon receipt from
the transporter;
2. to. return a signed copy of the manifest to the
SQG; and
3. to retain a copy of the signed manifest for a
minimum of three years.
TSDFs will not be required to retain a copy of the manifest
because it is anticipated that SQGs may meet the proposed
manifest requirements by affixing the manifest to the container.
Receiving facilities will be required, however, to keep a
reasonable record of the hazardous waste shipments received from
SQGs for a period of at least three years.
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FACTORS AFFECTING SQG RESPONSES CHAPTER 5
INTRODUCTION
This chapter discusses a number of issues relating to SQGs'
likely responses to the proposed regulations. We assume, other
things being equal, that SQGs will select the lowest cost method
for complying with the proposed regulations. To identify the
options available to SQGs for complying with the regulations, and
to assess the costs of those options, lEc evaluated in detail a
number of issues that may affect SQGs1 compliance costs. In
addition, a number of non-cost considerations that may influence
SQGs1 decisions are considered. The discussion in this chapter
provides information on conditions that could result in signifi-
cant cost increases for some SQGs, and provides background for
the more aggregated analysis of costs in Chapter 6.
The information presented in this chapter is based on a
variety of sources. lEc contacted a number of states, commercial
facilities, commercial transporters, and trade associations to
obtain their views on a variety of issues. (A partial list of
these contacts is provided in Appendix A.) In addition, lEc has
reviewed the available literature on the costs and availability
of various practices, and on the legal liabilities associated
with hazardous waste management.
The following topics are discussed in this chapter:
o Availability and cost of services at commercial
TSDFs;
o Availability and cost of commercial transportation
services;
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o Regulation of SQG discharges to POTWs under the
Clean Water Act;
o Legal liabilities affecting SQGs;
o SQGs1 knowledge of waste characteristics and
available technical expertise;
o Extent of current compliance with proposed
requirements (or the equivalent);
o Effect of potential future regulations on SQG
requirements;
o Effect of tradeoffs between transportation and
storage costs on SQGs1 responses; and
o Potential incentives for illegal disposal.
AVAILABILITY AND COST OF COMMERCIAL
TREATMENT AND DISPOSAL SERVICES
SQGs are more likely than generators of larger quantities to
rely on commercial waste management services because most types
of on-site management are not likely to be economic for the small
quantities of waste involved. Therefore, whether commercial
services are available to SQGs, and at what cost, will have an
important effect on the burdens imposed by the proposed
regulation. This section presents the available information on
commercial prices and discusses cases in which prices for SQG
wastes might differ from those charged for LQG wastes. We then
consider whether commercial capacity will be adequate to handle
larger quantities from SQGs.
Commercial Treatment and Disposal Prices
Information on prices charged by commercial TSDFs is
generally limited. Prices per ton of waste vary dramatically
depending on the type of waste involved (and hence the type of
treatment required.) In a survey of nine commercial firms
conducted for EPA by Booz-Allen (Reference 11), the following
price ranges were reported for different types of treatment and
disposal in 1983:
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o Landfill
drummed wastes
(equivalent to $.45 - 1.09/gallon
at 55 gallons/drum)
bulk wastes
(equivalent to $.10 - .36/gallon
at 8 Ibs/gallon)
solidification
(equivalent to $.04 - .20/gallon
at 8 Ibs/gallon)
o Land Treatment
o Incineration
clean, high Btu liquids
other liquids
solids, toxic liquids
o Chemical Treatment
acids and alkalies
cyanides, heavy metals,
toxic wastes
o Resource Recovery
o Deep Well Injection
oily waste waters
toxic rinse waters
$25 - 60/drum
$25 - 90/ton
$10 - 50/ton
$.02 - .09/gallon
$(.05) -.25/gallon *
$.35 - 1.00/gallon
$1.50 - 3.10/gallon
$.06 - .55/gallon
$.50 - 3.20/gallon +
$.14 - 1.30/gallon
$.05 - .15/gallon
$.50 - 1.10/gallon
Note: * Some cement kilns and light aggregate
manufacturers pay for such wastes.
+ As high as $6.00/gallon if reactives are
included.
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These reported price ranges were used in the cost analysis
to develop prices for managing SQG wastes at commercial TSDFs.
As these data show, wastes with high Btu value can be incinerated
at relatively low cost and SQGs may even be paid for such wastes.
For example, spent solvents that are not heavily contaminated
with paints or other materials (especially non-chlorinated
solvents) can be incinerated at low cost or can be sold to be
burned for energy recovery, resulting in relatively low overall
costs to the generator. Such solvents may also be recycled,
requiring disposal of solvent recovery still bottoms, but
providing a credit for the value of recovered solvents and
avoiding the costs of other types of disposal. Other wastes,
such as heavily contaminated sludges or solids, may be costly to
dispose of. The least-cost method for commercial disposal for
such wastes is likely to be landfilling. The cheaper technologies
are limited to certain types of wastes: land treatment for
biodegradable organic wastes and deep well injection for highly
dilute wastes. Acids and alkalies are relatively easy to treat
and these services are widely available. PCB, reactive, metal-
bearing and highly-toxic wastes are generally more expensive to
treat. Liquid wastes are more expensive to landfill because of
the need for solidification.
The prices quoted above suggest that the costs of sending
wastes to approved commercial facilities may range from moderate
to substantial, depending on type of waste. For example, a SQG
generating 500 kg/month of toxic liquid wastes in drums (30 drums
per year) might pay $660 - 2,200 a year for landfilling
(including solidification), $2,500 - 5,100 a year for
incineration, or $825 - 5,300 a year (or more) for chemical
treatment not including the cost of transportation to
commercial facilities.
As the Booz-Allen price estimates show, costs for
landfilling are higher for wastes contained in drums. According
to some commercial facilities contacted by lEc, costs may also be
higher for drummed wastes than for bulk wastes for other types of
treatment. For example, drummed wastes cannot be incinerated
except in certain incinerators, unless wastes are removed from
the drums. Wastes must also be removed from drums for other
types of treatment, and drums must then be disposed of (or sent
to a drum reconditioner) by the commercial facility. In addition,
wastes in drums may require more extensive waste analysis when
received at commercial facilities, since a larger number of
samples must be taken for a given quantity of waste. (Commercial
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facilities often minimize this cost by combining samples from all
drums in a given shipment, and testing each drum separately only
if the original waste analysis indicates some problem.) Since
SQG wastes are likely to be shipped in drums given the small
quantities shipped by any single generator, costs per ton for
commercial services may be higher on average for SQGs than for
LQGs.
Commercial facilities often impose a fixed charge per
shipment received. This charge reflects the fixed acceptance
costs involved in handling of manifests and waste analysis. This
charge may not place unusual burdens on SQGs to the extent that
SQG shipments are consolidated in transportation, and hence
arrive in full truckloads. Since the economics of transportation
encourage consolidation of shipments, this is likely to be the
case. However, if SQGs were to transport their own wastes to
commercial TSDFs, the fixed charges imposed by commercial
facilities could impose higher costs per ton of wastes for SQGs
than for LQGs.
Commercial facilities may also impose one-time requirements
before generators begin sending their wastes that may represent a
burden for SQGs. Many of the commercial facilities contacted by
lEc require generators to complete some form of waste
description, often involving lab analyses of the wastes.
Facilities may assign a number to the waste, which must then be
provided with every shipment, and may test some or all shipments
to verify that the waste descriptions submitted by the generators
are accurate. These procedures are designed to ensure that the
commercial facility has accurate information on the wastes being
accepted, and to reduce facilities' potential liabilities
resulting from mismanagement of wastes. If these conditions are
imposed for SQG shipments, these generators may have to pay for
lab analyses of wastes beyond those required by the proposed RCRA
regulations. (In some cases, SQGs will be able to obtain the
required information from suppliers and may not have to actually
test wastes.) Further, if the fixed costs to the commercial
facility of reviewing and keeping records on wastes from each
generator are high, some commercial facilities may be reluctant
to accept SQG wastes.
In summary, commercial treatment and disposal prices for
managing SQG wastes will vary significantly, depending on the
types of wastes involved. SQGs may incur higher costs per ton of
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waste on average than LQGs with similar wastes, because their
wastes are more often drummed and because there may be fixed
charges per shipment.
Commercial Capacity for
Handling SOG Wastes
Only a few of the commercial facilities contacted by lEc
indicated that they routinely handle wastes from SQGs currently
(although they may receive consolidated shipments from
independent transporters that include SQG wastes). A number who
do not currently handle SQG wastes indicated that they are
considering expanding services to accept drummed wastes from
SQGs, however. Most facilities contacted also indicated that
they were operating below capacity and could handle additional
waste quantities from SQGs. The trade literature on the
commercial industry confirms that most types of facilities were
operating below capacity in recent years. (The exceptions have
been hazardous waste incinerators, especially those approved to
handle PCB wastes.) Capacity utilization has reportedly
increased recently, however, as improved economic conditions have
resulted in larger volumes of waste being generated. (See
References 11 and 32.)
Potential SQG demand for commercial services represents only
a small portion of total demand for such services. For example,
EPA estimates that approximately three percent of all hazardous
wastes generated by LQGs or approximately 9.7 million MT in
1981 is managed off-site (Reference 59). The total quantity
generated by SQGs annually (as estimated by the SQG survey)
represents only three percent of that off-site amount.
Therefore, there does not appear to be any general capacity
constraint that would prevent acceptance of SQG wastes at
commercial facilities.
SQGs may not be able to compete with LQGs for commercial
services, however, in cases where capacity is (or becomes)
limited. Capacity may become limited for some types of
commercial services, especially as EPA promulgates restrictions
on land disposal for specific wastes. To the extent that
providing services to SQGs is less profitable than LQG services,
commercial facilities may become more reluctant to accept SQG
wastes. Commercial facilities often have to adjust their
practices to accept SQG wastes. For example, they may have to
provide greater assistance to SQGs in characterizing their
5-6
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wastes, or (as noted above) may have to perform more extensive
waste analyses for SQG shipments. These requirements make
handling SQG wastes less profitable, other things being equal,
unless the added costs can be recovered from SQGs.
The available information on current and future capacity at
commercial facilities, and on the costs of managing SQG wastes,
is not adequate to determine whether SQGs will be able to obtain
commercial services at prices similar to those charged for LQGs.
(The Agency is currently planning to conduct a survey of the
commercial industry that will provide information on current
capacities and plans for expansion by type of waste management
technology, as well as on pricing practices. The survey results
will support more accurate analysis in the future of the affects
of commercial practices on costs for SQGs and others.) Based on
the limited information obtained by lEc from commercial
facilities, it appears that capacity for managing SQG wastes at
commercial facilities is likely to be available in the aggregate.
However, there may be regional capacity shortfalls for some
management practices.
Most of the commercial firms contacted by lEc indicated that
they would be reluctant to accept, wastes from other than a
licensed transporter, because mismanagement by the transporter
could increase the liability of the commercial facility. A
number indicated that they would not necessarily require that
generators report an EPA identification number, since in most
cases these facilities already have information on the
generator's identification because they pick up wastes from
generators themselves or because they assign each generator a
number and require that the number be attached to all shipments.
(One firm uses the generator ID number in a computerized
recordkeeping system and would require use of an EPA ID number by
any generator even if EPA had proposed to waive the requirement
for SQGs.)
AVAILABILITY AND COSTS OF
COMMERCIAL TRANSPORTATION SERVICES
Many SQGs are likely to depend on commercial transporters
for shipments of wastes off-site, rather than transporting wastes
themselves. This section discusses the potential availability of
commercial transportation services to SQGs and the likely costs
of such services.
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Description of Transportation Services
Hazardous waste transportation services are often provided
by commercial TSDFs, as well as being offered by a large number
of independent transporters. Where sufficiently large quantities
of waste are available from a single generator or where
generators are willing to pay all costs associated with
collection and transportation, transporters will make a dedicated
trip to collect wastes from the generator. Those wastes may be
shipped directly to the final destination (most often when the
quantities shipped are very large or the destination facility is
nearby), or may be shipped to a transfer facility where shipments
are consolidated for shipment to a destination facility (often in
larger trucks). Smaller shipments are generally collected in
multiple-stop trips (often referred to as "milk runs"), where the
transporter attempts to fill a truck with wastes from generators
located in close proximity. Some transporters contacted by lEc
who report serving SQGs say that they attempt to establish
regular collection schedules for different geographic areas.
Others contact generators to arrange for services when they plan
to collect in a specific area. Some even keep track of the
length of time since the last pick-up, and notify generators when
their 90 day on-site accumulation period is expiring. Again,
multiple-generator collections may be transported directly to a
destination facility or may be taken to a transfer station for
further consolidation.
Costs of Transportation Services
The economics of transportation favor full truckloads and
the use of larger trucks for trips of longer distances. In
addition, there are fixed costs associated with each collection
point, due to time spent driving to the collection point, loading
and unloading wastes, and completing required paperwork. As is
the case with commercial TSDFs, the existing information on
availability of commercial transportation services, and the
prices charged for those services, is limited. The Booz-Allen
survey cited earlier provides a rough estimate for transportation
charges of between $.09 and $.18 per metric ton-mile. (This would
imply a charge of $1.80 - 3.60 per drum or $.03 - .06 per gallon
for a 100 mile trip.) This estimate is most likely applicable to
full loads for standard truck sizes. An earlier Booz-Allen
report on the commercial waste management industry (Reference 12)
reported that pricing methods differ, but often include flat
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charges per truck hour (so that costs vary with both trip
distance and time spent at individual collection points), flat
charges per mile, or combinations of minimum charges per pick-up
plus a charge per mile. The pricing rules cited in the Booz-
Allen report applied to full truckload pick-ups for standard-
sized trucks (6,000 gallon-capacity for tank trucks and 80 drum-
capacity stake trucks.);
lEc's analysis of tabulations from the 1981 RIA Mail Survey
indicate that transportation costs can represent a substantial
portion of the total costs associated with off-site management.
The survey results represent the experiences of LQGs and may
understate the costs that would be experienced by SQGs. The
average cost reported in the survey for transportation to a
commercial facility was $.50/gallon. Average reported prices
varied by region, from $.42/gallon in Region 8 to $.85/gallon in
Region 10. Transportation costs represented an average of 39
percent of the total cost of off-site waste management, ranging
from 30 percent in Region 2 to 57 percent in Region 10.
Information developed for EPA by Abkowitz, et al. (Reference
1) on the basic costs of operating a truck was used by lEc to
estimate likely prices for commercial transportation of SQG
shipments under different conditions. (This source also provided
the basis for the costs used to predict regulatory costs, as
described in Chapter 6.) The methodology for this analysis is
described in Appendix D. While this analysis may not provide
precise estimates of actual costs (since the assumed truck sizes
may not reflect actual practices for SQG shipments, and since it
was necessary to make a number of simplifying assumptions in the
analysis), the results illustrate the factors that affect costs
for SQG shipments.
Exhibits 5-1 and 5-2 present total estimated annual
transportation costs for SQGs as a function of (1) shipment
frequency (and shipment size), (2) distance to the destination
facility, (3) distance between SQG collections,and (4) percent of
the truck filled by the collections on a single collection trip.
Exhibit 5-1 shows.results for the the upper end of the SQG size
range (generating 1,000 kg/month) and Exhibit 5-2 reports results
for the lower end of the size range (generating 100 kg/month).
The calculations estimate costs based on the assumption that the
transporter collects wastes until his truck is either full or
half-full, depending on the scenario being considered.
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Exhibit 5-1 shows that costs are quite sensitive to the
distance to the destination facility, as might be expected. In
addition, the results show that costs can increase significantly
if transporters are not able to make up full truckloads where the
destination facility is far away. Transportation of partial
truckloads is not so costly when the destination facility is
nearby (e.g. 25 miles). Under the assumptions of this analysis,
total costs for an individual SQG are not very sensitive to the
size of shipment (and hence the number of shipments per year)
where long hauls are required to reach the destination facility,
since the cost of the long-haul transportation dominates total
costs. At shorter distances, the shipment frequencies have a
greater proportional effect on costs, although the total costs
are still substantially less for the shorter distances. Finally,
the distance to the SQG does not have a significant effect on
costs for SQGs of this size, as long as the transporter is able
to pick up enough waste to fill all or half of his truck. The
effect of urban vs. rural location is understated in these
calculations, however, if it is significantly more difficult to
make up full or half truckloads in rural areas than in urban
areas.
Exhibit 5-2 shows the same calculations for a small SQG.
These results are very similar to those described above. Given
the much smaller quantities to be shipped, total transportation
costs over the course of a year are substantially lower than
those faced by larger SQGs (although the costs per ton of waste
are substantially higher, with the difference proportionally
greater for shorter distances to destination facilities). Again,
distance to SQGs does not have a dramatic effect on costs, as
long as the transporter is able to complete a full or half
truckload for transportation to the destination TSDF. However,
small rural facilities may find it difficult to attract
transporters unless they are located near enough to other
customers to allow completion of adequate loads.
Exhibit 5-3 illustrates the effect of distance between
generators (or the round trip distance between the transporter
and the SQG if only 1 pickup is made) on total transportation
costs. The exhibit shows the costs for a generator who generates
500 kg/month and compares two scenarios of transportation
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distances to the SQG: 7 miles and 75 miles.I/ As the exhibit
reveals, transportation costs are sensitive to the distances
traveled to make collections. In general, the distance to the
TSDP is more likely to have a significant effect on costs since
distances to the TSDFs are typically longer than the distance
travelled to the collection point, and larger and more expensive
trucks are likely to be used for shipments to TSDFs than for milk
runs. However, since a shipment to a TSDF may contain wastes
from more than one generator, each generator accounts for only a
portion of these "long-haul" costs. The costs associated with
traveling to a SQG (either from another collection point or from
the transporter's site) on a milk run are attributed entirely to
that SQG. Exhibit 5-3 clearly shows that SQGs who are not
located in proximity to other generators may incur significantly
higher transportation costs than generators who are located near
other generators.
The costs per ton of waste shipped are significant for long-
haul trips, ranging between $350 and $415 per ton ($70 - 83/drum)
for larger SQGs and between $410 and $1,409 per ton ($82 -
282/drum) for smaller SQGs for a 1,000 mile trip. At long
shipment distances, transportation costs might be high enough to
present incentives for on-site management.
While transporters' pricing rules may not reflect
contribution to costs exactly, it is likely that SQGs will be
charged higher rates for transportation (1) the farther their
wastes must be transported to their final destination and (2) the
farther the SQG is from other collection points. It appears that
these two factors outweigh variations in costs attributable to
size of SQG shipment per so. (unless a single SQG's wastes
determined truck utilization because there were no other
shippers nearby).
I/ The specified distances between generators include a portion
of the distance traveled between the transporter's location and
the first stop on the route. For instance, a transporter may
travel 12 miles to get to this first stop (if he is located
outside of the city), then travel 2 miles to his next stop, and
then travel 12 miles to return to his site. The roundtrip
distance is 26 miles and the distance attributable to each
generator is 13 miles. We use the term "distance between
generators" for convenience; in the scenario just described, this
distance is 13 miles.
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The transporters contacted by lEc indicated that they often
provide extra services to SQG shippers, which may result in
additional charges. These include help in completing manifests
and in interpreting DOT packaging, marking, labeling and
placarding requirements. Transporters often provide SQGs with
copies of the Uniform National Manifest and with appropriate
labels and placards.
Several transporters also reported that their services for
SQGs are not currently profitable, because they are not able to
charge rates for SQG pick-ups that provide adequate returns.
Several transporters said that, when they have quoted prices to
generators over the phone, generators frequently complain about
the quoted rates, do not contract for services, and/or simply
hang up. Transporters' inability to earn adequate returns may
reflect the fact that SQGs are not currently regulated or that
the existing regulations on SQGs are not being enforced in many
cases, with the result that only a small portion of potential SQG
customers in fact request services. As the previous discussion
shows, transporters' costs for picking up wastes from a single
generator are sensitive to the transporter's ability to collect a
full truck load in a single area. Thus, costs may decline and
services to SQGs may become more profitable if a larger portion
of SQGs are required to transport wastes off-site as a result of
the proposed regulation.
Two cases in which transporters collect dry cleaning wastes
on a regular schedule apparently have resulted in moderate
transportation charges. These are programs run by the
Neighborhood Cleaners Association and the North East Fabricare
Association. In both cases, wastes are collected on a pre-
specified schedule, and routes are organized to economize on
transportation costs. (The Neighborhood Cleaners Association
imposes additional charges for collections outside of a 50 mile
radius of the recycling facility.) The success of these programs
may reflect the value of some of the solvent wastes collected
from dry cleaners, as well as the economies achieved in
transportation, however. (Neither association was able to provide
a. separate estimate of the charges associated only with
transportation.)
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Transportation Costs Used in
Aggregate Cost Analysis
The analysis of costs described in Chapter 6 used
transportation costs developed by Pope-Reid Associates (PRA).
With one exception, the assumptions used in developing those
costs were likely to result in "worst-case" costs per SQG. The
costs developed by PRA are substantially higher than those
developed by lEc for milk run transportation scenarios, even when
the lEc model uses many of the same assumptions as used by PRA
(see Exhibit 5-4). The major differences between the two
estimates include the following:
1. The PRA estimates assume that each shipment
collected on a milk run is the same size, whereas
the lEc model does not depend on the shipment
sizes or the number of collections made from other
SQGs to calculate the transportation costs for a
particular SQG.
2. The PRA transportation cost estimates assume that
all milk runs are completed within an eight hour
day.
3. The PRA estimates assume that an 18 MT capacity
stake truck makes all the collections and delivers
the waste to the TSDF, whereas the lEc model
assumes that a smaller truck makes the collections
and that a stake truck delivers the wastes to a
TSDF.
4. The PRA estimates assume that the wastes collected
in a milk run in one eight hour day are then
delivered to the TSDF without adding any more
waste shipments to the load. This assumption
results in utilization rates for some shipment
sizes of as low as 35 percent of total truck
capacity.
Based on lEc's conversations with commercial transporters
currently handling SQG shipments of hazardous waste, it appears
that some of PRA's assumptions may overstate actual costs. In
particular, our conversations indicate that:
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1. Trucks with a capacity of about 30 drums are used
on milk runs, and wastes are consolidated on large
trucks for shipments to a TSDF.
2. Wastes are held at the transporter's site prior to
shipment to TSDFs to achieve more economic
shipment sizes, and trucks are operated as close
to full truckload as possible). Therefore, a
shipment to a TSDF may contain wastes from more
than one milk run.
3. The shipments collected on a milk run are not
necessarily uniform in size, although shipment
sizes may be close to uniform when regular
collections are made from the same industry (e.g.,
collections of dry cleaning wastes made every 90
days).
The Pope-Reid transportation cost estimates were based on
the assumption that SQGs ship 100 miles to the destination TSDF.
Because transportation costs are so sensitive to shipment
distances, lEc reviewed available information on typical shipment
distances. The results of this review (reported later in this
chapter) indicate that SQGs may often have to ship further than
100 miles. Therefore, while many of the assumptions underlying
the cost analysis tend to overstate costs, some SQGs are likely
to incur transportation costs higher than those assumed in the
cost analysis because they must ship longer distances to TSDFs.
Effect of Location on Transportation Costs
lEc has developed two "average" transportation scenarios to
reflect likely conditions for two types of SQGs: a SQG located
in an urban area and a SQG located in a rural area. Based on the
shipment distance analysis discussed in the following section and
our conversations with transporters, we assumed that an average
distance to a TSDF from a commercial transporter is 200 miles.
(Transporters contacted by lEc reported average shipment
distances of 50 - 700 miles.) Based on our conversations with
transporters we also assumed that an average distance between
SQGs in an urban area is 7 miles, that the average distance
between SQGs in a rural area is 75 miles, and that the average
capacity utilization rate is 85 percent. The transportation
costs developed using these average scenarios are shown in
Exhibit 5-5. Clearly, SQGs located in rural areas will incur
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significantly higher costs than those in urban areas. Since the
SQG Survey indicated that most SQGs are located in urban areas,
the transportation costs for the urban scenarios are most likely
to reflect the transportation costs incurred by most SQGs. The
average costs under the rural scenarios more closely approximate
the average costs developed by PRA for the compliance cost
analysis. Thus, the PRA cost estimates are likely to overstate
costs for the majority of SQGs, located in urban areas, but may
reflect costs incurred by SQGs in rural areas fairly closely.
Typical Transportation Distances
As discussed above, shipment distances to a TSDF can have
significant effects on the generator's transportation costs.
Unfortunately, no comprehensive estimates of average shipment
distances to commercial TSDPs are available, by either waste type
or type of waste management method. Past efforts to analyze
shipment distances have not isolated average shipment distances
to commercial TSDFs, but have included "intra-firm" shipments of
hazardous waste in the averages as well. Therefore, XEc
attempted to develop more accurate estimates of the shipment
distances to commercial TSDFs.
lEc performed an analysis of shipment distances based on
data from the RIA Mail Survey Generator Questionnaire (Q 117) and
the Part A permit application from HWDMS. In question #17,
generators reported the EPA identification number of the TSDFs to
which their hazardous waste was taken for management, the
quantity of waste delivered and the number of shipments to each
reported TSDF made in 1981. Of the TSDFs reported in Question
17, lEc selected (where possible) at least one commercial
facility in each of the EPA Regions offering specific waste
management practices, to provide data for different regions and
types of facilities. (We were not always able to select each
facility type in each region.) The waste management practices of
interest included landfilling, incineration, deep well injection,
solvent recycling and neutralization. We identified commercial
facilities and determined the availability of these practices at
particular facilities using the Commercial Hazardous Waste
Facilities Data Base (Reference 30) . Fifty-six facilities were
selected. More than 900 generators reported shipping hazardous
waste to these facilities in 1981. Each generator and TSDF was
geographically located by latitude and longitude measurements
provided in the Part A permits data base. The distance between
each generator and TSDF was then calculated. Average shipment
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distances to each TSDF were calculated, as were weighted average
shipment distances (based on the number of shipments reported by
the surveyed generators). This procedure does not provide
statistically-valid estimates of average shipment distances, but
does provide some insight into how distances may vary by location
and type of management.
The results of this analysis are shown in Exhibits 5-6 and
5-7. The overall average shipment distance was 154 miles (and
the average weighted by number of shipments was 122 miles). The
analysis therefore indicates that shipment distance may exceed
the 100 miles assumed in the cost analysis significantly,
especially for some TSDF locations and types of facilities. The
averages weighted by number of shipments were consistently less
than the simple averages for all TSDFs, as would be expected,
since generators are likely to ship more frequently when shipment
distances are closer and since TSDFs are likely to be located
close to large numbers of generators. Reported distances may
reflect shipments made to a facility which remanifested the waste
and then shipped to another facility for ultimate management.
The generator may be unaware that the waste traveled to a second
facility and would report an interim storage facility as the
destination facility. Therefore the distance which the waste
actually traveled may be understated in this analysis.
Average shipment distances appear to vary by type of
facility. Landfill facilities accounted for the longest average
shipment distance: 234 miles (or 180 miles weighted by number of
shipments). Facilities offering incineration reported an average
shipment distance of 174 miles (119 miles as a weighted average).
Note, however, that nearly all of the facilities analyzed offered
more than one type of waste management practice. Therefore,
average shipment distance for landfilling (for example) may
reflect shipments of wastes which are not actually landfilled,
although the distance this shipment traveled is reflected in the
"average" shipment distance reported for landfill facilities.
The weighted and unweighted average shipment distances by
region are shown in Exhibit 5-7. This exhibit shows the average
calculated shipment distance for facilities located in the
indicated region. These distances do not indicate, therefore,
the average shipment distance which a generator located in each
of these regions is likely to experience. The results suggest
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that facilities in Region 1 receive wastes from an average
distance of 50 miles, and that facilities in Region 9 receive
wastes from an average of 249 miles.
These shipment distances were calculated from information
provided by large quantity generators in 1981. Small quantity
generators may ship different waste types and may be on average
located closer or further away from commercial TSDFs. To date/
no comparative analysis has been performed to indicate whether
LQGs and SQGs are located in different geographic areas and would
thereby have different shipment distances to TSDPs. Although the
shipment distances occurring in 1981 may not reflect the
conditions in place when SQGs are regulated, it is unlikely that
these shipment distances have shortened in the interim period,
since few new TSDFs have been opened, and it is more likely that
TSDFs have closed since 1981 or will close by the time SQG
regulations are effective (due, for example, to the need to come
into full compliance with RCRA Part 264 requirements).
Therefore, these distance estimates may represent the low end of
average shipment distance for SQGs.
Availability of Transportation Services
Aside from possible problems with the profitability of
transporting SQG wastes, there do not appear to be any serious
constraints on the availability of commercial transportation
services. A directory of commercial hazardous waste firms
(Reference 16) lists 293 transporters who handle containers. Of
these, 260 advertise that they will collect less-than-full
truckload shipments. There may be local shortages of hazardous
waste transportation services in some regions or for some types
of wastes. However, there do not appear to be any significant
barriers to entry in hazardous waste transportation in most
states (unlike the significant difficulties in siting that may
constrain future growth in commercial treatment and disposal
capacity). Therefore, if transportation of SQG wastes can be
performed at an adequate profit, it is likely that commercial
transportation services will be available for SQGs. In a few
cases, trade associations for SQG industries contacted by lEc
stated that members have had difficulty in obtaining
transportation services. These problems were most often
mentioned in connection with SQGs located in rural areas,
however, suggesting again the potential importance of location in
determining the cost and availability of transportation services.
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REGULATION OF SQG DISCHARGES TO
POTWs UNDER THE CLEAN WATER ACT
The SQG survey revealed that a substantial percentage of
wastes from some SQG industries are currently disposed to sewers.
As described in Chapter 4, these discharges are exempt from
regulation under RCRA. It is possible that the costs imposed by
the proposed regulation will encourage increased disposal to
sewers. This section discusses the extent to which such
discharges would be regulated under current provisions of the
Clean Water Act that would require SQGs to pretreat wastes before
discharging to sewers.
SQGs are subject to the requirements of the Clean Water Act
if they are either direct or indirect dischargers. Direct
dischargers in certain industry categories must comply with BPT,
BAT, and New Source Performance Standards. Indirect dischargers
must meet new or existing pretreatment standards if effluent from
the establishment is expected to interfere with or alter POTW
operation and discharge. These pretreatment guidelines are of
particular importance to SQGs because of the widespread practice
of waste disposal to POTWs via the sewer system.
Exhibit 5-8 indicates the survey industry groups subject to
pretreatment standards. As shown, the majority of SQG industries
are not subject to pretreatment standards. Only 11 percent of
the SQG establishments (or about 12,000 generators) are
potentially covered by pretreatment regulations. Regulated
industries include those in metal manufacturing, chemical
manufacturing, other manufacturing (tanning leather and
miscellaneous plastics products) and pulp and paper
manufacturing.
SQG industries may be excluded from some or all of effluent
guideline regulations for two reasons. First, if the Agency
decided that the industry was not a significant polluter, then
the industry was never included in a listing of 21 industrial
categories to be regulated. Second, these industries may not be
subject to BAT, NSPS, PSES, or PSNS (but are subject to BPT)
regulations under the terms of a Settlement Agreement with the
Natural Resources Defense Council (NRDC). This NRDC Settlement
Agreement followed years of litigation over EPA's development of
(or failure to develop) a program to regulate toxic pollutants.
This Settlement Agreement included a schedule for EPA to propose
and promulgate effluent regulations for the 21 major industrial
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categories for 129 specific priority pollutants. The agreement
also provided for a Paragraph 8 Exclusion, which may affect many
SQG industries. This Paragraph 8 exclusion allows EPA to exclude
a point source category, subcategory, or specific toxic pollutant
from BAT, NSPS, PSES, or PSNS regulation. A Paragraph 8
exclusion may be justified where:
o The Agency's guidelines already provide sufficient
protection;
o A specific pollutant is present in the effluent
solely as a result of its presence in intake
waters;
o A pollutant is not analytically detectable;
o A pollutant is detectable from only a small number
of sources within a subcategory and the pollutant
is uniquely related to those sources;
o A pollutant is present only in trace amounts and
is not causing toxic effects or it is present in
amounts too small to be effectively reduced by
known technologies;
o The amount and toxicity of each pollutant in the
discharge does not justify developing national
regulations and in accordance with the Settlement
Agreement schedule; and
o For pretreatment standards, 95 percent of the
dischargers in the industrial category/subcategory
do not discharge pollutants to a POTW, or the
pollutants discharged are insignificant in terms
of quantity and toxicity.
Within the industries that are subject to pretreatment
standards, some generators may be exempt from requirements
because they generate and discharge relatively small quantities
of wastewater. According to EPA's Industrial Technology
Division, three effluent guideline standards affecting SQG
industries have limitations in pretreatment requirements based on
size. The following size standards affect applicability of
pretreatment limitations:
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o Electroplating Pretreatment Standards for Existing
Sources (PSES): Different standards (limitations
and pollutants) apply to those facilities
discharging less than 38,000 liters (10,000 gallons)
per day.
o Porcelin Enameling PSES; Plants discharging less
than 60,000 liters (16,000 gallons) per day or
coating less than 1,600 square miles per day are
excluded.
o Leather Tanning £S££: The chromium limitation is
excluded for facilities in three of nine
subcategories treating less than the following
number of pieces, per day:
Subcategory A 275 hides
Subcategory C 350 hides
Subcategory I 3,600 splits
Other pollutant limitations remain in effect,
however.
Thus, it appears that pretreatment standards for SQG
industries are the exception rather than the rule, and the major
constraints on increased disposal to POTWs will be the physical
form of the waste in question, SQGs1 proximity to sewers, and
limits other than pretreatment standards that may prevent
disposal to sewers.
LEGAL LIABILITIES
Generators of hazardous wastes, as well as other parties
transporting, treating or disposing of such wastes, are subject
to significant liabilities for damages caused by the release of
wastes. The most significant liabilities are imposed by
provisions of CERCLA (the "Superfund" Act) and RCRA. These two
statutes impose strict liability for the cost of cleaning up
contaminated sites on any generator whose wastes are found at the
site.
Under CERCLA Section 107, EPA can clean-up contaminated
sites and then sue to recover the costs of the clean-up from
"responsible parties" owners/operators of the site,
transporters who brought wastes to the site, and generators or
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others who "arranged for" disposal of wastes at the site. Under
CERCLA Section 106, EPA can order private parties to undertake
clean-up or other actions to mitigate damages, where releases
present an "imminent hazard" to health or the environment. . EPA
may also negotiate with private parties to secure "voluntary"
clean-up of contaminated sites, under the threat of suit under
CERCLA.
EPA has argued that Section 107 of CERCLA imposes "joint,
strict and several liability" on generators of hazardous wastes
whose wastes are found at contaminated sites. Under this theory
of liability, the government need not show negligence on the part
of the generator, but merely that the generator had sent wastes
to the site in question ("strict liability"). Further, the
government need not demonstrate that the wastes sent by any
particular generator actually caused the contamination of
concern, nor must the government determine what portion of the
total harm is attributable to any particular generator ("joint
and several") liability. The government may sue any one of the
responsible generators for the entire amount of the clean-up.
CERCLA defendants have challenged EPA's interpretation of
liability under CERCLA. Courts have ruled on some but not all of
the issues relevant to generator liability, and generators' legal
status is therefore not clear. In general, the courts have
upheld EPA's interpretation of the provisions of CERCLA, although
some limitations are suggested in previous decisions. For
example, courts have ruled that "joint and several" liability
applies only where the harm caused by release of wastes is
"indivisible" that is, where the contribution of one party's
wastes cannot be clearly distinguished. However, in most cases,
the courts have found that harm is indivisible. The burden is on
the generator to show that his wastes were isolated from others
in the facility or otherwise did not contribute to the
contamination of the site. Except in unusual circumstances, the
nature of operations at most commercial sites would make it
difficult to argue that harm is divisible.
Potentially, then, the CERCLA provisions impose liability on
any generator who has sent wastes to a contaminated site for the
entire cost of cleaning-up the site. Since these costs can
amount to millions of dollars, the financial implications for
generators are potentially significant. The government's
decisions about who to sue in any particular case, and the
courts' decisions about how to apportion damages, may in effect
limit the liability of any one generator. However, even the
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costs of a small portion of a site clean-up would present a
substantial burden for a SQG, as would the cost of any litigation
involved in the case.
The government also has the authority under Section 7003 of
RCRA to require clean-up of sites where releases pose an imminent
hazard to human health and the environment. This liability
applies to both active and inactive sites. Further, full
compliance with the provisions of RCRA (including the fact that
the site was permitted under RCRA) does not provide immunity for
the generator. The courts have generally applied a standard of
strict liability under Section 7003 of RCRA, so that a generator
may be held liable even if the site owner is primarily at fault.
In addition/ a generator can be held liable for waste releases
caused by improper handling by a transporter. The only third
party defense available is a demonstration that the contamination
from a facility was caused solely by the act of another
generator or transporter. The court decisions to date have not
resolved whether joint and several liability will be applied in
Section 7003 actions.
The HSWA extend generators' liabilities in a number of
cases. In particular, the statute allows citizen suits under
Section 7003, except under some circumstances designed to avoid
interference with government prosecution of cases. Thus, private
parties will be able to sue generators where the government has
not taken action.
The CERCLA and RCRA liabilities described above currently
apply to SQGs, and SQGs1 legal responsibility for mismanagement
of their wastes will not change in theory as a result of the
proposed regulations. It is not clear whether SQGs will in fact
be the target of actions under CERCLA and RCRA. In practice,
SQGs currently are not as likely to be sued as other generators.
When the proposed regulations take effect, SQGs will have to
notify the government that they are generating wastes and will
have to manifest and label every shipment of wastes to off-site
facilities. In practice, then, the proposed regulations are
likely to make SQGs1 activities more "visible" and more
vulnerable to legal actions.
A number of trade associations contacted by lEc expressed
concern about their members' legal liabilities. Most of the
associations contacted believe that their SQG members are often
unaware of their potential legal liabilities. Some that are
aware mistakenly believe that use of the manifest system for
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wastes sent off-site provides a safeguard against liability. The
trade associations expressed considerable frustration that full
compliance with generator requirements does not shield a
generator from liability for mismanagement of wastes by others.
Many of those contacted believed that more of the liability for
off-site shipments should be borne by transporters. A few trade
associations indicated that they are encouraging their members to
recycle wastes off-site whenever possible, both to reduce
disposal costs and because they believe that (unlike the case
with off-site disposal) generators' liabilities are ended once
wastes are recycled.
Several trade associations indicated that their members view
the full manifest system as a help in monitoring and controlling
liability. The fact that the destination facility must sign and
return the manifest provides greater assurance that wastes have
reached their intended destinations (although there have been
cases in the past where transporters have forged signatures for
wastes not delivered as intended.) In addition, the manifest
provides the generator with a record of the exact quantities of
wastes shipped off-site, which is of potential importance if the
generator becomes involved in litigation invoking joint and
several liability. A full manifest system may therefore be more
valuable than a partial (one-way) system to generators as well as
to the government, since the full system provides a means of
monitoring waste shipments.
In general, the significant legal liability imposed on
generators of hazardous wastes may discourage SQGs from sending
wastes to sites that may eventually become contaminated. For
example, legal liabilities might encourage use of recycling,
discharge to sewers under the provisions of the Clean Water Act
(see below), or, if generators expect enforcement of the proposed
regulations to be limited, complete non-compliance with RCRA
(including notification, manifest and labelling requirements that
make SQG activities more visible.)
KNOWLEDGE OF WASTES
AND TECHNICAL EXPERTISE
Many of the trade associations contacted by lEc stressed
that their members will often have difficulty determining whether
their wastes are regulated under RCRA. Generators tend to be
familiar with trade or generic names for hazardous materials
(such as solvents) that eventually become wastes. They may have
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difficulty relating the information they have on wastes to the
lists of hazardous wastes issued under RCRA. Further, they may
not have the technical expertise needed to assess whether their
wastes exhibit one of the characteristics of hazardous wastes
(ignitability, corrosivity, reactivity, and EP toxicity.) Many
establishments have been using hazardous substances for years,
and find it difficult to believe that wastes from use of these
chemicals are hazardous and require special handling. SQGs may
be better able to characterize their wastes once new OSHA
requirements take effect. The "Chemical Hazard Identification"
rules require that shipments of hazardous chemical products be
accompanied by a "Material Safety Data Sheet" that provides
information on the properties and proper handling of the product.
In any event, the Agency expects identification of wastes subject
to RCRA requirements to present a substantial problem for some
types of SQGs, and is planning to devote a significant portion of
the education programs for SQGs to waste characterization.
Beyond the problems of waste characterization, SQGs are also
likely to lack other types of technical or legal expertise
required to comply with the proposed regulations. SQGs are
likely to be dependent on the proposed education program and on
the support of trade associations to interpret the complicated
regulatory requirements imposed by RCRA. As noted above, lEc's
conversations with transporters and with trade associations
suggest that transporters are an important source for
interpreting and applying the manifest and shipping requirements
of RCRA and DOT regulations.
In addition, few SQGs are likely to have the chemical or
engineering expertise on-site to comply with some of the proposed
requirements especially those that would be involved in
permitted on-site management.
CURRENT LEVEL OF COMPLIANCE
The incremental costs of complying with the proposed
regulations will be significantly less to the extent that SQGs1
practices already comply with the requirements.
Some SQGs may already be substantially in compliance with
the proposed regulations because they are located in states that
already regulate generators of less than 1,000 kg/month. A 1983
survey of states conducted for EPA by the Association of State
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and Territorial Solid Waste Management Officials (ASTSWMO)
(Reference 7), and additional information obtained by lEc,
indicate that:
o sixteen states currently regulate generators of
less than 1,000 kg/month more stringently than the
federal provisions;
o of these, three states regulate all generators of
hazardous wastes, with no exclusion level;
o another seven states impose limited requirements
(such as manifesting, recordkeeping, and/or
limitations on disposal methods) on generators of
less than 1,000 kg/month; and
o fifteen states plan to change their current SQG
definitions (in some cases to maintain equivalency
with the proposed changes in the federal exclusion
levels) .
The geographical distribution of SQG wastes by four census
regions was reported in the Abt survey.2/ Data in the Survey
Report indicate that three of the regions the Northeast, the
North Central, and the South generate nearly equal amounts of
waste (27 percent of total) with the states in the West
generating 17 percent of all SQG wastes. This proportion remains
nearly the same for the top ten waste streams. The distribution
of SQG wastes among the states was not available from the survey.
ICF, Inc. (Reference 26) developed the state distribution using
2/ The Northeast region is composed of Maine, New Hampshire,
Vermont, Massachusetts, Rhode Island, Connecticut, New York, New
Jersey and Pennsylvania. States in the North Central region
include Minnesota, Iowa, Missouri, North Dakota, South Dakota,
Nebraska, Kansas, Michigan, Ohio, Indiana, Illinois and
Wisconsin. The South region is composed of Arkansas, Louisiana,
Oklahoma, Texas, Kentucky, Alabama, Mississippi, Delaware,
Maryland, Virginia, West Virginia, North Carolina, South
Carolina, Georgia, Florida and the District of Columbia. The
West census region is composed of Washington, Oregon, California,
Alaska, Hawaii, Montana, Idaho, Wyoming, Nevada, Utah, Colorado,
Arizona, and New Mexico.
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data available in the Census County Business Patterns (CBP).
There were a few cases where this methodology resulted in
significant differences between the waste quantities allocated
for a region (computed by summing the state totals), and the
regional totals reported by the survey. For example, the ICF
methodology predicted an even distribution of mercury waste
across the four census regions. In contrast, the SQG survey
reported that all generators of mercury waste were located in one
region (North Central). In general, however, the methodology
predicted similar quantities generated per census region as
compared to the quantities reported in the survey.
Exhibit 5-9 presents the quantities of wastes generated by
the top ten states and the state SQG regulations currently in
effect. As shown, SQGs in the top ten states generate more than
134,000 MT of waste or 59 percent of the total 228,500 MT
calculated by the ICF methodology. 3_/ SQGs in California generate
the largest quantity of waste (24,500 MT or nearly 11 percent of
total), followed by SQGs in New York (20,300 MT/year or 9 percent
of total). These two states together account for 20 percent of
total SQG wastes.
Exhibit 5-10 presents the waste distribution among the top
five states for the top ten waste quantities. California
generates the largest quantities of seven of the top ten
waste streams: spent solvents, photographic wastes, wastes with
silver, ignitable wastes, ignitable paint wastes, pesticide
washing and rinsing, and spent plating wastes. New York
generates the largest proportion of acids and alkalies, and dry
cleaning filtration residues. Ohio generates the largest amount
of formaldehyde wastes.
More than two-thirds of the total quantity of SQG wastes are
generated in states that have more stringent regulations than
existing federal guidelines, such as lower exclusion levels,
and/or required manifesting, recordkeeping, and reporting.
Approximately one-half of all SQG wastes are generated in states
that require some form of manifesting. As shown in Exhibit 5-9,
only two of the top ten waste-generating states Florida and
I/ The total of 228,500 MT/year derived by ICF, is larger than
the total SQG quantity of 187,804 reported in the survey. The
following discussion is based on the state totals determined by
the ICF methodology.
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Ohio have SQG disposal requirements that are less stringent
than the federal regulations. California, the largest SQG waste-
generating state, has strict SQG regulations: a zero quantity
exemption, with required manifesting, labeling, recordkeeping,
biennial reporting, and contingency plans. New York, the second
largest SQG waste-generating state, has a 100 kg/month exclusion
limit, and requires some recordkeeping and reporting. Texas has
a proposed 100 kg/month exclusion level and has proposed
manifesting and recordkeeping requirements. New Jersey,
Illinois, and Pennsylvania currently require SQGs to manifest and
keep records. Michigan has a 100 kg/month exclusion and requires
SQGs to keep records and file annual reports. Massachusetts has
strict SQG regulations: a 20 kg/month exclusion, with required
manifesting, recordkeeping, and annual reporting.
Although more than half of all SQG wastes generated are
currently subject to requirements under state regulations, there
is some evidence that these requirements are not being actively
enforced. A study prepared for EPA by The Cadmus Group
(Reference 13) investigated seven state programs in some detail.
Respondents in most of the states said that SQGs in their states
are generally not aware of their obligations under the hazardous
waste regulations. Only two of the states contacted specifically
allocate inspection resources for SQGs, and none of the states
specifically allocates enforcement resources for SQGs. In
general, the states have placed higher priority on enforcing
compliance by TSDFs, transporters and large quantity generators.
The extensive lack of compliance with existing state SQG
regulations is confirmed by a survey of generators in states with
SQG regulations conducted by the U.S. Chamber of Commerce. This
limited survey indicated that SQGs were generally unaware of
applicable state and federal requirements, or even that they were
generating hazardous wastes.
Finally, a recent survey of 100 generators of less than
1,000 kg/month in North Carolina also indicated that SQGs were
generally not complying with that state's provisions. SQGs did
not know where 54 percent of the wastes sent off-site went.
Fifteen percent of the companies surveyed did not know which
state or federal regulations might apply to them. In general,
SQGs "did not display a high level of knowledge about the
hazardous components of their waste, the proper handling of these
components, or the ultimate disposal fate of the wastes." The
5-27
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major cause cited by the study for the lack of information and
compliance is SQGs1 lack of technical staff to monitor
regulations and assess their responsibilities.
While more than half of SQG wastes are generated in states
imposing requirements on SQGs, then, these generators do not
appear to be aware of or complying with the requirements in many
cases. One practical effect of the federal requirements and the
EPA-sponsored education program may be to increase compliance
with the existing state requirements, although the increased
compliance would not be entirely attributable to the proposed
federal regulations (since many of the requirements are already
in place in some of the states).
EFFECT OF FUTURE REGULATIONS
ON SQG COMPLIANCE OPTIONS
Chapter 4 described the options currently available to SQGs
to manage their wastes in compliance with the proposed
regulations. A number of expected changes in RCRA and other
regulations may significantly limit the options available to SQGs
in the future, however, or may increase the numbers of generators
and/or quantities of waste subject to the proposed rule. Many of
these changes are mandated by the HSWA. While these changes have
not been considered in estimating aggregate costs and changes in
risk in this report, this section provides information on
potential impacts on SQGs. The effects of changes which increase
the cost of complying with RCRA requirements will likely be to
increase incentives to recycle wastes where possible (since
recycling technologies are not regulated under RCRA) and to avoid
RCRA requirements entirely by discharging wastes to sewers
(except where Pretreatment Standards make this option too
costly). In general, the increased requirements for on-site
facilities are likely to increase SQGs1 dependence on commercial
waste management. However, except for potential new requirements
for short-term storage in tanks (discussed below), few SQGs are
expected to manage wastes on-site even under current regulations.
Therefore, the most significant effects on SQGs1 waste management
options are likely to result from potential restrictions on land
disposal of hazardous wastes.
5-28
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Land Disposal Restrictions
EPA is currently developing regulations required by the HSWA
which may ban many hazardous wastes from land disposal. EPA must
ban land disposal of hazardous wastes unless it specifically
finds that prohibition of one or more methods is not required to
protect human health and the environment for specific wastes.
Within 24 months of enactment, the Agency must decide whether to
ban land disposal of solvent and dioxin wastes. Within 32
months, ban decisions must be made for a long list of additional
wastes (the "California list").A/ All other hazardous wastes
must be evaluated for ban decisions within 66 months of
enactment. If EPA does not issue rules by any of these
deadlines, the wastes in question will be banned from land
disposal by the hammer provisions of the amendment. Such a ban
would apply to SQG wastes as well as to LQG wastes.
It is not possible to anticipate specific ban decisions in
analyzing the effects of proposed regulations on SQGs. However,
the criteria in the legislation suggest that many wastes will in
fact be banned from land disposal. This will limit the options
available to SQGs for managing their wastes in many cases
removing the least-cost management option. Affected parties can
apply for a variance if they can demonstrate that their land
disposal practices will prevent any migration of wastes for as
long as the wastes remain hazardous. Some commercial land
disposal facilities may be able to obtain variances to continue
disposing of some wastes otherwise banned from land disposal.
However, many SQG wastes are likely to banned from most or all
forms of land disposal within the next few years.
Solvent wastes one of the most common SQG wastes are
particularly likely to be banned from land disposal (at least in
some forms) within two years. While recycling might be increased
for some spent solvents, recycling generates a still bottom
containing residual solvents which may have to be incinerated
rather than being land disposed directly. A potential ban on
strong acids (pH < 2.0), which must be considered by 1987, would
I/ The California list includes liquids containing PCBs or
metals above specified concentrations, strong acids (pH<2.0), and
wastes containing halogenated organics over a specified
concentration.
5-29
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also affect significant quantities of hazardous waste. Such
wastes are relatively easy to treat (neutralize)/ however, and
are often discharged to sewers. Therefore, a ban affecting land
disposal of acidic wastes may not impose significant costs on
SQGs.
Financial Assurance for
Corrective Action
The HSWA also require that EPA require financial assurance
for corrective action for TSDFs. Under these provisions, SQGs
managing wastes on-site would have to demonstrate financial
capability to clean up contaminated sites. Financial assurance
requirements can be very costly for SQGs who are often small
businesses, and are likely to discourage on-site management by
SQGs.
New Requirements for
Qn-Site Management:
The HSWA also require more stringent design, monitoring, and
corrective action requirements for on-site surface impoundments,
interim status landfills, and interim status waste piles. New
controls on air emissions from all on-site facilities will also
be required. These additional controls will add to the cost of
on-site waste management. The few SQGs who might otherwise find
it economic to manage some wastes on-site under current
regulations might choose not to, in anticipation of these
additional requirements.
New Storage Requirements
EPA has proposed new requirements for on-site storage in
tanks and containers. As noted in Chapter 4, the Agency has
proposed a class permit procedure for storage in tanks and
containers, where that storage is the only activity for which the
facility is to be permitted. This proposal does not affect the
requirements imposed on such storage but will substantially
reduce the burden of obtaining permits for such facilities. (The
cost analysis described in Chapter 6 does not include permitting
costs, which are highly variable and which are not likely to be
incurred by many SQGs, since few are expected to apply for
permits for on-site facilities.)
5-30
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In addition, EPA is proposing new requirements for storage
in tanks. The proposed regulations delete the current shell
thickness requirements, and require testing for leaks, repair or
replacement of leaking tanks, groundwater monitoring and
secondary containment. The proposed regulations would also apply
secondary containment requirements to "accumulation" tanks
those tanks used to store wastes during the 90 day (or 180 and
270 day) period allowed for unpermitted storage. This provision
could impose significant costs on generators storing wastes in
tanks, even for less than 90 days. EPA has not yet determined
whether the proposed requirement will be applied for SQG short
storage (less than 180 or 270 days). (The requirements will be
applied as promulgated for storage by SQGs for more than 180 or
270 days, however.) The Agency has not completed a risk
assessment for the proposed rule that evaluates how risks
controlled by the secondary containment provisions might differ
for SQG and LQG short-term storage.
Pretreatment Standards
Regulations under the Clean Water Act may increase the
quantities of hazardous wastes generated by some SQG industries
and increase the costs of discharge to sewers. Additional
pretreatment requirements will require treatment of hazardous
waste waters prior to disposal to POTWs, generating potentially-
hazardous sludges that may be costly to dispose of. In
particular, enforcement of Pretreatment Standards for Metal
Finishing establishments is likely to have significant effects on
the quantities of waste generated and on the use of disposal to
the sewers. The SQG survey preceded the effective date of the
Metal Finishing Pretreatment Standards (MFPS), and thus the
quantities of hazardous waste reported in the survey are likely
to be understated for some industries.
Used Oil Regulations
Many SQGs (such as automotive repair facilities) generate
used oils, and hence will be affected by any regulations on
management of these wastes. Regulations on management of used
oils (currently being developed by EPA) would regulate used oil
as a RCRA hazardous waste. Under the proposed rule, used oil
which is not recycled or which is mixed with another hazardous
waste would be subject to the same requirements under RCRA as any
5-31
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other hazardous waste. Used oil which is recycled and which is
not mixed with another hazardous waste ("recycled oil") would be
subject to more lenient requirements. The regulation would
include a small quantity generator cutoff for recycled oil of
between 100 and 1,000 kg per month. (EPA is proposing 1000 kg per
month and requesting comment.) Recycled oil would not count
against the regular hazardous waste SQG limit, but only against
the recycled oil limit. Generators generating recycled oil below
the recycled limit would be exempt from regulation. To be
recyclable, used oil must meet certain concentration standards
for chlorine, arsenic, cadmium, chromium, lead, and PCBs. Mixing
used oil with other hazardous wastes is likely to result in a
mixture that is unrecyclable. Therefore, mixing (currently a
prevalent practice, especially with chlorinated solvents) is
likely to occur less frequently, since it will be to the
generator's advantage to recycle. Used oil for recycling is
worth about $0.20 per gallon. While the price received for used
oil is not expected to completely offset the generator's
compliance costs, net compliance costs will be considerably lower
if the generator recycles. There are no obstacles to recycling
used oil as long as it has not been mixed with another hazardous
waste and meets the recycling concentration specifications. Used
oil has sufficient market value that limitations in recycling
capacity are not expected to be an obstacle to SQGs recycling
used oil.
The Regulatory Analysis for the used oil requirements
(prepared by Temple, Barker and Sloane, Reference 49) estimates
that there are about 47,000 establishments generating over 1,000
kg/month of used oil, and about 178,000 generating between 100
and 1,000 kg/month. TBS does not estimate of the number of
facilities generating under 100 kg/month; however, they do
estimate that a significant fraction of automotive service
stations (40 to 65 percent) generate less than 100 kg/month.
Many of these generators could be regulated for larger quantities
of waste (if they are already SQGs) or may become SQGs, if they.
do not recycle their used oil. However, it seems unlikely that
these generators will choose not to recycle. Used oil may be
stored indefinitely in quantities up to 1000 kg; therefore,
generators of small quantities of used oil could store it until
they had enough to be conveniently recycled.
The regulation of recycled used oil is expected to impose
only moderate costs for individual facilities, according to TBS.
5-32
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TRADEOFF BETWEEN STORAGE AND TRANSPORTATION COSTS
This section discusses the tradeoffs facing SQGs sending
wastes off-site between the costs of longer storage and the costs
of more frequent transportation. In general, longer storage of
wastes on-site will require larger storage facilities, using more
space and involving higher regulatory costs. More frequent
transportation results in higher total transportation costs, due
to the fixed charges per pick-up imposed by transporters and the
shipment of smaller quantities on average. To assess changes in
transportation and storage practices, it is necessary to evaluate
how these two types of costs interact to affect SQGs1 shipment
practices.
As described above, lEc developed a model that predicts
transportation charges for individual SQGs under different
circumstances. (The model is described in Appendix D. Some of
the limitations of this model were discussed previously in this
chapter.) lEc used storage costs developed by Pope-Reid
Associates (PRA) (Reference 26) as inputs into the model. The
storage costs developed by PRA (exclusive of the costs of space)
do not fully reflect the variability of storage costs with the
quantity of waste stored, as described below, but nonetheless
provide insight into SQGs1 likely choices about shipment
frequencies. The estimated costs do increase after 180 and 270
days of storage. Significant costs are incurred after that
period as SQGs will be forced to comply with full Part 264
standards. (The cost of obtaining a Part B permit are not
considered in this analysis.) Appendix D also describes the
storage cost estimates used in this initial analysis.
Exhibit 5-11 shows the results of the analysis for a SQG
located in an urban area and generating 500 kg/month of wastes to
be shipped off-site. Exhibit 5-12 illustrates the tradeoffs
between storage costs and transportation costs for the same-sized
SQG located in a rural area. For the urban case, lEc assumed
that space is relatively limited (costing $20 per square foot)
and that the SQG is located in close proximity to other SQGs of
the same size. (The calculation of transportation costs assumes
seven miles between SQG pick-ups, a distance to the disposal site
of 200 miles, and transportation in an 80 drum truck operating at
85 percent of capacity.) For the rural case lEc assumed that the
costs of storage space are 510/square foot and that generators
are located 75 miles apart (again, assuming 200 miles to the
destination facility and an 80 drum truck operating at 85 percent
of capacity).
5-33
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Exhibit 5-11 suggests that a SQG located in an urban area is
unlikely to take advantage of the 180 or 270 day period for
storage without a permit. The assumed costs of the space needed
to store drums outweigh any savings associated with less frequent
shipments, especially since the SQG is located in close proximity
to other potential shippers (making him a relatively attractive
client for transporters). For the model urban SQG, total storage
plus transportation costs are minimized by shipping off-site
every 45 days. However, total costs do not vary much with the
number of shipments per year (unless wastes are stored longer
than 270 days), since the relatively high fixed costs of on-site
storage used here dominate total costs.
Exhibit 5-12 suggests that a rural SQG receives greater
benefit from ability to store wastes for longer period without a
permit. Under the assumed conditions, the model SQG would store
wastes up to 120 days before shipping off-site. Transportation
costs are somewhat more variable with shipment frequency in this
case than in the urban case, and storage costs are again
estimated as fixed (except for space) prior to 180 or 270 days.
Exhibit 5-12 also shows that even if the regulatory costs of
storage do not increase after 180 days of storage, that SQGs will
not store for longer than 120 days under this scenario due to the
costs of the space utilized by the storage of increased numbers
of drums. This analysis shows that allowing SQGs, especially
those located in rural areas, to store for longer than 90 days
may be beneficial, but that even limited variability in costs due
to the cost of space may discourage storage for as long as 180
days.
Some SQGs in rural areas may ha've unlimited storage space,
and hence incur lower costs than estimated those above for longer
on-site storage. We therefore evaluated the costs for various
shipment frequencies assuming a zero cost for space. The results
are shown in Exhibit 5-13. As expected, total storage and
transportation costs are minimized when wastes are shipped off-
site every 180 days, since the costs of storage do not vary with
quantity stored.
In general, this analysis overstates the length of the
storage period (and understates shipment frequencies) because the
variability of storage costs is understated. The analysis of
transportation cost captures the variability of these costs as a
function of quantity per shipment. However, the cost estimates
provided by PRA for generator storage requirements are not
5-34
-------
sufficiently detailed to allow lEc to calculate costs per drum.
Therefore, our analysis did not consider increases in regulatory
costs as a function of the quantity stored at any one time.
Three types of storage costs may vary based on the number of
drums managed:
1. cost of drums themselves;
2. cost of storage space; and
3. some regulatory costs (i.e., inspection costs).
The major part of storage costs for the period less than 180 or
270 days are fixed with respect to quantity stored, however.
Hence, in most cases SQGs face costs of storage and
transportation that are relatively insensitive to quantities
shipped and quantities stored, and thus SQGs1 total costs
(transportation plus storage) are not highly sensitive to the
allowed accumulation period prior to imposition of storage
facility requirements. Again, the exception will be SQGs located
in areas where transporters are not able to complete adequate
loads with wastes from other generators. These SQGs will have
stronger incentives to store on-site for the full 180- or 270-day
period.
INCENTIVES FOR ILLEGAL DISPOSAL
The issues discussed in this chapter suggest that SQGs could
in some cases be subject to significant increases in waste
management costs as a result of the proposed regulation. This is
particularly true where SQGs would have to ship wastes long
distances to obtain commercial services and/or are located in
isolated areas not served by transporters. Further, SQGs may be
subject"to increased effective (if not actual) legal liabilities
for releases of waste that can be traced to them, even if they
have complied fully with the proposed regulations. These effects
in combination raise the possibility that SQGs will evade
regulation under RCRA and dispose of wastes illegally.
Whether SQGs will choose to dispose illegally depends in
part on the inherent "detectability" of such illegal disposal.
Some types of illegal disposal are extremely difficult to detect
and trace to responsible parties. These include disposal of
certain common wastes (such as solvents) to drains (which may not
be illegal), evaporation of some types of wastes, and off-site
5-35
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transportation and "midnight dumping" of small quantities of
waste. Increasing public awareness of the risks from hazardous
waste management resulting from the planned education program is
likely to increase public scrutiny of potential generators, and
may act as an important deterrent to illegal dumping. In
addition, industry members who are complying with the proposed
regulations can be expected to exert pressure on other industry
members to comply with the regulations, since they have an
incentive to prevent low-cost competition from non-complying
establishments.
It is impossible to predict the net affect of increased
costs and liabilities vs. increased public scrutiny and
enforcement of the proposed regulations. Because the annual
costs imposed on most SQGs are not expected to be significant
(see Chapters 6 and 8), it is likely that the proposed
regulations, in combination with efforts to educate SQGs about
proper disposal practices, will result in improved waste
management. However, in some cases, mismanagement of wastes
could continue or even increase as a result of the proposed
regulations.
5-36
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EXHIBIT 5-1
TRANSPORTATION COSTS FOR fl SENERflTOR OF 1000 KG/MO.
No. of Shiwents/Year
fiveraqe Shioment Size
No. of Druas Shiooed
Case A: FULL TRUCKLOflDS
Distance to Distance
Destination Stun. PicK-uos
(Riles) (miles)
25 1
25 10
200 1
200 10
500 1
500 10
1.000 1
1.000 10
Case B: HflLF TRUCKLOflDS
25 1
25 10
200 1
200 10
500 1
500 10
1.000 1
1.000 10
2
6.000
30
194
210
505
522
1,025
1,041
1,860
1,875
236
252
858
874
1.897
1.914
3,568
3,584
-TOTftL COST PER YEflfi-
4 8
3000 1,500
15 8
234
266
522
554
1,010
1,041
1,806
1,837
274
306
aso
882
1,825
1,856
3,418
3,449
238
301
5£1
584
1,004 1,
1,067 t,
1,800 1,
1,863 1,
278
341
844
907 I.
1.810 1,
1,872 1,
3,402 3,
3,465 3,
12
1000
5
337
431
613
713
100
194
396
990
377
471
940
035
302
397
495
589
COST PER TON CF kftSTE
£ 4 B 12
6.000 3.000 1.500 1,000
20 15 8 5
16
18
42
43
85
87
155
156
20
21
71
73
158
159
297
299
44
34
87
151
153
23
25
71
73
152
155
285
287
20
25
64
89
150
155
23
28
156
254
283
92
158
16£
Ibt
-------
EXHIBIT 5-2
TRflNSPORTflTION COSTS FOR fl GENERflTOR OF 100 KG/MO.
No. of Shi went s/Year
Average Shipment Size
No. of Drums Shicioed
Case fl: FULL TRUCKLOflDS
Distance to
Destination
(mles)
25
25
200
200
500
500
1.000
1.000
Distance
Btwn. Pick-uos
(Biles)
1
10
1
10
1
10
1
10
Case B: HflLF TRUCKLOflDS
25 1
25 10
200 1
200 10
500 1
500 10
1.000 1
1,000 10
2
600
3
56
73
87
104
139
156
223
239
60
77
123
139
226
243
394
410
~ 1 U 1 HU LUD 1
4
300
2
103
134
132
163
181
212
260
292
107
138
165
1%
262
293
421
453
PCK
8
150
1
202
265
230
293
279
341
358
421
2%
269
263
326
359
422
518
581
T CHU
12
100
1
301
395
329
423
377
472
457
551
305
399
351
456
457
552
617
711
COST PER TON OF l^flSTE
2 4 8 12
600 200 150 100
3211
61
73
116
130
186
199
50
64
102
116
189
202
328
342
36
112
110
136
150
177
217
243
39
115
137
163
218
245
351
377
:68
221
232
285
298
351
172
224
21
393
381
254
333
432
484
-------
EXHIBIT 5-3
THE EFFECT OF DISTflNCE BETWEEN PICK-UPS
ON TRflNSPORTflTICN COSTS
(For a uenerator of 500 ka/mo.)
No. of Shionents/Year
Average Shionent Size
No. of Drums Shiooed
Case Q: FULL TRUCKLOflDS
Distance to
Destination
tailes)
25
25
200
£00
500
500
1,000
1,000
Distance
Btwn. Pick-uos
(niles)
7
75
7
75
7
75
7
75
Case B: HflLF TRUCKLOflDS
£5 7
25 75
200 7
200 75
500 7
500 75
1.000 7
1,000 75
2
3,000
15
134
259
289
414
549
674
967
1,092
155
279
466
590
-IUIHI. LU:
4
1500
8
140
378
284
522
528
765
926
1,163
160
397
448
686
3i PCK rt
8
750
4
260
735
402
877
643
1,118
1,041
1,516
280
755
563
1,038
HK
it
50(
380
1,093
521
1,234
761
1.474
1,159
1,872
400
1,113
632
1,395
CDST PER TON GF wASTE
986 935 1.046 1.163
1.110 1,173 1.531 1.875
1,321 1.732 1,842 1,959
1,945 1,969 2,317 2.672
1.000
15
22
43
48
69
92
112
161
182
26
47
78
98
164
185
303
324
l.:CO
3
23
63
47
37
38
128
154
194
27
66
75
114
156
195
289
328
750
t
43
1£2
67
146
107
186
174
253
n7
ii£
94
173
17^
253
307
386
500
63
182
37
206
127
246
193
312
67
IKS
11»
£32
19i
313
326
f4j
-------
EXHIBIT 5-4
COMPARISON OF ESTIMATED TRANSPORTATION COSTS
($1984)
Shipment
Size
600 kg.
1000 kg.
3000 kg.
6000 kg.
No. of
Shipments
Per Year
2
2
2
2
Truck
Utilization
Rates
35
53
60
75
PRA
Cost
Estimate
258
258
572
862
V.UO1O
lEc
Cost
Estimate
116
121
258
391
NOTES:
PRA's costs estimates are from ICF Incorporated, et. al., "Economic
Analysis of Resource Conservation and Recovery Act Regulations For
Small Quantity Generators," May 1985, pp. 3-34 and 3-35.
The distance to the TSDF is 100 miles and (for the lEc analysis) the
distance between pick-ups is 10 miles (20 minutes at 30 mph).
-------
EXHIBIT 5-5
AVERAGE TRANSPORTATION COSTS
FOR URBAN AND RURAL GENERATORS*
Distance URBAN SQG RURAL SQG
to TSDF Annual Costs Annual Costs
(miles) Costs Per MT Costs Per MT
25
200
500
1000
138
321
626
1,118
23
53
104
186
262
445
751
1,242
44
74
125
207
* For a generator of 500 kg/mo, shipping twice a year in a
truck operating at 85% utilization.
-------
EXHIBIT 5-6
AVERAGE SHIPMENT DISTANCES BY
METHOD OF WASTE MANAGEMENT
Unweighted Weighted
Average Average
Management Distance Distance
Method' (miles) (miles)
Landfill 234 180
Incineration 174 119
Solvent Recycling 132 97
Deep Well Injection 130 91
Neutralization 140 108
TOTAL 154 122
NOTES:
These distances were determined based on results
from Question #17 of the Generator Questionnaire
of the RIA Mail Survey and the HWDMS Data Base.
Commercial hazardous waste management facilities
were identified based on the EAB Commercial
Facility Data Base.
-------
EXHIBIT 5-7
AVERAGE SHIPMENT DISTANCES BY
FACILITY LOCATION
Unweighted Weighted
Average Average
EPA Distance Distance
Region (miles) (miles)
1 50 39
2 126 79
3 68 53
4 146 97
5 139 126
6 213 142
7 98 93
8 176 32
9 249 246
10 220 179
TOTAL 154 122
NOTES:
These distances were determined based on results
from Question 117 of the Generator Questionnaire
of the RIA Mail Survey and the HWDMS Data Base.
Commercial hazardous waste management facilities
were identified based on the EAB Commercial
Facility Data Base.
-------
Exhibit 5-8
INDUSTRY GROUPS SUBJECT TO PRETREATMENT STANDARDS
Industry Category
Pesticide End-Users
Pesticide Application
Chemical Manufacturing
Wood Preserving
Formulators
Laundries
Other Services
Photography
Textiles
Vehicle Maintenance
Equipment Repair
Metal Manufacturing
Construction
Motor Freight Terminals
Furniture *
Printing *
Cleaning Agents
Other Manufacturing
Cottom Ginning
Miscellaneous Plastics
Leather Tanning **
Flat Glass & Abrasives
Abrasive Products
Gaskets
Paper Industry **
Analytical Laboratories
Educational Establishments
Wholesale and Retail
Excluded from
Pretreatment
Regulation
Section 8
X
X
X
X
X
X
X
X
X
X
X
Other
X
X
X
X
X
X
X
X
Subject to .
Pretreatment
Regulations
X
X
**
Some subcategories in this industry are subject
pretreatment regulations.
to
A few subcategories in this industry are excluded from
pretreatment regulations under Section 8.
-------
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Exhibit 5-10
MAJOR GENERATING STATES FOR THE
TEN LARGEST WASTES
Waste Stream
Quantity
Generated
National
MT/year *
Major
Generating
States
% of
Total
Spent Solvents
105,368
Strong Acid or Alkaline Wastes
29,791
Photographic Wastes
18,431
Filtration Residue for
Dry Cleaning
13,660
Solution or Sludge with
Photo Silver
8,919
California
New York
Pennsylvania
Texas
Illinois
Total
New York
California
Pennsylvania
New Jersey
Texas
Total
California
New York
Illinois
Texas
Ohio
Total
New York
California
Texas
Pennsylvania
New Jersey
Total
California
New York
Texas
Illinois
Florida
9.51
7.64
6.93
6.29
5.54
35.91%
12.53
8.72
8.65
6.99
6.91
43.80%
19.19
10.89
6.23
4.61
3.99
44.92%
11.99
8.89
7.69
5.34
4.83
38.73%
17.25
14.02
6.50
4.84
4.58
Total
47.19%
-------
Waste Stream
Quantity
Generated
National
MT/year
Major
Generating
States
% of
Total
Waste Formaldehyde
8,850
Ignitable Wastes
8,485
Ignitable Paint Wastes
6,713
Ohio
Illinois
Michigan
Texas
Indiana
Total
California
New York
Illinois
Ohio
New Jersey
Total
California
New York
Illinois
Ohio
Texas
Total
8.70
7.95
5.54
5.01
4.67
31.87%
9.97
7.28
6.78
6.16
5.12
35.32%
14.80
8.16
5.67
5.58
4.65
38.87%
Pesticide Washing and Rinsing
6,069 California 8.55
Ohio 8.11
Illinois 7.88
Texas 6.33
Florida 6.15
Spent Plating Wastes
Total 37.02%
5,768 California 17.29
New York 14.80
Pennsylvania 8.89
New Jersey 8.54
Massachusetts 7.16
Total 56.67%
*These waste quantities, developed by ICF, are slightly larger than
totals calculated by lEc based on the SQG survey.
the
Source: ICF, Inc., Reference 26.
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COSTS OF THE PROPOSED RULE AND ALTERNATIVES CHAPTER 6
INTRODUCTION
This chapter describes the costs of the proposed SQG
regulations and alternatives to the proposed rule. The chapter
o summarizes the methodology used to develop the
costs;
o reports the estimated aggregate compliance costs;
o describes compliance costs for alternatives to the
proposed rule;
o presents estimates of the costs likely to be
incurred by the government in implementing and
enforcing the proposed regulations; and
o discusses the limitations of the cost analysis.
All analyses described in this chapter were prepared by ICF,
Incorporated, Development Planning and Research Associates
(DPRA), and Pope-Reid Associates (PRA), and are documented in the
report titled, "Economic Analysis of Resource Conservation and
Recovery Act Regulations For Small Quantity Generators"
(Reference 26) .
6-1
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DESCRIPTION OF METHODOLOGY
FOR ESTIMATING COSTS
Components of Compliance Costs
Incremental costs associated with the proposed regulation
were calculated by Pope-Reid Associates (PRA) as the difference
between the costs of baseline (pre-regulation) practices and the
costs of post-regulation practices. The compliance costs
resulting from SQG regulations consist of two components: (1) the
direct regulatory costs associated with administrative and
facility requirements, and (2) the higher costs of new methods
for treating or disposing of the waste (including transportation
costs if the waste is shipped off-site).
The direct regulatory costs which SQGs are most likely to
incur include the costs of complying with 40 CFR Part 262 and
Part 265 (Subparts A - I). These costs consist of initial costs
(which were annualized to determine an annual revenue
requirement) and annual costs. The costs of complying with each
portion of the proposed regulation are shown in Exhibits 6-1
through 6-3. The estimated regulatory costs do not generally
vary by waste stream or facility size, except for the costs of
complying with 40 CFR Part 265, Subpart I which specifies the
requirements for managing wastes in containers. These costs
vary both by type of waste and by the quantity of waste stored
on-site.
The costs of treating and disposing of wastes were developed
by PRA based on the type of waste, the type of management, and
the quantity of waste managed. Transportation costs were
estimated assuming that wastes are shipped 100 miles to a
disposal site twice a year. Total transportation costs vary by
the quantity of the waste transported but do not vary by waste
type.
Estimated Incremental Costs by Waste Stream
and Required Change in Practice
Incremental compliance costs were developed by PRA for each
of the ten largesc waste streams generated by SQGs. These ten
waste streams represent more than 90 percent of the waste
quantities generated by SQGs. The results of the SQG Survey
indicate that each waste stream is managed by more than one
management method. Therefore, incremental costs for different
6-2
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baseline and post-regulation management combinations were
developed for each waste stream. In selecting the post-
regulation compliance option to apply to each baseline management
method and each waste stream, it was assumed that the method of
waste management would not change unless the current practice
would be prohibited under the new regulations (e.g., sanitary
landfill disposal). In these cases, the costs of different
baseline and post-regulation management scenarios were developed.
For each baseline and post-regulation waste management
combination, costs were developed for three different sizes of
generators: those generating 1,2.00 kg/year, 6,000 kg/year, and
12,000 kg/year. Baseline costs included the cost of storage
(where appropriate) in closed metal drums, plus the cost of the
current waste management method. Post-regulation costs include
the cost of upgrading storage, the costs of administrative and
facility requirements, the higher costs associated with new
management practices (if any) and the costs of transportation
(where relevant). Exhibit 6-4 shows the range of incremental
compliance costs for each waste stream.
Distribution of Waste Quantities
by Required Change in Practices
Once the costs of baseline and compliance practice
combinations were determined, it was necessary to assign waste
quantities to each of these combinations for each waste stream.
Not all baseline and potential post-regulation management
practices were considered in the distribution of waste quantities
or in the analysis of compliance costs, to simplify the analysis.
On-site treatment, on-site incineration, disposal to septic
tanks, off-site treatment and off-site incineration at Subtitle
C facilities, and off-site incineration at solid waste facilities
were not included explicitly among the baseline options. In
addition, the use of Subtitle C incinerators is not considered
among the potential post-regulation practices, although it would
be a legal option. Therefore, no waste quantities and no costs
are associated with these specific practices.
In order to estimate aggregate SQG compliance costs, it was
necessary to take into account non-targeted wastes and SQGs in
industries not explicitly surveyed in the SQG Survey. Abt
Associates estimated that the total amount of waste generated by
SQGs is 740,000 MT/year. This quantity includes used lead-acid
batteries. For the purposes of this analysis, it was assumed
that used lead-acid batteries would be reclaimed and therefore
6-3
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would be exempt from regulation under RCRA. Abt estimated that
62 percent of the wastes generated by SQGs are used lead-acid
batteries. Therefore, 38 percent of waste generated by SQGs was
included in developing aggregate compliance cost estimates.
Although explicit survey results are available for only 186,232
MT of waste, the remaining waste quantity (94,768 MT) was
distributed among the waste streams and management practices
based on survey results.
Waste quantities were distributed among the major baseline
practices based on waste-specific results reported in the Abt
report on the SQG Survey (Reference 6) showing the quantity of
five waste streams managed by the various baseline practices.
Distributions for the other waste streams were developed based on
the number of generators reporting each practice, using
tabulations prepared by DPRA and PRA. The seven baseline
practices considered were: sanitary landfills, secure landfills,
treatment and recycling for off-site practices; recycling and
POTW disposal for on-site practices; and a category for "other"
practices. Waste quantities reported as being managed by
practices different from the seven specific practices considered
were assigned to the "other" category. In cases where the
baseline management practice for a particular waste quantity was
unknown, this quantity was redistributed among the known waste
management options in proportion to the amount of waste currently
managed by those options. Where a waste was reported as being
managed by more than one option, the total waste quantity was
assigned to the fi:ial management practice.
Post-regulation practices were predicted by assuming that
the current baseline practice did not change unless that practice
will be banned under the proposed regulations. In most cases,
the least-cost alternative means of managing the waste was
selected as the post-regulation practice if a change in practice
was required. The least-cost option was not chosen in cases
where it was believed that the least-cost option (1) would not be
available in the future due to regulatory restrictions (e.g.,
banning liquids from landfills), or (2) is already being utilized
to the maximum extent available.
The distribution of the waste quantities by combinations of
baseline and post-iregulation practices are shown in Exhibit 6-5.
Exhibit 6-6 shows the predicted shifts in practice by waste used
in the cost analysis. This exhibit is derived from the
percentages shown in Exhibit 6-5.
6-4
-------
For purposes of the cost analysis, the only shifts in
practice considered result from discontinued disposal in Subtitle
D landfills. Wastes previously disposed in such landfills are
predicted to be recycled (spent solvents), sent to Subtitle C
landfills (acids and alkalies, photographic wastes and wastes
with silver, dry cleaning filtration residues, ignitable wastes,
and formaldehyde wastes), sent to Subtitle C treatment off-site
(ignitable paint wastes) or disposed in sewers (pesticide washes
and rinses.
These simplified assumptions about shifts in practice
understate somewhat the extent to which SQG management practices
will have to change, and hence understate costs in some cases.
More detailed analysis of potential changes in practices
(discussed in Chapter 7) suggests that shifts due to discontinued
Subtitle D disposal represent less than 70 percent of the
quantities likely to require changes in management practice, and
even that figure may be overstated. On-site treatment may also
be discontinued in many cases, because SQGs would not incur the
regulatory costs associated with being a treatment facility.
However, the shift from Subtitle D landfills does constitute the
largest portion of predicted changes in management practice, and
was therefore the focus of the cost analysis.
Estimate of Aggregate Compliance Costs
Estimates of the total incremental costs for the proposed
SQG regulation were developed using the incremental costs of the
baseline and post-regulation combinations by waste stream
described above. Aggregate compliance costs were estimated using
annual incremental costs developed for a facility generating
6,000 kg/year of the specified waste. For example, for ignitable
wastes which are currently disposed in sanitary landfills, the
least expensive compliance option is disposal at a secure
landfill. A generator who must shift his ignitable wastes from a
sanitary landfill to a secure landfill is estimated to incur
incremental annual costs of $1,846 ($1,538/MT) if he generates
1,200 kg/year, ?3,566 ($594/MT) if he generates 6,000 kg/year,
and $5,554 ($463/MT) if he generates 12,000 kg/year. Therefore,
when calculating aggregate costs, an incremental cost of $594/MT
(corresponding to the cost for a 6,000 kg/year generator) was
assumed for all ignitable wastes currently disposed in sanitary
landfills by SQGs. This simplification understates costs for
smaller SQGs and overstates costs for larger SQGs.
6-5
-------
To determine total compliance costs for all ignitable wastes
currently disposed in sanitary landfills, $594/MT was multiplied
by the quantity of ignitable wastes currently disposed in
sanitary landfills (3,111 MT) to determine the total compliance
cost for these wastes disposed in sanitary landfills ($1.8
million). To determine total compliance costs for ignitable
wastes, the compliance cost for each relevant baseline and post-
regulation combiniition was multiplied by the quantity of waste
associated with that practice, and then these costs were summed.
The compliance costs for each waste stream and the total costs
for all wastes are shown in Exhibit 6-5.
The compliance cost assigned to those waste quantities in
the "other" management category was the incremental compliance
cost for the most common management method for each waste stream.
For example, as Exhibit 6-5 shows, the most common management
practice for photographic wastes is on-site recycling.
Therefore, the quantities classified under "other" are assigned
the incremental cost for on-site recycling, or (for photographic
wastes) S177/MT.
Under the proposed rule, generators who recycle their wastes
off-site under special agreements with recyclers (where the
generator or the recycler maintains ownership of the waste at all
times) are exempted from manifesting requirements. This will
reduce compliance costs by $245/year for each generator recycling
his wastes in this manner. For the purposes of the cost
analysis, it was assumed that 50 percent of the spent solvents
currently recycled off-site and 10 percent of the ignitable
wastes and ignitcible paint wastes currently recycled off-site
will be subject to these reduced requirements.
Wastes which are disposed to POTWs (without pretreatment or
storage prior to disposal) are exempt from RCRA regulations.
Therefore, these wastes will not be subject to compliance costs
under the proposed regulation. The percentage of wastes disposed
to POTWs are shown in Exhibit 6-5, although no costs are
associated with this practice, in order to account for the
management practices of all SQG wastes.
As described here, the procedures used to calculate
aggregate costs make a number of simplifying assumptions to
reduce the complexity of the analysis. Therefore, the estimated
costs may not be accurate for particular groups of SQGs. It is
unlikely that more refined analysis would result in significantly
different aggregate costs, however, although the costs for
6-6
-------
particular groups could be over- or understated. Further, the
cost analysis provides sufficient detail to identify the
conditions that will cause SQGs to incur significant costs. The
major limitations of the aggregate cost analysis, as well as the
major factors potentially resulting in significant costs, are
discussed in the final section of this chapter.
RESULTS OF COMPLIANCE COST ANALYSIS
The cost analysis estimated aggregate compliance costs of
about $56 million per year for the ten waste streams specifically
considered. These wastes account for 271,000 MT or 96.5 percent
of the 281,000 MT of waste generated by SQGs (including wastes
from secondary industries not included in the SQG survey.)
Compliance costs for the remaining 9,835 MT of wastes estimated
to be generated by SQGs were developed assuming that these wastes
are distributed across the baseline management options in
proportion to the ten modeled waste streams. The average
incremental compliance cost for each management option was
applied to these quantities. After these additional wastes are
considered, the aggregate compliance costs total $58 million.
Exhibit 6-7 summarizes the results of the aggregate cost
analysis. More than two-thirds of the aggregate incremental
compliance costs result from imposition of additional
administrative, manifest and storage requirements in cases where
management practices are not predicted to change (253,000
MT/year). The added costs in these cases average $164 per MT of
waste. A much smaller quantity of waste (28,000 MY/year) is
predicted to be managed by different practices, with an average
increase in costs (for higher-cost management plus
administrative, storage and manifest costs) of $582 per MT.
These wastes account for less than one-third of the aggregate
costs.
ICF et. al. tested the potential sensitivity of the
aggregate cost results to a major assumption used in the cost
analysis: the use of a 6,000 kg/year generation rate for all
wastes. Because waste quantities were the primary unit of
analysis, it was necessary to assume a generation rate to obtain
aggregate costs. The average generation rate selected can have a
significant effect on aggregate costs, since different rates
implicitly assume different aggregate numbers of SQGs subject to
additional costs. To test the sensitivity of aggregate costs to
6-7
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the rate selected, costs were calculated assuming two extreme
generation rates: 1,200 kg/year and 12,000 kg/year. If all SQG
wastes were generated at a rate of 1,200 kg/year, total aggregate
compliance costs would be $220 million. At a generation rate of
12,000 kg/year, total aggregate compliance costs would be $37
million. Costs are lower at the higher rate, since most
compliance costs are fixed with respect to quantity generated at
each establishment and vary with the number of generators, and
since the higher rate implicitly assumes a smaller number of
generators. The Abt survey suggests that a mean generation rate
for SQGs is between 3,600 kg/year and 6,000 kg/year.
Interpolating to estimate costs for generation rates of 3,600
kg/year and 4,800 kg/year (the midpoint between 3,600 kg/year and
6,000 kg/year) result in aggregate compliance costs of $85
million and $68 million, respectively. Thus, the estimate of $58
million developed assuming a generation rate of 6,000 kg/year
may somewhat understate the actual aggregate costs. However,
neither estimate of aggregate costs for generation rates which
may more closely reflect the actual generation rates exceed $100
million.
COMPLIANCE COSTS FOR REGULATORY ALTERNATIVES
Differences in compliance costs were calculated by ICF et.
al. only for alternatives to the generator requirements. Two of
the alternatives for facility standards (Fl and F2) differ by
timing only, with the proposed alternative having an extended
effective date. Differences in costs associated with the delayed
effective date were not estimated. Tailored facility standards
were not considered in detail for alternative F3, and no costs
were estimated.
The costs for the three alternatives for generator standards
are shown in Exhibits 6-1 through 6-3. The costs consist of
initial and annual portions. As is evident from Exhibits 6-1 and
6-2, alternative G-2 imposes the lowest costs on generators for
complying with 40 CFR Part 262 and Part 265 (Subparts A-H only) .
The largest portion of compliance costs for Part 262
requirements, for all alternatives, is incurred for waste
analysis and notification to obtain an EPA identification number.
The largest portion of costs for compliance with Part 265
(exclusive of Subpart I) requirements, for all alternatives, is
incurred for instructing employees on the proper management of
the waste and emergency procedures, having the facility inspected
6-8
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by the fire department, and other measures to ensure that the
facility is maintained so as to ensure safe waste handling during
the unpermitted storage period. Alternative G-l imposes
additional costs for recordkeeping and reporting, contingency
plan preparation, and some other requirements. The only cost
difference between options G-2 and G-3 is that option G-3
involves additional costs for recordkeeping and reporting
(initial costs of $87 and annual costs of $90). All options
include the same costs for container management under 40 CFR Part
265, Subpart I (shown in Exhibit 6-3). These costs vary widely
depending on current storage practices and types of waste
involved.
The estimated costs in Exhibit 6-1 through 6-3 show that
reduced manifest requirements have only a minor effect on costs.
More significant cost reductions result from the reduced
requirements for short-term storage.
ESTIMATED GOVERNMENT COSTS
Implementation of the small quantity generator regulation
will impose a number of costs on the government, most of which
are administrative in nature.I/ Total government costs
attributable to the SQG regulation include three major
categories: program administration costs; technical assistance
and public education program costs; and compliance monitoring and
enforcement costs. Depending on the regulatory alternative being
considered, program administration costs consist of one or more
of the following cost elements: issuing an EPA identification
number; reviewing exception reports; reviewing biennial reports;
issuing permits; and overseeing state programs.
The costs to the government associated with the proposed
rule and alternatives were estimated by ICF, Inc., as described
in Reference 26. Exhibit 6-8 summarizes the three categories of
government costs incurred in the first year of SQG regulation for
the different regulatory alternatives considered. The major
I/ If the SQG regulatory program is administered by an
authorized state, the costs will be borne by the state, rather
than by EPA. The following discussion assumes that costs
incurred by the states are identical to those incurred by EPA.
6-9
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portion of the costs for all alternatives are attributable to the
technical assistance and public education program, which range
from $8 million to $10 million. This represents a cost of from
$160,000 to $200,000 per state. This unit estimate was developed
based on the funding that is available for a similar SQG
consultation program already in effect in one state. The costs
of inspection are the next largest costs, ranging from a total
of $1.92 million to $2.74 million. Enforcement costs of from
$910,000 to $1.3 million were estimated assuming that no
enforcement action would be used other than a warning letter to
those SQGs found to be violating SQG regulations. The estimated
costs of administering an EPA ID number requirement total
$900,000. This is a one-time cost, incurred in the first year of
the regulation. An additional $45,000 was estimated for costs
incurred in subsequent years, although this value has not been
included in the total estimates presented in Exhibit 6-8. The
cost of reviewing biennial reports is one of the smallest costs
incurred an estimated $432,000 every two years, or
approximately $21(5,000 per year. Costs for issuing permits for
storage and on-site treatment are estimated to be negligible
because it is assumed that (1) very few SQGs will store wastes
on-site for more than 180 or 270 days days because of the high
storage cost beyond this period, and (2) few SQGs will dispose of
wastes on-site because the costs of doing so generally will be
higher than off-site disposal.
Total costs for each regulatory option, incurred in the
first year of the SQG regulation, are also presented in Exhibit
6-8. Pour of the six regulatory alternatives (1, 2, 5 and 6)
incur the same combination of sub-category costs, resulting in
identical total government costs of from $11.24 to $14.06
million. The costs for alternatives 3 and 4 are only $200,000
higher because they involve the additional cost of reviewing
biennial reports. All of the regulatory alternatives impose the
same costs except for the costs of reviewing biennial reports.
The costs shown in Exhibit 6-8 are likely to be somewhat
overstated. These estimates include costs to States that are
currently regulating SQGs, and are therefore currently incurring
the costs of some or all of the activities described above.
However, ICF estimates that these costs are likely to be
overstated by no more than ten percent, based on a review of
current state regulation of SQGs. In addition, costs are
estimated to decline after the first year. For example, the cost
of issuing EPA identification numbers will be highest in the
first year of regulation. Costs for the second and subsequent
6-10
-------
years following the regulation will be less ($45.000 a year as
opposed to $0.9 million for the first year). In addition-
although the technical assistance and public education program
may need to continue for a number of years. the major
expenditures will be incurred in the first few years that the
regulation is in effect. Therefore, these costs of $8 million to
$10 million dollars might be substantially lower in the years
following the first year of SQG regulation.
CONCLUSIONS AND LIMITATIONS
OP THE ANALYSIS
The analysis prepared by ICF et. al. described in this
chapter suggests that the proposed rule will impose costs of
approximately $69 million per year, at least in the early years
of the SQG regulation. Of the estimated costs, compliance costs
incurred by SQGs account for $58 million per year (on an
annualized basis) and costs incurred by the government to
implement and enforce the proposed rule account for approximately
$11 million in the first year. Based on these estimates, the
proposed rule does not constitute a major rule according to the
aggregate social cost criterion specified by Executive Order
12291 ($100 million per year )
A number of simplifying assumptions were made for the
purposes of this cost analysis which may affect the accuracy of
the estimated costs- These limitations include the following:
o The cost analysis did not take into account the
fact that some SQGs are currently regulated under
State laws and may incur no costs or limited costs
attributable to the proposed Federal regulations.
o The most common baseline and compliance practice
options were considered explicitly in estimatinq
costs for different combinations of practices and
in estimating aggregated costs. Costs for less
common practices may be under- or overstated by
this approach.
o Only the ten largest waste streams were analyzed
in detail, and the compliance costs for other
waste streams were developed based on this
analysis. Thus, the results may not be accurate
for some wastes. However/ the ten waste streams
6-11
-------
considered explicitly comprise 96.5 percent of the
total quantities generated by SQGs.
Some current practices which are predicted not to
change after imposition of the proposed rule may
in fact have to be changed to comply with the
relevant RCRA requirements- For on-site treatment.
the cost analysis assumes that practices will not
change- In reality. some forms of on-site
treatment may have to be upgraded or would be
discontinued. For example, it is particularly
likely that any treatment in surface impoundments
would be discontinued, because of the high costs
involved in meeting the Part 264 and 265
requirements Costs are understated in these
cases.
Aggregate costs were estimated assuming that all
wastes are generated at an average rate of 6000
kg/year This procedure is expected to
underestimate costs somewhat-
It was cLSsumed that wastes are stored in drums for
purposes of estimating compliance costs. and
therefore the analysis does not consider the costs
incurred by SQGs who may store their wastes in
tanks or by other methods. Further, it was
assumed for the cost analysis that all generators
are currently storing in metal drums and would
therefore not have to upgrade their containers.
This assumption understates costs for those SQGs
currently storing in inadequate containers.
The cost analysis did not take into account the
fact that some recycled wastes are exempt from
RCRA requirements entirely (those that are used or
reused without prior reclamation)- Thus. SQGs who
manage such wastes will not incur the costs for
complying any of the regulatory costs. Use/reuse
represents 33 percent of reported on-site
recycling and 25 percent of reported off-site
recycling (see Exhibit C-14.) On the other hand,
recycling is assumed to continue for waste
currently burned or blended as fuel or applied to
the land, although both practices may end under
6-12
-------
the proposed rule. These practices together
represent 12 percent of the reported recycling.
o The cost analysis assumes off-site transportation
distances of 100 miles. As discussed in Chapter
5- actual distances may be much greater in some
cases. While the transportation costs assumed for
100 miles in the cost analysis appear to be
somewhat high, the estimates used may not be as
high as some SQGs will in fact incur. SOGs
located in rural areas or in states without
permitted landfill capacity are especially likely
to incur higher transportation costs.
o The cost analysis developed costs for generators
assuming that only one waste stream is generated
per establishment. This may understate costs to
those generators who generate more than one waste
stream who may have to transport and manage each
waste separately.
While a number of simplifying assumptions were necessary to
reduce the complexity of the analysis, alternative assumptions
are not likely to result in an aggregate cost estimate which is
significantly different than presented here. However. it is
possible that costs may be under- or overstated for some groups
of SQGS.
6-13
-------
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-------
EXHIBIT 6-3
INCREMENTAL PART 265 (SUBPART I) COMPLIANCE COSTS
Initial Annual
Subpart I . ($)* (S/Yr)*
< 180 days:
100 Kg/month 4-537 404-924
1,000 Kg/month 25-1,854 447-4,251
£ 270 days:
100 Kg/month 7-757 406-1,021
1,000 Kg/month 29-2,323 454-4,454
Full Subpart I 2,165-7,500 477-5,517
Requirements
Cost ranges are a function of baseline practice and waste stream; costs
for transport and disposal are not included in annual costs.
SOURCE: ICF Incorporated, et. al., "Economic Analysis of
Resource Conservation and Recovery Act Regulations
For Small Quantity Generators," May 1985, Exhibit 4-4
-------
EXHIBIT 6-4
INCREMENTAL COMPLIANCE COSTS
FOR PROPOSED SQG REGULATIONS
BY WASTE STREAM
Waste Stream
Spent Solvents
Strong Acids/Alkaline Wastes
Photographic Wastes
Dry Cleaning Residue*.
Solutions or Sludges With
Photographic Silver
I gn it able Wastes (liquid)
Ignitable Wastes (solid)
Wastes Containing Formaldehyde
Spent Plating Wastes
Pesticide Washing and Rinsing
Sol ut ions
Ignitable Paint Wast«s
120O kg/yr.
$825-1714
*443-1534
* 1062-2086
* 1062- 1846
$1062-2441
* 1257-2356
$1502-1846
*2056
$443-2329
$1217-2086
$1252-2166
Annual Cost Ranges
fferent Generation
600O kg/yr. 1
$845-3625
$443-2993
$1064-4766
$1064-3566
$1064-4766
$1352-5932 $
$253 1-3566
$4432
$220-5903 $
$1568-4766
$1568-5229
200O kg/yr.
$870-5853
$215-5543
$1065-7954
$1065-5554
$1065-7954
1221-10, 242
$3816-5554
$7242
1065-10, 2O9
$1797-7954
$1797-9898
* Cost ranges exclude incremental costs for disoosal to POTWs (without
oret reat merit) because such disoosal will have no costs under this
regulation and wi.Ll be the lowest cost option in those cases where
wastes are in a suitable form for POTW disoosal. In addition, the
costs for a shift in oractice to onsite treatment are not included
because it is assumed that SQGs will choose a lower cost ootion. fil
costs are expressed in 1984 dollars.
Source: ICF Incorporated, et. al., "Economic Analysis of Resource
Conservation and Recovery Act Regulations for" Small Quantity
Generators," Exhibits 45 throuah 415.
-------
EXHIBIT 6-3
AGGREGATE COMPLIANCE COSTS
BY WASTE STREAM AND MANAGEMENT PRACTICE
Waste Stream
SPENT SOLVENTS
Current Mgmt. Distrib.
Comol lance Cost (ave. »/MT>
New ngmt. Distribution (X>
Total Comol lance Co»t (*1OOO)
STRONG AC I OS /ALKALINE WASTES
Current Mgmt. Distrib.
Comol ianc> Comt Cave. */MT>
New Mgmt. Distribution (X)
Total Compliance Cost (stOOO)
PHOTOGRAPHIC WASTES
Current Mgmt. Distrib.
Compliance Cost lave. »/MT)
New ngmt. Distribution (X)
Total Compliance Cost (slOOO)
DRV CLEANING RESIDUES
Current Mgmt. Distrib. IX)
Compliance Cost (ave. »/MT)
New Mgmt. Distribution . »/MT)
N»M Mgmt. Distribution (X)
Total Conpliane* Cost (»1OOO)
WASTES CONTAINING FORMOLDEHYDE
Current flgmt. Distrib. (X)
Conolianc* Cost (av«. »/MT>
NKM ngmt. Distribution
Sam t arv
Landf l 1 1
4
*07
0
21O9
3
4O4
0
307
Z
694
0
293
54
394
0
7731
1
694
O
84
27
394
0
1848
14
739
O
843
Subtitle C
Landf i 11
3
i&e
3
1179
1O
182
13
762
2
4S2
4
178
12
422
66
1224
O
N/fl
1
N/A
9
422
36
438
O
N/A
14
N/A
Subtitle C
Treatment
6
332
6
2380
0
N/A
O
N/A
0
N/A
0
N/A
O
N/A
O
N/A
O
N/A
O
N/A
1O
622
1O
717
0
N/A
O
N/A
Recycle
36
162
6O
11732
a
182
a
610
4
422
4
336
7
432
7
714
0
N/A
0
N/A
29
418
29
1397
O
N/A
0
N/A
Reeve le
On-Slte
16
231
16
3202
20
177
20
1482
11
177
11
41O
7
177
7
299
32
177
32
684
3
223
3
130
2
N/A
2
N/A
POTW
3
O
3
O
39
O
39
O
79
O
79
0
13
O
13
O
43
O
43
O
16
0
16
0
80
0
80
0
Other
1O
182
1O
2338
20
177
2O
1482
2
177
2
73
7
422
7
714
24
177
24
313
4
422
4
194
4
203
4
67
Total
129341
1OO
194
10O
23 ISO
41369
10O
116
IOO
4843
21073
100
62
IOO
1311
24166
100
443
100
1O7O2
12083
100
106
IOO
1282
11321
100
410
IOO
4723
8149
100
112
IOO
910
MT
MT
HT
BT
«T
MT
rrt
-------
EXHIBIT 6-5. continued
AGGREGATE COMPLIANCE COSTS
WASTE STREAM AND MANAGEMENT PRACTICE
Comt of Waste Management Practice
: Sar.itarv Subtitle C Subtitle C Recycle
Waste Stream : Landfill Landfill Treatment Recycle On-Slte POTW Other Total
SPENT PLATING WASTES !
Current Mgmt. Dlstrib. <»> :
Compliance Cost (ave. »/MT) ;
NeM Mgmt. Distribution <»> :
Total Compliance Cost (»1OOO) 1
PESTICIDE WASHING AND RINSING :
BQUJTIONS :
Current Mgmt. Dlstrib. (X) ;
Compliance Cost (ave. »/MT) :
New Mgmt. Distribution (X) :
Total Compliance Cost (S1OOO) 1
I OMIT ABLE PAINT WASTES :
Current Mgmt. Dlstrib. <*> 1
Compliance Cost (ave. s/MT) 1
New Mgmt. Distribution <*> t
Total Compliance Cost («IOOO) !
1
TOP TEN WASTES 1
Tojal Compliance Cost <»1OOO) :
OTHER WASTES :
Current Mgmt. Distribution !
Compliance Cost (ave. C/MT) 1
Mam Mgmt. Distribution :
Total Compliance Cost (*1OOO> !
1
OU. WASTES i
Total Compliance Cost (S1OOO) 1
1
0
N/A
0
N/A
3
0
0
O
37
872
0
2337
13792
to
38O
0
370
16363
1
312
1
*0
4
422
*
128
a
399
a
233
4182
6
262
13
133
4336
22
612
22
1O39
0
N/A
0
N/A
0
N/A
37
N/A
4336
4
409
3
161
4317
7
312
7
282
16
422
16
312
23
383
23
703
16323
31
191
33
382
169O8
a
177
a
111
32
177
32
698
13
261
13
286
93O4
16
214
16
337
9641
62
O
62
O
12
0
13
O
2
0
2
O
O
22
O
22
0
0
0
N/A
0
N/A
13
177
13
173
13
399
13
379
3936
11
203
11
222
6178
7S&8
100
19O
IOO
1*93
7387
10O
199
IOO
1313
7306
100
342
100
3939
271163
33916
9633
loo
206
IOO
2027
281OOO
37943
MT
MT
NT
NT
NT
NT
The differences b«tws«n the total costs reoorted heir* and thos* in the ICF report are due to rounding.
OUKTEi ICF Incorporated, et. al.. Refirr-er.ee XX, Exhibit 4-16.
-------
Exhibit 6-6
PREDICTED CHANGES IN MANAGEMENT PRACTICES
FDR THE TEN LAR6EST-OUANTITY WASTE STREAMS
(Quantities of Waste in NT/Year)
Waste Streai
Spent Solvents
Acids and Alkalies
Photographic Wastes
Dry Cleaning Residues
Wastes Mith Silver
Ignitable Wastes
Formaldehyde Wastes
Spent Plating Wastes
Pesticide Washes/Rinses
Ignitable Paint Wastes
Sanitary Subt. C Subt. C Off-Site
Landfill Landfill Treatant Recycle
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
Current
Predicted
5,182 6,477
6,477
1,256 4,187
5,443
422 422
843
13,050 2,900
15,950
121
121
3,111 1,037
4,148
1,141
1,141
79
79
228 303
303
2,703 584
584
7,772 72,543
7,772 77,725
3,350
3,350
843
843
1,692
1,692
1,152 3,341
1,152 3,341
1,731 551
1,731 551
1,214
1,214
1,827
2,703 1,827
On-Site
Recycle
20,727
20,727
8,374
8,374
2,318
2.318
1,692
1,692
3,867
3,867
576
576
163
163
629
629
3,945
3,945
1,0%
1,096
PQTW
3,886
3,886
16,329
16,329
16,649
16,649
3,142
3,142
5,196
5,1%
1,343
1,843
6,519
6,519
4,878
4,878
910
1,138
146
146
Other
12,954
12,954
8,374
8,374
422
422
1,692
1,632
2,900
2,900
461
461
326
326
986
986
950
950
TOTffl
129,541
129,541
41,869
41.869
21,075
21.075
24,166
24,166
12,083
12,083
11,521
11,521
8,149
8,149
7,368
7,868
7,587
7,587
7,306
7,306
SOURCE: Derived froi ICF, Inc. et. al., Reference 26, Table 4-16. Estinates of quantities
include wastes fro* secondary industries not covered in the SQG Survey.
-------
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BENEFITS OF THE PROPOSED RULE AND ALTERNATIVES CHAPTER 7
INTRODUCTION
This chapter analyzes the changes in risk to human health
and the environment that are expected to result from responses to
the proposed regulation. These reductions in risk represent the
primary benefits of the proposed regulation.
The first section of this chapter discusses the risks posed
by various SQG practices. For each practice, we first describe
the nature of the risks presented by the practice, and then
describe how the proposed regulation might affect risks from the
practice.
The analysis of changes in risks resulting from the proposed
rule is subject to many of the same uncertainties that affect the
analysis of costs. In particular, the uncertainties about the
extent to which management practices will change limit the
reliability of estimated changes in risk. Where the analysis
ignores changes in practice (e.g., by understating reduction in
on-site treatment), both costs and reductions in risk are likely
to be understated. Reductions in risk would be overstated only
if the proposed rule discouraged a very safe on-site practice and
encouraged shifts to more risky off-site practices.
Many of the practices currently used by SQGs as well as
practices that may be employed in response to the proposed
regulation have not been well-characterized with respect to
risk. For some practices, information on the nature of releases
to the environment is fragmentary. For other practices, the
available information is more applicable to practices used by
larger generators than by SQGs. The latter is the case, for
7-1
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example, for burning of wastes as fuel, where the available
information on emissions has been developed primarily for large
industrial boilers and furnaces. These devices are likely to
differ from devices that might be used by SQGs burning wastes as
fuel in ways that may affect emissions. Because of these
limitations, lEc was not able to develop a comprehensive estimate
of changes in health risk resulting from the proposed rule. The
second section of this chapter presents quantitative estimates
for selected aspects of the changes in risk, based on the
predicted changes in practice discussed in below.
Most of this chapter focuses on the effects of different SQG
management practices on risk. The predicted changes in practice
do not vary for the different regulatory scenarios defined in
Chapter 2, since the alternatives differ primarily with respect
to recordkeeping and reporting requirements. The final section
of this chapter discusses the benefits of various administrative
requirements and describes how those benefits vary for different
regulatory alternatives.
DESCRIPTION OF RISIS FROM SQG PRACTICES
Releases to the environment via air, surface water, or
ground water may occur in treatment, disposal, storage, or
transportation. The proposed RCRA regulations are intended to
reduce risks both by changing the practices used by SQGs (for
example, by prohibiting disposal in municipal landfills) and by
encouraging greater care in practices that continue to be used
(e.g., transportation or storage).
Exhibit 3-5 in Chapter 3 provides an overview of estimated
quantities of SQG hazardous waste managed by treatment,
recycling, and various disposal methods. The exhibit indicates
that the following practices account for the largest portion of
current SQG waste management practices:
o on-site and off-site recycling (28,000 MT/year and
55,000 MT/year respectively);
o discharge to sewers (40,000 MT/year);
o off-site landfilling (both Subtitle C and solid
waste approximately 12,000 MT/year in each; and
7-2
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o miscellaneous forms of on-site treatment (21,000
MT/year).
Exhibit 7-1 presents an estimate of potential changes in
management practices, based on information provided by Pope-Reid
Associates (PRA) and supplemented by lEc. PRA provided estimates
of the quantities of waste shifted in all cases shown in Exhibit
7-1, except for shifts from municipal incinerators. lEc
estimated these shifts assuming that wastes were shifted to the
lowest-cost alternative among the options for which PRA reported
costs (see Chapter 6.)
Exhibit 7-1 considers only the ten largest-quantity targeted
waste streams reported by the primary industries included in the
SQG survey. Therefore, the total quantities shown here are less
than the quantities shown in Exhibit 6-6 (which provided the
basis for the cost analysis.) Further, the estimated quantities
shown in Exhibit 7-1 are based on estimated quantities by current
practice shown in Exhibit 3-5. These quantities were developed
by lEc by adjusting distributions by practice based on numbers of
generators to reflect expected differences in the average
-quantities managed by different methods. Finally, the
information provided by PRA included predicted shifts from
practices other than Subtitle D landfilling, whereas the cost
analysis was based on shifts only from Subtitle D landfills (as
shown in Exhibit 6-6.) Therefore, the quantities shown in
Exhibits 6-6 and 7-1 are not consistent. The estimates in
Exhibit 7-1 are intended to provide more detailed information
needed to evaluate potential changes in risk than was considered
in the cost analysis. Exhibit 7-2 shows the only the quantities
shifted from current practices to some new practice, based on the
estimates in Exhibit 7-1.
Even the more detailed information provided in Exhibit 7-1
is likely to understate changes in management practices to some
extent. The information provided by PRA assumed that disposal to
septic systems, on- and off-site treatment, and waste management
methods not specified in the survey responses (shown as "don't
know" in the exhibit) would continue after imposition of the
proposed rule. In fact, some or all of these practices
(accounting for 24 percent of the quantities included in Exhibit
7-1) might have to change.
Subject to these limitations in the estimates of likely
changes in practices, the rest of this section discusses how the
proposed rule might change risks from management of SQG wastes.
7-3
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Recycling
Recycling practices include "reclamation" (e.g. distillation
to recover solvents), burning or blending as fuel, "use/reuse"
without prior reclamation, and use/reuse involving application to
the land. As noted in Chapter 4, hazardous materials destined
for use or reuse (except where involving placement on the land)
are not defined as solid waste and hence are not regulated under
RCRA. Therefore, the proposed regulation will not affect
use/reuse, and these practices will not be discussed here.
Characteristic wastes other than spent materials are also not
defined as solid wastes (and hence are not regulated under
Subtitle C of RCRA) when reclaimed. However, an estimated 90
percent of all spent solvents are listed as hazardous under RCRA,
and hence would be regulated prior to reclamation. All hazardous
wastes are regulated when burned as fuels.
According to Exhibit 3-5 spent solvents account for most of
the reported recycling of wastes off-site by SQGs (almost 90
percent), and almost half of on-site recycling. Estimates
reported in Exhibit 7-1 suggest that recycling will increase as a
result of the proposed rule. Again, spent solvents account for
most of the predicted increase, with a smaller increase in
recycling of liquid ignitable wastes.
Solvent recycling generates still bottoms that require
management as hazardous waste. It is likely that off-site
recyclers currently handling SQG solvents are disposing of these
still bottoms in compliance with RCRA already, since these
facilities are likely to be handling solvents from LQGs as well.
On-site recyclers report "reuse", filtration, and disposal in an
on-site Subtitle C landfill as the major management practices for
solvent still bottoms. Solvent recycling may also result in air
emissions. However, because reclamation processes are not
subject to RCRA requirements under Parts 264 and 265, the
proposed rule will not cause any changes in these emissions per
gallon of waste recycled.
Burning of solvents and other wastes as fuel may result in
emissions of toxic organics or metals in stack gases. Analysis
performed for EPA in connection with the proposed regulations on
waste-as-fuel activities (Reference 30) suggests that most
industrial boilers and furnaces achieve high levels of
destruction or organics (99.99 percent or more). However, no
7-4
-------
evidence is available on the performance of smaller boilers and
other devices (such as space heaters) that may be used by SQGs to
burn wastes. Emissions of metals from burning will depend on the
metals content of the wastes being burned, and on the types of
air pollution controls in place (if any). The metal
manufacturing industry accounts for over 90 percent of the waste
burned as fuel on-site by SQGs. Solvents and acids and alkalies
account for 98 percent of the waste burned as fuel.
As noted in Chapter 4, most burning by SQGs is likely to be
prohibited under the Phase I waste-as-fuel regulations. Burning
by SQGs may be allowed under Phase II rules, however, under
conditions that ensure controls on risks from organics and metals
emissions. SQGs may continue to burn wastes as fuel if the Phase
II regulations eventually promulgated include an exemption for
burning of de minimis quantities. SQGs may also continue to send
wastes to other facilities for burning as fuels, and in fact
might expand this practice when the proposed regulation is
implemented, since this presents a relatively low-cost option for
wastes with high Btu content.
Other wastes which are frequently recycled include strong
acids and alkalies, wastes containing silver, pesticide
solutions, ignitable wastes, ignitable paint wastes, and waste
pesticides. These wastes are mostly reclaimed or "reused." The
information available from the survey on how these wastes are
reclaimed or reused is not adequate to allow any generalizations
about the risks from these practices, or about how these
practices might change as a result of the proposed rule.
Discharge to Sewers
As described in Chapter 4, discharge to sewers is regulated
under the Clean Water Act and this practice will not be directly
affected by the proposed regulation. According to Exhibit 3-5,
photographic wastes account for 30 percent of quantities
currently disposed to sewers, and numerous other SQG waste
streams are disposed in sewers in smaller quantities. Disposal to
POTWs is not predicted to increase significantly overall as a
result of the proposed rule, although some increase of disposal
to sewers is predicted for dry cleaning filtration residues and
for pesticide solutions (see Exhibit 7-1).
7-5
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Risks from discharge of hazardous wastes to POTWs arise from
(1) waste constituents that are not adequately treated at POTWs
and hence pass untreated to surface waters, (2) contamination of
POTW sludges, that may pose risks to ground water or air when
these sludges are disposed, usually by landfilling or
incineration (3) volatilization of toxic constituents from POTWs
and sewers leading to POTWs, and (4) damages to POTW operations.
Some hazardous constituents may be biodegrated or altered so that
they are no longer hazardous as a result of the POTW treatment.
These risks are the subject of an on-going EPA study, mandated by
Congress in the HSWA, which will determine whether changes in
regulations are required to control risks from indirect
discharges of hazardous wastes under the RCRA domestic sewage
exemption.
Recent analysis of the fate of SQG wastes in POTWs by Pope-
Reid Associates (Reference 44) suggests that removal efficiencies
for various hazardous constituents vary widely, depending on the
types of treatment facilities and other factors. PRA estimated
ranges for cumulative removals of 60 to 100 percent, with
removals generally lower (where no advanced treatment is used)
for aromatics, phthalates, inorganics and metals, and higher for
pesticides and aliphatics. Some of the removal results from
degradation for organics (between 0 and 50 percent) and some from
volatilization of organics (0 to 40 percent). Much of the
metals, inorganics and difficult-to-degrade organics (including
pesticides and PCBs) in the influent ends up in sludges, as does
some portions of the organic constituents. Thus, depending on
the constituent, negligible concentrations may end up in the
final effluent, but the removals via volatilization or sludges
may still pose hazards. To the extent that acids and alkalies
are neutralized prior to discharge, they may pose little risk and
may in fact no longer be hazardous wastes. Other wastes disposed
to sewers are likely to contain toxic constituents that may
present risks when managed in this way.
Disposal in Landfills
Wastes disposed in landfills present risks to ground water
and nearby surface waters from potential leaks. Land disposal
may also result in toxic air emissions from volatilization of
wastes and from fugitive emissions.
7-6
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Exhibit 3-5 suggests that landfilling of SQG wastes is
common currently, and is evenly distributed between Subtitle C
and Subtitle D landfills. As a result of the proposed rule,
disposal in sanitary landfills will not longer be allowed.
Disposal in Subtitle C landfills is expected to increase by
almost 50 percent, as wastes are diverted from other practices to
comply with the proposed rule (see Exhibit 7-1.)
Risks from the two types of landfills are a complex function
of types of waste, landfill design, location, and landfill
management practices. For example, the concentration of toxic
constituents in landfill leachate depends on (1) the
concentration of the constituent in the hazardous waste, (2) the
ratio of hazardous waste to non-hazardous waste in the landfill,
(3) the infiltration rate, (4) the density of the waste in the
landfill, (5) the depth of the landfill, and (6) the distribution
of the hazardous waste in the landfill. The effect of leachate
production on ground water quality is determined in turn by the
design of the landfill, including presence of liners, as well as
the likelihood of detection of leaks and corrective action.
Major potential differences between solid waste and Subtitle
C landfills result from (1) the Subtitle C design requirements
for liners, intended to control migration of leachate, (2)
restrictions on the disposal of liquid (hazardous and non-
hazardous) wastes in Subtitle C landfills that might increase the
production of leachate, and (3) Subtitle C requirements for
ground water monitoring, leachate collection, and corrective
action in the event of leaks. Further, operating practices may
differ at the two types of landfill. Sanitary landfills often use
an "area fill" procedure, that involves spreading of wastes over
a large area and compacting to reduce volume. Sanitary landfills
generally cover active areas daily, but substantial release of
volatile wastes to the air can occur during spreading and
compacting. Hazardous wastes pose a particular hazard when
loaded and unloaded during transit and when drums are crushed
during compacting, due to explosions, spraying of liquid wastes,
and other such releases. Toxic constituents in hazardous wastes
may also inhibit the normal biological activity in a sanitary
landfill and thus lengthen the time it takes the landfill to
stabilize. Leakage of wastes is controlled to some extent by
the absorptive capacity of the non-hazardous wastes in sanitary
landfills. The absorptive capacity of non-hazardous wastes
depends on the extent to which wastes are screened and shredded
7-7
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(since unshredded wastes leave large gaps in the landfill through
which hazardous wastes may migrate quickly), as well as on the
mobility of the hazardous wastes and the climate.
Unfortunately, direct evidence on the contribution of SQG
wastes to risks from sanitary landfills is limited. The
remainder of this section describes some of the evidence on
factors that are likely to influence risks from sanitary landfill
disposal of SQG wastes.
lEc contacted a number of sanitary landfill operators to
determine how these facilities are likely to handle wastes known
or suspected to be hazardous. In virtually all cases, those
contacted indicated that they do not knowingly accept hazardous
wastes. When identified, these wastes are generally returned to
transporters. The widespread reluctance to handle hazardous
wastes at sanitary landfills is due to concerns about potential
liability for clean-up should releases occur. On the other hand,
most operators ssaid that they are able to perform only
rudimentary screening to prevent the disposal of hazardous
wastes. Only obviously-suspicious containers (drums and hospital
lab packs) are likely to be spotted and returned. Most operators
say that they would not be able to detect hazardous wastes co-
disposed with other trash. Therefore, wastes sent to sanitary
landfills in dumpsters are likely to escape detection.
A recent study by the Association of Bay Area Governments
(ABAC) attempted to assess problems resulting from the disposal
of hazardous wastes with municipal waste streams (Reference 6).
The study reported primarily anecdotal evidence of problems
ranging from minor burns and nausea to blindness, respiratory
problems and unknown chronic effects. The study summarizes
reports of problems with hazardous waste disposal reported by
members of the National Solid Waste Management Association
(NSWMA). (Note that the small quantities in question may have
been disposed by household or non-complying LQGs, as well as by
SQGs.) The study sstated that incidents were generally identified
by attentive operators (prior to releases) or by injuries to
workers or outbreaks of fires. As summarized by the study, half
of the incidents reported to NSWMA involved fires or explosions,
over half of the reported incidents occurred during collection
and handling, and nearly half involved less than 100 kg.
lEc reviewed the individual incidents reported to NSWMA, as
summarized in the ABAC study. The following shows the
distribution and number of incidents by type of incident:
7-8
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at landfill in collection
explosions/fires 5 12
fumes/leaks/spills/spraying 2 11
detected prior to release 4 5
The following types of wastes were involved in the incidents:
paints, thinners, solvents or furniture finishers (6 incidents),
elemental sodium (2 incidents), resins (3 incidents), acids and
caustics (13 incidents), pool chemicals (4 incidents), pesticides
(2 incidents) and other chemicals (4 incidents).
It is difficult to determine how much disposal of SQG wastes
in sanitary landfills might contribute to ground water
contamination, because SQG wastes represent an unknown portion of
the total quantities of hazardous waste disposed in landfills
(which may receive wastes from households and other sources.)
Limited information cited by the ABAC study suggests that the
portion of wastes disposed in municipal landfills represented by
hazardous wastes from all sources is very small one study
cited in that report estimated a ratio of 740 units of non-
hazardous waste to 1 unit of hazardous waste at a particular
landfill accepting mixed household and industrial waste.
Direct evidence on risks to ground water from disposal of
hazardous wastes in sanitary landfills is limited and in some
case contradictory. Tests of solid waste landfill leachate
quantity and quality, conducted in 1971 using laboratory
simulations and field tests (Reference 17) suggested that
leachate is generated during compaction and placement of wastes
in the landfill, and also results from net infiltration of
water. (These tests took into account the absorptive capacity of
non-hazardous wastes.) Significant quantities of leachate were
produced in a simulated landfill approximately 430 days after
adding water to the facility. Simulations of leachate production
in different climates suggested that time to first appearance of
leachate varied from 15 months to 145 months wherever there was
some net infiltration (and "infinity" where weather conditions
resulted in no net infiltration to landfills).
A more recent laboratory study on the co-disposal of
municipal and industrial wastes in sanitary landfills (Reference
36) suggested that the quantity of leachate produced does not
7-9
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vary significantly between cells containing municipal waste only
and cells containing a mixture of municipal and industrial wastes
(assuming the same rate of infiltration). The time to first
appearance of leachate also does not vary significantly between
the two types of coll; for both, first leachate appeared after
about 8 months. However, the quality of the leachate differed
significantly, even where the industrial wastes had been
solidified. The presence of industrial wastes increased the pH
of leachates, and in some cases affected biological activity in
the municipal waste. Heavy metals did not appear in the
leachates in appreciable amounts. However, the findings
contradicted the results of some earlier studies, and it is
possible that the study period was too short to observe leaching
of metals.
The available evidence suggests that risks to ground water
from landfill disposal of SQG wastes may vary widely, then,
depending on the type of waste and the type of facility involved.
Current RCRA requirements for Subtitle C landfills are likely to
reduce or delay contamination of ground water, however, because
of more stringent requirements for liners, monitoring for leaks
and corrective actions where leaks are detected. There are
currently no regulations in effect specifically designed to
control air emissions from Subtitle C landfills and other
Subtitle C facilities, although the Agency will be proposing such
regulations in the future. It is nonetheless likely that
volatilization from Subtitle C landfills will be less extensive
than from Subtitle D facilities for two reasons. First,
containerized wastes are less likely to be spilled or released
prior to being cov.ered at Subtitle C landfills, which are
specifically operated for hazardous wastes. Second, prohibitions
on landfilling of liquid wastes without solidification may reduce
volatilization, as well as the generation of leachate.
Treatment
According to Exhibit 3-5, on-site treatment is used by SQGs
for a relatively small percentage (11 percent) of all SQG wastes,
but includes a wide variety of activities. (See Appendix C for a
detailed description of treatment practices and quantities.) The
most common on-site treatment activities include neutralization,
evaporation, and filtration. Strong acids and alkalies and
solvents account for the greatest portion (39 percent) of the
wastes treated ori-site. Off-site treatment is not a common
practice. No changes are predicted in Exhibit 7-1 for on-site
7-10
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treatment. Off-site treatment is predicted to increase primarily
due to increases in treatment of spent plating wastes, ignitable
paint wastes, and acids and alkalies.
It is difficult to generalize about risks from current or
predicted treatment of SQG wastes, because the practices are so
diverse and because current practices are not described in detail
in the survey. Under the proposed regulations, treatment of SQG
wastes would be subject to specific Part 264 and 265 requirements
design and operating requirements for that treatment which occurs
in surface impoundments and incinerators. Additional general
operating requirements and performance standards will apply to
all thermal, chemical, physical and biological treatment.
Currently, only the regulations on incineration impose direct
limits on air emissions from treatment facilities (requiring
99.99 percent destruction or removal most of hazardous organic
constituents in stack gases). (Controls on air emissions from
TSDFs are currently being developed by EPA, and presumably would
apply to facilities managing SQG hazardous wastes.) No
performance requirements are currently imposed with respect to
the quality of solid residuals from any type of treatment
(although such standards may be developed by EPA in connection
with future restrictions on the land disposal of hazardous
wastes.)
Storage
As reported in Chapter 3, SQGs use a variety of methods for
storing wastes prior to treatment or disposal. The most common
method used is storage in closed metal drums, but other practices
include storage in piles, surface impoundments, tanks, and other
types of containers (open and closed drums, pails and garbage
cans) .
Storage of SQG wastes may result in spills during handling
or due to container failure. Such spills may pose threats to
ground water if not contained and cleaned-up. Depending on the
types of wastes involved, spills may also pose health risks due
to volatilization of toxic gases. Explosions and fires may
result from improper combinations of wastes in storage or
improper handling. All of these "sudden" incidents are likely to
be detected quickly. These incidents pose immediate threats to
the surrounding population. Since (according to the SQG Survey)
most SQGs are located in urban areas, large numbers of people may
potentially be exposed to releases from spills at SQG facilities.
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Generators already have incentives to prevent explosions and
fires, to avoid damages to their own property and employees and
to avoid liabilities from readily-detected releases that harm
neighbors. Further, OSHA regulations governing occupational
exposures may encourage careful handling and storage practices
where hazardous materials are being used. SQGs may be less
aware, however, of the hazards presented by wastes when spills
are not cleaned up, and may have less incentive to avoid such
incidents or to provide for effective clean-up should a spill
occur.
Storage of !3QG wastes may also result in "non-sudden"
releases, including accidental leaks and continual emissions in
the form of fugitive emissions or volatilization. These releases
are less likely to be detected immediately, and may be less
readily observed and traced to the responsible party. Leaks,
like spills, pose threats to ground water or surface water, and
possibly through volatilization (although the surface area
involved in a leak is likely to be less than in a spill,
involving less change of significant volatilization). In
addition, open piles and other unenclosed storage facilities may
result in fugitive emissions, and certain types of wastes may
volatilize from feicilities or containers that are not properly
enclosed and sealed. Some emissions from storage of volatile
wastes are inevitable, since containers are opened when wastes
are transferred and since tanks frequently leak around valves and
fittings. However,. releases of volatile compounds will obviously
be greater from open containers, piles and impoundments.
Risks from storage of hazardous wastes are likely to vary
with the types of storage containers used, the total quantities
in storage at any one time (large quantities increasing the
number of points at which spills or other releases may occur and
resulting in greater total exposure when releases occur), the
length of the storage period (with longer periods resulting in
more leaks and possibly more handling of containers, increasing
the changes of spills), and the types of waste stored. With use
of proper containers, frequent inspection for leaks, and care in
handling, it is likely that most releases from storage (other
than volatilization from surface impoundments, routine emissions
from tank valves and seals, and air emissions during transfers of
wastes) can be avoided.
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The proposed regulations are likely to reduce risks from
storage of SQG wastes in several ways. First, for both short-term
and permitted storage, SQGs would be required to label containers
of hazardous wastes, ensuring that all who handle these wastes in
storage are aware of potential hazards. Second, the required
notification and labelling of shipments may increase local
awareness that hazardous wastes are being handled at a SQG's
site, potentially resulting in greater outside scrutiny of SQG
storage practices. These two effects may indirectly encourage
more careful handling of SQG wastes in storage. Third, the
regulations will require periodic inspections of storage areas.
Fourth, SQGs will be required to maintain storage containers and
tanks in good condition, and to keep containers closed except
when transferring wastes. Finally, all SQGs storing wastes on-
site will have to train their personnel in the proper handling of
hazardous wastes and in responses to spills and other releases,
and will be subject to performance standards regarding emergency
preparedness and prevention and maintenance of adequate emergency
equipment to allow effective responses to release incidents.
Permitted storage facilities will be subject to additional
requirements. SQGs will have to protect piles from wind, and
comply with Subtitle C controls on air emissions from surface
impoundments and other facilities (when issued). The regulations
will also impose requirements designed to contain spills
(secondary containment for waste piles and containers and tanks,
and liners for surface impoundments). Finally, permitted
facilities will be required to provide more extensive
documentation regarding responses to fires or explosions
(contingency planning and required emergency equipment),
personnel training, and inspection plans and results.
In practice, few SQGs are likely to incur the costs of
complying with the storage facility requirements by storing in
piles or surface impoundments, or for longer than the allowed 180
or 270 days in tanks or containers. Therefore, the risks
associated with storage on the land and with storage for longer
periods are likely to be avoided. Additional reductions in risk
will result from more careful management of storage in containers
and tanks than may occur in the absence of regulation. SQGs1 use
of storage may increase overall, however, if longer storage is
required to compile economic shipment sizes (due to longer
shipment distances to off-site facilities and greater use of off-
site facilities see Chapter 5). For example, SQGs currently
storing wastes in dumpsters prior to pick-up with regular weekly
waste collections will probably have to store wastes for longer
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periods under the proposed regulation. This increase in the
total quantities in storage at SQG establishments may offset the
reductions in risks from more careful storage practices to some
extent.-
Because potential changes in storage practices were not
quantified in detail in this RIA, however, and because the risks
from unregulated storage have not been well-characterized
quantitatively, IE« did not estimate new changes in risk from SQG
storage. It is difficult to judge without more detailed analysis
how the proposed rule will affect aggregate risks from storage.
Potential increases in quantities stored for some period may be
significant. Exhibit 3-10 suggests that as much as 60 percent of
the wastes managed on-site, and 26 percent of the wastes managed
off-site, are not currently stored prior to treatment or
disposal. Storage is likely to increase for these wastes,
although the increase will exclude wastes continuing to be
discharged to sewers (42 percent of the wastes currently managed
on-site.) Therefore, an estimate of the maximum increase in
quantities being stored for some period for the first time is
59,000 MT/year (518 percent of 47,000 MT/year not stored and
managed on-site plus 32,000 MY/year not stored and managed off-
site from Exhibit 3-10.) Further, wastes currently being
stored for less than 180 days may be stored for somewhat longer
periods by some SQGs to compile more economic shipment loads.
These two factors will tend to increase the quantities stored and
the average length of storage. On the other hand, 11,000 MY/year
of wastes currently being stored for more than 180 days are
likely to be shipped, treated or disposed more quickly as a
result of the proposed rule. Exhibit 3-11 also suggests that
storage methods will be upgraded for 54,000 MT/year (those
quantities currently stored in bulk waste containers, pails of
garbage cans, piles;, open drums, and surface impoundments.) It is
not currently possible to predict the net effect of these changes
on risks from storage of SQG wastes.
Transportation
As reported in Chapter 3, most SQG transportation occurs in
trucks and is most likely to be in drums. Drums may be
transported either in open stake trucks or in enclosed vans (the
regulations do net specify types of truck that may be used).
Releases from transport may occur at terminals (either from
storage or from loading, unloading and other handling), during
pick-ups (from handling during loading), and en route, as a
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result of accidents. Risk of releases in transit are a function
of the distance shipped, as well as the type of truck, the type
of roadway, and the quantity and type of waste. Risk of releases
at terminals and during pick-ups is a function of types of
wastes, numbers of handlings and handling practices. The risks
from either type of release are similar to those from releases in
storage: risk to ground water or surface water from spills,
explosions and fires (with associated toxic gases in some cases)
and possible volatilization from spills. Releases may also
result from combinations of incompatible wastes, use of
inappropriate containers for wastes, or use of containers in poor
condition.
A major determinant of risk from transportation is the
extent to which transporters are aware of the hazardous nature of
cargoes. As discussed previously in this chapter, a number of
cases have been reported in which hazardous wastes or materials
have been discarded with trash and have caused damages when
loaded by refuse collectors or unloaded by workers at landfills.
Handling of such materials has caused rashes, chemical burns,
nausea, respiratory problems, eye irritation, and blindness.
(See Reference 6 for a summary of reported incidents.) ' More
generally, the methods used to store and handle wastes in transit
are likely to improve if transporters are adequately notified
about the hazardous nature of the cargoes.
The proposed regulations will reduce risks from
transportation in four ways. First, they will require labelling,
placarding and manifesting of all shipments, which should ensure
that original- transporters, subsequent transporters and off-site
recipients of wastes are aware of potential hazards. Second,
they will require use of a transporter subject to DOT
regulations, who is required to comply with a number of
regulations that reduce the likelihood of accidents (driver
training, condition of vehicles, etc.). Third, the proposed
regulations will require prompt reporting and response to any
release during transportation, thereby reducing damages where
releases do occur. Finally, the regulations will require
shipment in containers that meet DOT requirements, precluding
such practices as transport in garbage trucks.
Again, reductions in risk due to safer transportation
practices may be offset somewhat by increases in the total amount
of transportation of SQG wastes. Some SQGs currently managing
their wastes on-site (and hence not transporting wastes) are
predicted to switch to off-site management. Further, the
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distance to Subtitle C facilities will in many cases be greater
than to off-site facilities currently disposing of SQG wastes
(e.g., solid waste landfills and incinerators). Potential
changes in risk from transportation are discussed further in the
next section.
ESTIMATES OF CHANGES IN RISK
This section presents estimates of some types of changes in
risks that are likely to result from the proposed rule. Changes
in risk are expected to result from several features of the
proposed regulations.
First, the regulations themselves, along with the education
program being planned for SQGs by EPA, will generally increase
SQGs1 awareness of the hazardous nature of their wastes and
thereby result in more careful handling of these wastes. The
proposed notification, labelling, placarding and manifest
requirements will also alert transporters, off-site disposal
facilities and the general public to the presence of hazardous
waste. This increased general awareness is likely to put
pressure on SQGs to manage their wastes properly, and to increase
SQGs1 effective legal liabilities if they do not (by increasing
the probability that legal sanctions will be imposed on
violators). In addition, parties other than SQGs (transporters
and off-site facilities) will be better able to identify SQG
wastes as being hazardous, and to manage those wastes
appropriately. The requirements will also put SQGs in contact
with transporters and off-site TSDFs, who are more likely than
the SQGs themselves to be familiar with proper waste handling
methods, and who represent an important education resource for
SQGs. The effects resulting from changes in "general awareness"
are difficult to predict and quantify, but could result in a
significant reduction in risks from transportation and handling
of SQG wastes.
Second, the proposed regulation includes mechanisms that
support implementation and enforcement of other requirements.
For example, the notification requirement provides Federal and
State officials with a means of identifying SQGs for potential
inspection or enforcement actions. Requiring off-site facilities
to file biennial reports that include shipments from SQGs will
also provide States with information on the extent of compliance
with the proposed regulations. Again, the effects of these
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mechanisms on ultimate risks from SQG practices are difficult to
assess quantitatively, but it is likely that without such
mechanisms, non-compliance would be widespread.
Third, the proposed regulations will require specific
changes in management practices that will reduce risks from SQG
wastes directly. These changes in practice and the nature of
potential changes in risk were described in the previous section.
The remainder of this section estimates two sources of
potential changes in health risk resulting from the proposed
rule: changes in the type of disposal used and changes in
transportation costs.
Effects of Changes in Practices
on Risks from SQG Wastes Management
As noted above, a relatively small portion of SQG wastes are
predicted to be managed by different methods as a result of the
proposed rule (although the extent of the predicted shifts in
practices is likely to be understated in this report). The major
shifts involve discontinued use of Subtitle D landfills,
resulting in increased disposal in Subtitle C landfills, off-site
recycling, off-site treatment and (to a lesser extent) disposal
to POTWs. This section discusses the effects of the predicted
shifts (other than effects resulting from changes in the amount
of transportation) on risks from SQG wastes.
It was not possible within the scope of this study to
evaluate risks from all post-regulation practices. In
particular, we were not able to evaluate risks from increased
off-site treatment (primarily of ignitable paint wastes) and
increased off-site recycling (of spent solvents and liquid
ignitable wastes.) However, work performed by ICF, Inc. and
Pope-Reid Associates (PRA) for EPA provides some insights into
the health risk effects of decreased Subtitle D landfill disposal
and increased Subtitle C and POTW disposal.
To illustrate the effects of shifts from Subtitle D
landfills to Subtitle C landfills and to POTWs, PRA specified
characteristics of "composite" SQG wastes, that contain a number
of constituents commonly found in SQG wastes currently disposed
in Subtitle D landfills or discharged to POTWs. PRA then
characterized quantities and constituents for composite waste
streams that reflect the wastes predicted to shift to Subtitle C
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landfills and to POTWs. (Exhibit 7-3 shows the concentrations
and quantities of waste assumed in this analysis.) Next, PRA
predicted releases; of toxic constituents to ground water and to
air from typical POTWs and Subtitle D and C landfills from
management of these composite wastes. (The assumed
characteristics oi: the typical facilities are summarized in
Exhibit 7-4.) ICF then estimated health risks (cancer cases and
non-carcinogenic Ccises) per facility and in aggregate, based on
these releases. ICF did not estimate aggregate risks for POTW
disposal, because they lacked information on the number and
distribution of POTWs receiving wastes from SQGs. To illustrate
potential effects on risk from increased disposal to POTWs, lEc
made some simplifying assumptions to calculate aggregate risks.
Several limitations in the methodology and assumptions used
are important in evaluating the results of the analysis performed
for EPA. The analysis uses EPA's Liner Location Model (Reference
29) to estimate resleases, exposures, and risks. This model
evaluates releases and risks from various types of Subtitle C
land disposal facilities, and input assumptions about landfill
design and wastes were adjusted to reflect conditions
representative of Subtitle D landfills. The modified waste and
design characteristics included waste:fill ratios, waste moisture
content, and waste densities. For Subtitle D landfills, no liner
was assumed, while Subtitle C facilities were assumed to have
clay and synthetic liners in place. This assumed facility designs
will not provide em accurate estimate of risks from all landfill
facilities, since there is significant variation within the two
types of landfills in design and operating characteristics.
While For example, many states require that Subtitle D landfills
in fact be lined, and for such facilities the proxy used could
overstate risks from Subtitle D facilities.
In addition, other assumed facility and waste
characteristics may not be accurate reflections of actual
conditions. For example, use of a composite waste reflects the
assumption that toxic constituents contained in SQG wastes are
evenly distributed across all facilities, whereas in fact
different facilities will receive different mixes of SQG wastes.
Facilities will eilso vary widely in the size of the exposed
population, quantities of SQG wastes handled, the types of
treatment performed (at POTWs), and environmental
characteristics that affect releases. Estimates of non-
carcinogenic health effects are particularly sensitive to the
assumed distribution of wastes among facilities, since the total
quantity disposed per facility has an important effect wherever
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the relevant health effects exhibit a threshold (that is, where
exposure levels must exceed a threshold level before any adverse
effect on health is expected.) (Cancer risks are commonly assumed
not to have a threshold, and to increase linearly with dose at
low levels of concentration. Hence the estimated number of cases
per facility is more closely related to the quantity of waste
disposed in each facility.) The analysis described here is based
on simple assumptions about the number of POTWs and Subtitle C
and D landfills receiving SQG hazardous wastes, since the SQG
survey results reported only number of generators sending wastes
to these facilities, and not numbers of facilities receiving SQG
wastes. Therefore, the aggregate estimates provided here are
sensitive to the assumptions about numbers of facilities
receiving SQG wastes and the quantities of waste received.
Finally, the analysis assumes that POTW sludges are sent to
sanitary landfills, rather than being incinerated or disposed in
Subtitle C landfills. If the sludges exhibited a characteristic
of hazardous wastes (e.g. EP toxicity), they would in fact have
to be managed at Subtitle C facilities.
Given the methodology used, then, the results reflect the
effects of (1) shifts from the use of unlined Subtitle D
facilities to Subtitle C landfills, (2) dispersed disposal of
hazardous wastes in numerous landfills (as is likely the case
with Subtitle D landfills) vs. more concentrated disposal in a
smaller number of landfills (as will be the case where SQG wastes
are shifted to Subtitle C landfills), and (3) some changes in the
composition of wastes going to POTWs and landfills. The aggregate
results also reflect simple assumptions about the numbers of
facilities receiving SQG wastes, the average quantities disposed
at each facility, and the numbers of people exposed to various
media at each facility. Finally, the analysis does not consider
the relative frequency of spills, explosions, or other such
sudden event, which could constitute a significant source of risk
from some types of hazardous wastes in Subtitle D landfills.
While EPA recognizes that the analysis will not estimate risks
accurately for any particular facility, then, the analysis does
provide a useful illustration of the potential effects of the
proposed rule on health risks.
The analysis considered risks from four sources:
o groundwater contamination from direct disposal in
Subtitle D landfills;
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o groundwater contamination from sanitary landfill
disposal of sludge from POTW treatment;
o groundwater contamination from POTW treatment;
o discharge to surface waters of effluent from
POTWs; and
o volitilization from POTW impoundments.
The results showed no risk from leaching from POTWs
attributable to treatment of the assumed SQG waste. It was
assumed that all surface water discharges would be diluted prior
to any consumption downstream, and that any public water supply
withdrawals would include treatment rendering health risks
negligible. Leaching from various stages of a POTW, when diluted
by rivers with two different flow sizes (10**11 and 10**14
liters/year), resulted in not hazardous constituents from SQG
wastes in levels of concern. (Acetone concentrations in the worst
case were as high as 1.25 ppb. All other constituents were
present in the river in concentrations of less than 1.0 ppb.)
Furthermore, it was assumed that all potentially-contaminated
groundwaters near POTWs would discharge directly to a surface
water (i.e. that there are no ground water wells between the POTW
and the surface water.) Therefore, the predicted risks from POTW
disposal included only risks from volitalization and risks from
sanitary landfilling of POTW sludges.
Exhibit 7-5 summarizes the initial results of the analysis.
That exhibit presents estimates of two types of risk number of
cases of cancer (per facility and aggregate) and number of cases
for non-carcinogenic effects (again, per facility and aggregate).
The aggregate risks from disposal to Subtitle D landfills
were calculated assuming that some SQGs wastes go to all Subtitle
D landfills (of which ICF estimates there are 12,930). Aggregate
risks from Subtitle C landfills assume disposal of some SQG
wastes in each of 318 landfills. The weighted average risks per
landfill facility take into account the estimated distribution of
those facilities by types of climate and types of groundwater
environments, as well as the distribution of landfills by size
(for Subtitle D landfills) and the assumed exposed populations.
These assumptions are described in ICF (Reference 24).
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ICF provided initial results for volatilization from POTW
impoundments and groundwater contamination from sanitary landfill
disposal of POTW sludges. These results reported only the
maximum lifetime risk to a single exposed individual .5 km
downwind from each facility. For volatilization risks, the
calculations provide the high end of the range of risks to
individuals located 0.5 km from the facility. These results
ought to represent a conservative estimate of individual risks
from air exposures for calculating aggregate risks. For risks
via groundwater, ICF provided risks for 27 different combinations
of climate and groundwater flow field types, and for two facility
sizes.
lEc calculated the estimated aggregate risks from POTW
disposal shown in Exhibit 7-5, assuming the following:
o Sanitary landfills receiving sludges from POTWs
are distributed among climate and groundwater
scenarios in the same proportions as estimated by
PRA and ICF for all Subtitle D landfills.
o There are 76 POTWs receiving SQG wastes at the
average quantities estimated by PRA in the
baseline. This is the number of POTWs estimated
by PRA to be 50 mg/d or larger, based on a 1978
EPA Needs Survey. Ninety percent of these were
assumed to be 50 mg/d facilities, and ten percent
were assumed to be 250 mg/d facilities.
o Each POTW was assumed to send sludges to a single
Subtitle D landfill.
o lEc simulated the effects of increased disposal to
POTWs by assuming that additional POTWs begin
receiving SQG wastes at the same rate assumed by
PRA for POTWs currently receiving SQG wastes. PRA
estimated that there would be an increase of
quantities disposed to POTWs of approximately 20
percent. lEc therefore assumed that the number of
POTWs receiving SQG wastes would increase by 20
percent as well. The same assumptions about
climate types, groundwater types, and size
distributions were applied for these additional
facilities.
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o lEc assumed that 200 people are exposed to the
concentrations estimated by ICF for volatilization
from each POTW impoundment, and 200 (different)
people are exposed to groundwater contamination
from each sanitary landfill disposing of POTW
sludges.
The results in Exhibit 7-5 show a decrease in estimated
cancer cases of 255 over a 400 year analysis period due to the
decrease in Subtitle 0 disposal. Individual cancer risks are
higher on average at Subtitle C facilities (for the portion of
wastes shifted from Subtitle D to Subtitle C landfills), because
the average quantities of SQG wastes disposed at the Subtitle C
landfills are higher. However, the effect of the shift induced
by the proposed rule is to concentrate landfill disposal in
fewer, better designed facilities. Therefore, given no
difference in the numbers of people exposed at the two types of
facilities, aggregate cancer risks from land disposal are
predicted to decrease. The decrease is offset only slightly due
to increased disposal to POTWs. Because PRA estimates only
minimal changes in the concentrations of carcinogens in wastes
disposed to POTWs, average cancer cases per facility do not
increase. Therefore, the increase in risk is attributable
entirely to the assumed increase in the number of POTWs receiving
SQG wastes. Cancer risks from POTWs are dominated by risks from
landfill disposal of sludges aggregate risks from
volatilization are negligible. The estimated risks from
volatilization may be understated, if more than 200 people are
exposed to significant concentrations at each facility. However,
lEc calculated that almost 11,000 people at each POTW would have
to be subject to the conservatively-estimated risks reported by
ICF to result in one cancer case overall.
Exhibit 7-5 also reports results for non-cancer health
effects. As noted above, these results are more sensitive to
assumptions about the quantities of waste disposed per facility
than the estimates for cancer effects. In addition, ICF states
that the projected non-cancer incidents are primarily due to
exposures to methanol, and that the non-lethal effects are likely
to be severe recurrent headaches which stop upon removal of the
exposure. The dose-response relationship used for all non-
carcinogens in the Liner Location Model, including methanol, are
currently subject to review, to evaluate their applicability to
human health effects. Therefore, the results reported here
should be viewed as preliminary.
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Given the assumptions about quantities disposed per facility
and the health effects of the non-carcinogens, the results
suggest that non-cancer incidents would increase under the
proposed rule by 2369 incidents over the analysis period. This
result reflects the effects of more concentrated disposal in
fewer landfill facilities, as well as an increase in the number
of landfills accepting POTW sludges from treatment of SQG wastes.
Disposal of the hypothesized SQG wastes at numerous Subtitle D
facilities was found to exceed thresholds for non-cancer effects
only rarely. These thresholds are exceeded more often under the
assumed conditions at Subtitle C landfills, due to the larger
average quantities disposed at these facilities. The analysis of
risks from POTW sludges in sanitary landfills assumes no increase
in the average quantity disposed per landfill, and thus increased
risks are due solely to the larger number of POTWs receiving SQG
wastes. If the proposed rule resulted in larger quantities
disposed in any particular POTW, these results could understate
the increases in non-cancer incidents.
While the aggregate results shown in Exhibit 7-5 are subject
to a number of potential errors, the results do illustrate the
following characteristics of potential changes in risk from the
expected changes in practice. First, cancer risks are likely to
decline, due to the reduced exposure resulting from disposal at
fewer, better controlled Subtitle C facilities. The predicted
exposures and cancer risks are also delayed (i.e. occur at a
later time) as a result of the shift to lined Subtitle C
facilities. Cancer risks from increased disposal of POTW sludges
do not outweigh these reduced risks, under the assumed
conditions.
Results for non-cancer effects that exhibit a threshold are
less clear. Reductions in the number of Subtitle D landfills
receiving SQG wastes will result in reduced population exposures,
but the concentrations to which people are exposed at these
facilities may be too low to pose any risk of health effects.
Shifting SQG wastes containing threshold constituents to a
smaller number of Subtitle C facilities may result in exposures
above threshold levels following facility failure, and therefore
increase non-cancer incidents overall. Finally, it appears that
risks from POTW disposal are dominated by risks from the disposal
of sludges in sanitary landfills risks from volatilization in
POTW impoundments are negligible both before and after the
effects of the proposed rule.
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As indicated above, these conclusions are sensitive to
assumptions about the numbers of people exposed at each facility
and the average quantities disposed at each facility, and the
composition of the SQG wastes. More information would be needed
about the characteristics of SQG wastes and the locations in
which these wastes are disposed to provide more refined estimates
of changes in aggregate risks.
Changes in Risk from Transportation
The proposed rule results in an increase in the
transportation of SQG wastes, both because wastes currently going
to offsite Subtitle D facilities are likely to be sent in many
cases to more distant Subtitle C facilities, and because some
wastes previously managed on-site will be sent off-site for the
first time. The proposed rule is also likely to result in safer
transportation of SQG wastes than would otherwise occur. This
section considers^ the net effect of increase use of
transportation and safer transportation practices on risks.
The requirements that wastes be labelled and that shipments
be manifested are expected to increase transporters' and
destination facilities' ability to manage wastes properly. Of the
targeted wastes reported shipped off-site in the SQG Survey,
12,000 MT/year (10 percent of the total) is shipped by generators
who do not report notifying the transporter about the hazardous
nature of the wastes. At a minimum, the information provided to
transporters and off-site facilities is likely to be more
complete and accurate as a result of the proposed regulations for
the these and other wastes (together totalling 78,700 MT/year)
not already accompanied by an EPA manifest or DOT shipping papers
(estimated by subtracting quantities accompanied by EPA manifests
or DOT shipping papers from the total quantities shipped off-
site, from Exhibit 3-13) .
lEc has developed rough estimates of average shipment
distances for different types of off-site management in different
regions (see Chapter 5). These estimates were used, in
conjunction with predicted practices from Chapter 6 and with
rough estimates of typical shipment distances to off-site
facilities currently used by SQGs (e.g., sanitary landfills), to
estimate potential increases in total shipment miles.
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Exhibit 7-6 shows the expected increase in ton-miles of
transportation resulting from the predicted changes in practices.
This calculation assumes distances of 25 miles to Subtitle D
facilities, 200 miles to Subtitle C landfills and incinerators,
and 100 miles to off-site recycling and treatment facilities.
This exhibit shows an increase of 1.18 million ton-miles
predicted to result from the proposed rule. Using the same
assumptions about distances to facilities, current SQG practices
involve 8.56 million ton-miles of transportation per year
(excluding wastes for which destinations are unknown). Thus,
predicted changes in practices result in a 13 percent increase in
the transportation of SQG wastes. (If it is assumed that wastes
shipped off-site to unknown destinations are in fact shipped to
non-compliant facilities (non-Subtitle C or recycling) at an
average distance of 25 miles, then the predicted increases in
transportation represent a 14 percent increase over baseline
transportation.) The increased transportation is entirely a
function of the assumed increases in distances to allowable
facilities. Total quantities shipped off-site decrease slightly
(due to some increase in POTW disposal when wastes are no longer
shipped to Subtitle D facilities).
The net effect of predicted changes in transportation
practices on risks depend on the reductions in risk resulting
from safer transportation practices (including the effects of
greater transporter awareness of the types of wastes received)
and on the increases in total ton-miles shipped. The
calculations in Exhibit 7-6 suggest that the proposed rules would
result in net reductions in risk from transportation if safer
practices resulted in a 13 to 14 percent reduction in the
likelihood of releases during transportation or in exposures once
releases had occurred. Such reductions in exposures seem likely,
given the likely improvements in practices and in speed of
responses when releases occur.
Abkowitz et al. (Reference 1) have developed estimates of
the probability of releases from transportation of hazardous
wastes. Their estimates suggest that the following fractions of
the quantities shipped will be released in transit and in
terminal handlings for shipments in metal drums:
In-transit 2.4 E-06/mile
At terminals 2.9 E-04
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Using these estimates, the predicted increase in transportation
would result in expected increased releases of 4.2 MT/year in
transit, and a slight reduction in releases at terminals (0.2
MT/year) resulting from the decrease in total quantities shipped.
While the Abkowitz estimates are not directly relevant to
transportation of SQG wastes (in part because they are based on
releases from transportation of hazardous materials regulated by
DOT), these calculations suggest that expected releases from
increased transportation of SQG wastes represent small quantities
in the aggregate. Because any releases of the wastes now shipped
greater distances are more likely to be cleaned up under the
proposed rule, ass are spills from transportation to off-site
facilities (primarily to recycling facilities) that will continue
under the proposed rule. Further, transportation that continues
is less likely to result in releases in the first place,
especially where such wastes are not currently labeled as
hazardous. Finally, the proposed rules will eliminate
transportation off-site in garbage trucks and other vehicles that
are more likely to be involved in spills or other releases that
vehicles subject to DOT regulation. While lEc was not able to
estimate the effects of safer transportation practices
quantitatively, it: is likely the these effects would offset any
increase risk due to longer transportation distances, and may in
fact result in a neit decrease in risks from transportation.
Summary
The previous sections suggest that the proposed rules will
have a positive, if small, effect on risks from management of SQG
wastes. The estimates presented here are likely to understate
net reductions in risk, because lEc was not able to estimate
changes in risk resulting from safer storage or transportation
practices. Quantitative estimates of changes in risk were
developed only for a selected aspects of risk those resulting
from the limited changes in waste management methods predicted in
this report. The:se estimates include two sources of potential
increases in risks resulting from the proposed rule increased
disposal to POTWs a.nd increased transportation distances to off-
site facilities. In neither case does it appear that increases
in risk would be significant, with the possible exception of
increased exposure to threshold health effects resulting from
more concentrated disposal at fewer off-site facilities. (lEc did
not attempt to estimate increased risks from another source
potential increases in illegal disposal. Given the moderate
impacts at the facility level discussed in Chapter 8, such
7-26
-------
increases in illegal disposal may be minor). Thus, the proposed
rule is likely to result in net decreases in risks from the
management of SQG wastes, but it is not possible to estimate the
size of that decrease.
BENEFITS OF ADMINISTRATIVE REQUIREMENTS
This section describes the benefits of two of the
administrative requirements that differ among the regulatory
alternatives discussed in Chapter 2 the manifest system
(including exception reports) and the biennial reporting
requirement. For the most part, the benefits of these
requirements accrue to the government by supporting monitoring
and enforcement efforts. Therefore, these requirements affect
risks to human health and the environment only indirectly, and we
have not attempted to quantify these effects.
Benefits of Alternative
Manifest Systems
The use of a full manifest system (with exception reports)
results in three types of benefits. First, the manifest
provides information to the transporter/facility handling the
waste about the nature of the waste. The labeling function of the
manifest alerts transporters and TSDFs that they are handling
hazardous wastes, and discourages facilities and transporters
other than those authorized to handle hazardous wastes from
accepting these wastes. Presumably, the increased awareness of
the nature of wastes being handled results in more careful
handling, decreasing the likelihood of spills and other releases.
Should a release occur, the information about the waste recorded
on the manifest should be helpful to emergency response
personnel, thereby minimizing human and environmental damages
from spills and other releases.
Second, the full manifest acts as a tracking system,
allowing generators and others to monitor the actions of
transporters and increasing the likelihood that wastes will be
delivered to their intended destinations.
Third, the exception report (and in some cases the manifest
itself) represents an enforcement tool that potentially allows
regulatory agencies to detect illegal disposal of hazardous
wastes. The fact that generators are required to file exception
7-27
-------
reports when manifests are not returned to them by the final
destination facility enables state and federal enforcement
authorities to investigate any shipments that do not arrive at
the intended destination.
The proposed single copy manifest requirements eliminate
some of the benefits of the full manifest system. The proposed
requirements would provide information to the transporter and the
TSD facility about the nature and quantity of the hazardous
waste, but would not function as a tracking system, unless SQGs
voluntarily complete multiple copies of the manifest. (EPA
expects that many SQGs will choose to complete the multiple
copies.) The single copy system is not designed to provide any
information to support state and federal enforcement efforts.
The Agency has proposed the single copy manifest to relieve
SQGs of recordkeeping and reporting burdens. The partial
manifest will result in less paperwork for the regulated
community, and achieve the "notice" function addressed by
Congress in the legislative history of the HSWA. The Agency has
concluded that even a single copy of the manifest will alert
transporters and facility personnel to the hazardous nature of
the waste, thereby preventing accidents and injuries caused by
failure to identify shipments as hazardous.
Use of a partial manifest for SQGs may cause some problems
in implementation. The partial manifest system would require
TSDFs and transporters to distinguish between shipments from LQGs
and SQGs, to determine whether to accept single copies of
manifests and whether return of the signed manifest is required.
It will be difficult for TSDFs and transporters to verify a
generator's status as a SQG, since that status depends on
quantities generated over an entire month and not on the
quantities in any one shipment. Some of the hazardous waste
facilities contacted by lEc stated that it would be a burden to
confirm that a generator is a SQG, and opposed reduced manifest
requirements for SQGs. It is possible that SQGs will have to
complete full manifests in order to use certain TSDFs or
transporters, despite the reduced SQG requirements, if these
parties will not accept single-copy manifests.
As noted in Chapter 2, the Agency is specifically seeking
comments on both the benefits and burden of the proposed partial
manifest requirements, and of the full manifest and exception
reporting requirements as an alternative.
7-28
-------
Benefits of the Biennial Report
A biennial report is required of all TSDFs, and all LQGs
shipping hazardous wastes off-site. The report, usually compiled
from copies of manifests, provides EPA and the states with
information about the total quantities and types of wastes
shipped by generators and managed at on- and off-site TSDFs. A
number of states require more detailed information than specified
in the federal requirements, such as type of waste treatment
employed, the physical state of the waste, identity of
transporters, and the specific dates of shipment. The
information provided in these biennial (or in some states,
annual) reports is potentially useful for a number of reasons.
First, the reported data can be used to construct a detailed
picture of the regulated hazardous waste community.
Specifically, the report provides data needed to assess the
quantities and types of hazardous waste being generated and
treated, and to define the universe of generators, transporters
and hazardous waste facilities. These data have been used by
states in a number of ways, including use by state legislators to
support hazardous waste regulation, by state planning agencies to
evaluate requests- for new TSD facilities, and by state
enforcement agencies to check on the activities of generators,
transporters and facilities.
The biennial report also provides a quantitative basis for
assessing a hazardous waste tax or fee on generators and TSDFs in
some states. A number of states charge generators and facilities
an annual fee based on the type and quantity of waste generated,
and/or how the waste is treated.
A final benefit of the biennial report is that the
information on total waste types and quantities can be used for
enforcement efforts. The biennial report provides a more up-to-
date listing of generators sending wastes off-site than the one-
time notification, and thus may help states plan inspections. In
states that do their own tracking of manifests, the biennial
report is often used as a cross-check on manifests. A number of
states contacted also indicated that they compare the waste types
and quantities on the generator manifests to the quantities
reported in the biennial reports. If there is some discrepancy
between the waste quantities reported by the generator and those
reported by off-site facilities, the state may investigate both
the generator and the facility to determine if wastes are being
illegally managed.
7-29
-------
The proposed SQG regulation exempts generators from filing
biennial reports. The proposed rule results in reduced paperwork
for SQGs, and reduced burden to the regulatory agencies that are
required to review and summarize generator annual reports. The
reduced burden to the regulatory agencies may be particularly
significant when considering that more than 175,000 SQGs will be
newly regulated.
Without the biennial reporting requirement for SQGs, states
that use the biennial report to levy a hazardous waste tax on
generators would have to implement their own biennial reporting
requirement or devise another strategy to acquire information on
the quantity and type of waste being generated by individual
SQGs. In addition, it would not be possible to check generators'
reports against reports from TSDFs for enforcement purposes.
However, it will be possible to compile information on the
universe of generators sending wastes to off-site facilities (as
most SQGs other than those disposing to sewers or recycling on-
site are likely to do), because the TSDFs receiving those wastes
will still be subject to the biennial reporting requirement. The
major loss in information on the regulated community will be on
SQGs continuing to manage hazardous wastes on-site in ways that
do not subject them to the biennial reporting requirement as
TSDFs e.g., SQGsi that recycle wastes on-site.
Conclusion
The discussion in this section suggests that the proposed
rule will provide less information to regulators and enforcement
officials than would the alternatives considered, but will reduce
paperwork burdens on generators. The Agency has concluded that
the reduced requirements assure a reasonable measure of
protection of human health and the environment from the small
quantities of hazardous waste involved.
7-30
-------
O 3 * " **
« « *»»» * <& * *
s = = aa ss B 99
-. »- 35 SXJ 5»S»
fi £J ft S !5 22 SJ 81
S SS 33 53 93
S -l -f
3
-------
Exhibit 7-2
CHANGES IN MflNA6E>ENT PRACTICE
MT oer year
Current Practice:
Future Practice:
SPENT SOLVENTS
DRY CLEANING FIL
KIDS t ALKALIES
PHOTOGRAPHIC UAS.
SOLID WASTE INCINERATION
SOLID UASTE LANDFILL ON/OFF
Sscure Recycle Sewer Treat Haz. Was. Secure Treat
Landfill Off (POTW) Off Incin. Off Landf. Off
479 2,29fl 935
i>,295 684 2%
(1 22 441
276 128
SEC. SEWER
LAWJF. (POTW)
Treat Recycle
Off Off
17
I6NIT. PAINT UASTE
IGN. UAS. LIQUID*
I6N. UAS. SOLID*
PEST1C. SOLUT.
WASTES N/ SILVER
FORMALDEHYDE
SPENT PLATING UAS.
TOTAL
2,023
1,384
139
139
65
260
306
5,101 2,298 751 1.386
1.213
424
441
1,078
1.661
817
817
* Igmtable wastes, one of the too ten wastestreaas, has been further broken down into the hauid and
and solid couonents shown here.
Source: Swll Quantity Benerator Survey, targeted wastes and on wry industries only; and lEc analysis
of soecial survsy tabulations orepared by Pooe-Reid and ICF.
-------
Exhibit 7-3
QUANTITY AND COMPOSITION OF GENERIC SQG WASTES
ASSUMED FOR ANALYSIS OF RISKS
Currently Disposed in Subtitle D Landfills:
0.82 MT/year at 10,344 facilities
3.27 MT/year at 2,586 facilities
Total » 16,938 MT/year
Disposed at a rate of 50 and 200 tpd; 20 % water content;
density of 0.5 MT/m**3
Disposed in Subtitle C Landfills After Proposed Rule;
27.5 MT/year at 318 facilities
Total = 8,745 MT/year
Disposed at a rate of 80 TPD; moisture content =
"field capacity" (normally 40 - 60 percent water);
density of 1.3 MT/m**3
Composition, of Landfilled Wastes;
Constituent
Concentration (ppm)
In Subtitle D In Subtitle C
Facility Facility
Benzene
Carbon Tetrachloride
Chloroform
1,1,2,2-Tetrachloroethane
Trichloroethylene
Acetone
Methanol
Acetaldehyde
1,2-Dichlorobenzene
Methyl Ethyl Ketone
Toluene
Xylene
15,000
15,000
15,000
150,000
30,000
5,000
5,000
11,000
15,000
69,000
69,000
26,000
5,000
5,000
5,000
214,000
10,000
9,000
9,000
21,000
5,000
5,000
5,000
26,000
-------
Exhibit 7-3
(continued)
QUANTITY AND COMPOSITION OP GENERIC SQG WASTES
ASSUMED FOR ANALYSIS OF RISKS
Disposal to PQTWs;
o Two facility sizes modelled: 50 mgd and 250 mgd
o Assumed that SQG wastes represent 0.64 ppm in the
influent before regulation and 0.76 ppm after
regulation.
Sources: PRA estimates (Reference 45), with compositions for
landfilled wastes adjusted by ICF (Reference 24) to
exclude metal constituents (because of the low levels
of toxic metals relative to other toxic constituents
estimated by PRA), pesticides (because of the low
levels relative to the toxic constituents included),
1,1,l-trichloroethane (quantities combined with
trichloroethylene), and toluene diisocyanate (which
poses little risk at the levels estimated by PRA).
-------
Exhibit 7-4
FACILITY CHARACTERISTICS ASSUMED IN RISK ANALYSIS
Landf ills:
Subtitle D Landfills
Small Large Total
Number of
facilities
10,344 2,586 12,930
Exposed Population* 200 200
Liner unlined unlined
Facility Size
(sq m)
Leachate Detection
Cover
Waste:Fill Ratio
100,000 267,000
none
daily
90:10
none
daily
90:10
Subtitle C
Landfills
318
200
composite
clay with
synthetic
96,126
present
daily
70:30
POTW Impoundments:
o Concrete-lined surface impoundments representing
primary and secondary settling tanks and activated
sludge (aeration) basins at POTWs.
o Two facility sizes (50 mgd and 250 mgd), both assumed
to be activated sludge facilities with anaerobic
digestion and vacuum filtration of the sludge.
o Concrete liners assumed to be eight inches thick, with
permeability of lxlO**5 cm/sec.
Exposed population remains constant over the entire analysis
period. Assumed 70 year lifetime with uniform age distribution,
-------
Exhibit 7-5
RESULTS OF RISK ANALYSIS:
ESTIMATED CHANGE IN HEALTH RISK
(over 400 year analysis period)
Number of
Facilities (
CURRENT PRACTICE:
Subtitle D Landfills 12,930
POTWs: Groundwater 78
Volatilization 78
TOTAL
POST REGULATION:
Subtitle C Landfills 318
POTWs: Groundwater 94
Volatilization 94 .
TOTAL
- V.AWVȣ..K
Average Total
^ses/Facil. Cases
.028 364
.317 25
.0002 <1
389
.33 105
.317 29
.0002 <1
134
WUJN-WUNUCJ.K
Average Total
Cases/Facil. Cases
.0027 35
33.8 2,641
0 0
2,676
5.90 1,877
33.8 3,168
0 0
5,045
CHANGE RESULTING FROM
DECREASED SUBTITLE D
LANDFILL DISPOSAL!
(255)
2,369
NOTE: Based on assumptions about numbers of facilities, quantities of SQ
wastes disposed at each facility, and numbers of people exposed at
each facility. Non-cancer effects estimates are preliminary. Se
text for explanation.
-------
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ECONOMIC IMPACTS OF PROPOSED RULE CHAPTER 8
INTRODUCTION
This chapter describes the economic impacts resulting from
the proposed rule. This analysis was performed by Development
Planning and Research Associates, Inc. (DPRA), based on
incremental compliance costs developed by Pope-Reid Associates
(PRA). This chapter briefly summarizes the methodology developed
by DPRA to assess impacts, and describes the results of the
analysis. More detailed descriptions of methodology and results
are presented in ICF Inc., et. al., Reference 26.
DPRA assessed economic impacts at two levels: plant/firm and
industry. Plant/firm impacts are effects on individual genera-
tors, while industry level impacts are effects on industries as a
whole. Impacts of concern at the plant/firm level include:
o effects on generators' sales,
o effects on generators' costs,
o effects on generators' profits, and
o potential plant closures.
Impacts of concern at the industry level include:
o effects on industry production,
o effects on price, and
o effects on industry employment.
8-1
-------
The SQG regulation was found to have more significant
effects ' for certain groups of plants and firms than for any
industry group as a whole. However- in the great majority of
cases- economic impacts are expected to be minor even for the
most seriously affected establishments. DPRA's methodology
employed a number of simplifying assumptions that may overstate
or understate impacts for particular groups of SQGs. The
methodology is described in the next section and potential
limitations are summarized in the last section of this chapter -
Subject to those limitations. it appears that the proposed rule
will not impose significant economic burdens on a substantial
number of establishments in any industry, although in isolated
cases certain generators could experience significant impacts.
DESCRIPTION OF METHODOLOGY
£lani/PimL Impacts
DPRA analyzed plant/firm level impacts using 289 model
plants, which represent SQGs of different sizes in different
industries. These plants were subjected to two financial
"screens" to determine which ones may experience significant
impacts. Conceptually, the analysis assesses impacts on a firm
level- However- most of the data used are for establishments (or
plant level). The analysis is therefore based on the assumption
that for most SQGs. the "firm" and the "plant" or "establishment"
are the same
Model Plants
DPRA developed 289 model plants with different operational
and financial characteristics. The operational characteristics
include: 4 digit SIC code, size category, total annual waste
load. and primary waste stream- The size classes are: small- 1
to 9 employees; medium- 10 to 49 employees; and large. 50 or
more employees. Total annual waste loads were based on analysis
of the SQG survey data- and include all wastes generated by SOGs
in the SIC code and size class- The primary waste stream is the
one which accounts for the largest portion of the total annual
waste load. Financial characteristics include: sales (revenues)
pre-tax profits, and discounted cashflow after compliance (DCF).
Sales figures for each model plant were obtained from the FINSTAT
database Pre-tax profits were calculated from the corporate tax
rates and after-tax profits from FINSTAT. Discounted cashflow
8-2
-------
was calculated using financial data from FINSTAT and other
sources- I/ Discounted cashflow was only calculated for model
plants which appear to experience the greatest impacts based on
sales and profit.
Initial Screen
An initial screening analysis evaluated incremental cost of
compliance as a percent of sales and profits, to identify model
plants with the greatest potential impacts- Model plants with an
incremental cost of compliance greater than 1 percent of sales or
25 percent of profits were considered to experience potentially
significant impacts. The remaining model plants were considered
to experience insignificant impacts and were excluded from
further analysis.
The incremental cost of compliance for each model plant was
calculated using costs developed by Pope-Reid Associates (PRA)
for each waste- The calculation incorporates several important
simplifying assumptions, as follows:
o Initial costs were annualized using a 3 percent
discount rate and a 10 year time horizon.
o All incremental costs assumed a change from
disposal in a sanitary (Subtitle D) landfill to
disposal in a secure (Subtitle C) landfill.
o Compliance costs were based on the unit cost of
compliance for the primary waste stream and the
total annual quantity of all wastes generated.
The assumed change in practice (from sanitary to secure landfill)
is essentially a worst case assumption. Some practices will not
have to change- and industries usinq those practices on a
widespread basis will be subject to lower compliance costs than
those used in the impacts analysis.
I/ Other sources used include the 1984 Tax Reform Law. Robert
Morris Association Annual Statement Studies, and Value Line-
8-3
-------
Second Screen
A second screening analysis used the DCF to
whether a model plant might close in the face of the
worst-case costs- A DCF less than zero was assumed to
financial difficulties and possible closure- The
calculated only for the model plants which appear to
greatest impacts among those selected in the initial
analysis. The DCF was calculated from the following
variables:
o earnings before taxes.
o interest payments.
o sales growth.
o working capital requirements.
o cost of debt capital,
o cost of equity capital.
o overall cost of capital.
o debt position.
o annualized capital expenditures, and
o annualized compliance costs.
determine
estimated
indicate
DCF was
experience
screening
financial
Industry Impacts
DPRA analyzed industry level impacts for each of the
industry groups i.n the SQG survey using industry profiles and two
financial screening analysis.
Industry Profiles
DPRA developed a financial profile for each SIC code
included in the ;3QG survey, to characterize baseline financial
conditions- The profiles included the following information
(from the 1977 Census of Manufacturers) for each SIC and size
class (as defined for the plant/firm level impacts):
8-4
-------
o value of shipments (a proxy for sales or
revenues),
o number of establishments, and
o employment-
DPRA then estimated the share of revenues and employment
attributable to SQGs in each size class for each SIC, using the
number of SQG establishments as a percent of the total number of
establishments (from the SQG survey) and the share of total SIC
revenues and employment attributable to the size class (from the
Census).
The first screening analysis identified SICs in which SOGs
account for more than 5 percent of industry revenues or
employment. SICs with less than a 5 percent share were
considered unlikely to experience significant impacts at the
industry level and were excluded from further analysis.
The second screen was applied to industry groups as defined
in the SQG survey. An industry group was considered if any of
the SICs within that group failed the first screen. Aggregate
incremental compliance costs were calculated for each waste in
the industry group as the product of the unit cost of compliance
for that waste and the total quantity of that waste generated by
the industry group. These were then summed over all the wastes
for the industry group to obtain aggregate compliance cost, for
use in further analysis.
While the compliance costs used for the plant/firm level
impacts were based on a worst case assumption about change in
practices, the aggregate compliance costs used for the industry
level impacts are based on a more representative assumption. For
each waste, the unit cost of compliance was calculated as a
weighted average of the unit costs of compliance for all major
baseline practices described in Chapter 6- Post-regulation
management practices were generally assumed to be the least
costly feasible change- The costs for different current
management practices were then weighted by the percent of the
waste currently managed by each practice to get a unit cost of
compliance for the waste.
8-5
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The second screeninq analysis identified cases in which
aggregate costs of compliance were greater than one percent of
industry revenues. Industries identified by this screen would be
analyzed for price, production, and employment effects; however-
none of the industries showed compliance costs greater than one
percent of revenues, so this final step was not performed.
SUMMARY OF RESULTS
Piant/Firm Impacts
Plant/firm level impacts may vary widely in severity.
Severe impacts at the plant/firm level may results in plant
closure. However, a plant may remain open and still experience
significant impacts in the form of effects on sales, costs, and
profits.
As discussed earlier, two criteria were used as a first
screen to identify plants experiencing potentially significant
impacts: compliance cost greater than 1 percent of sales and
compliance cost greater than 25 percent of profits. Exhibit 8-1
shows the distribution by size and average financial
characteristics for all model plants and for the model plants
exceeding one or both of the criteria- The first column shows
plants exceeding only the sales criteria, the second shows plants
exceeding only the profits criteria, the third shows plants
exceeding both criteria, and the fourth shows plants exceeding
one or both criteria (i.e.. all plants represented in columns 1
2- and 3). The last column represents all the model plants
(including those represented in the first four columns). In
general, the most affected plants are small (1 to 9 employees).
have very low average baseline sales and profits, and have
somewhat higher-than-average compliance costs. The 16 plants
exceeding only the sales criteria are almost all small and have
fairly typical compliance costs- but very low average sales.
Three plants exceeding only the profits criteria are medium or
large, with very low profits and high compliance costs on
average- Six plants exceeding both criteria are all small, and
have extremely low sales and profits, and fairly high compliance
costs, on average.
Exhibit 8-2 lists the 25 model plants that fail the first
screen. For many of the wastes listed as the primary waste- the
sanitary-to-secure landfill assumption clearly overstates costs.
because only a small percent of these wastes are expected to
8-6
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experience that change in practice. For the following wastes.
less than 5 percent of the total quantity is predicted to shift
from sanitary to secure landfills:
o Solutions or sludges with photographic silver-
o Ignitable wastes (liquid),
o Photographic wastes.
o Pesticide washing and rinsing solutions.
o Strong acid or alkaline wastes.
o Waste formaldehyde.
o Spent plating wastes, and
o Spent solvents.
Because all other expected changes in practice are less costly
than shifting from sanitary to secure landfills for these wastes,
the impacts on the plants in Exhibit 8-2 producing these wastes
will be less severe-
The sanitary-to-secure landfill assumption is more
representative for the plants producing the following wastes:
o Filtration residues from dry cleaning, and
o Ignitable wastes (solid).
About 42 percent and 25 percent of these wastes respectively are
expected to require the assumed sanitary-to-secure landfill
change. Plants producing these wastes may be significantly
affected. Plants producing ignitable paint wastes may also be
significantly affected. While no ignitable paint wastes are
predicted to shift from sanitary to secure landfills. 42 percent
are predicted to require a more expensive change in practice
(from sanitary landfill to Subtitle C treatment). (This is the
only instance in which a waste experiences a more expensive
change in practice than sanitary to secure landfill). Plants
potentially experiencing significant impacts that produce these
wastes include:
o Dry Cleaning Plants, except Rug (Laundries).
8-7
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o Radio and Television Repair (Equipment Repair).
o Radio Broadcasting (Equipment Repair).
o Painting, Paperhanging. and Decorating (Construc-
tion) .
o Wood Kitchen Cabinets (Furniture/Wood Manufac-
turing & Refinishing).
o Industrial Launderers (Laundries).
o Prefabricated Wood Buildings (Construction). and
o Carpet and Upholstery Cleaning (Laundries)-
(Industry group is noted in parentheses.) The plant-level
results suggest that (1) dry cleaners generating filtration
residues- (2) equipment repair establishments generating
ignitable wastes- and (3) small manufacturers or services
generating ignitable paint wastes, in quantities greater than 100
kg/month- are the generators most likely to experience
significant impacts.
The discounted cashflow was calculated for the six plants
exceeding both the sales and profits criteria, in order to assess
the possibility of plant closure- All six plants had positive
discounted cashflows, which indicates that plant closures are
unlikely- It seems likely that the discounted cashflow of the
plants exceeding only one criteria would also be positive under
worst case assumptions-
This analysis suggest, then, that few if any plant closures
are likely to result from the proposed rule. However- individual
plants in certain industries may be significantly impacted. and
could close with positive but small cash flows.
Industry Impacts
The analysis: suggests that impacts at the industry level
impacts will be negligible. This is largely due to the fact that
SOGs account for a. very small share of most industries' revenues
and employment- For more than half of the SIC groups considered,
SQGs accounted for less than 5 percent of revenues or employment.
8-8
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Impacts on these SQGs are unlikely to affect the industry as a
whole. The industry groups containing SICs in which SOGs account
for 5 percent or more of revenues or employment are:
o Metal Manufacturing.
o Vehicle Maintenance.
o Photography.
o Printing.
o Laundries.
o Other Services,
o Pesticide Applicators.
o Laboratories.
o Other Manufacturing, and
o Furniture Manufacturing and Refinishing.
The aggregate compliance costs as a percent of industry revenues
are extremely small for these industries, ranging from 0-001
percent for Metal Manufacturing to 0.05 percent for Vehicle
Maintenance- (Revenues were not available for Pesticide
Applicators.) Compliance costs for the industries listed above
range from 51-3 million per year for Furniture Manufacturing and
Refinishing to $10 million per year for Metal Manufacturing.
Due to the low aggregate compliance costs and small SQG
share of industry revenues, then, industry level impacts such as
effects on price. production. employment. and industry
profitability are not expected to be significant.
CONCLUSIONS AND LIMITATIONS OF THE ANALYSIS
The results of the analysis described in this chapter
suggest that most SQGs are not likely to experience signficant
impacts as a results of the proposed rule. This conclusion
depends on the accuracy of the estimated compliance costs, of
course. In most cases, the costs used in the establishment-level
8-9
-------
analysis are likely to overstate actual costs. However, in some
cases. costs (and hence impacts) may be understated. As
described in Chapter 6- these include the following:
o SQGs using current management practices that are
not predicted to change but would in fact be
likely to change under the proposed rule (eg.,
on-site treatment that occurs in surface
impoundments, rather than in tanks or containers)
may be subject to more severe impacts than
estimated here-
o SOGs w.tio would have to ship wastes substantially
further than the 100 miles assumed in the cost
analysis, or who are not located in areas likely
to be served by transporters, may experience more
severe impacts-
o The analysis is based on average financial
characteristics and waste generation quantities
within the three size categories considered.
Within .any size category and industry, the assumed
chracteristics may not be accurate for some
generators. and thus some generators may
experience greater or lesser impacts than
estimated here.
The analysis suggests that the SQGs that are the most likely
to experience significant impacts include: (1) SOGs managing
certain wastes (ignitable paints and other ignitable wastes and
dry cleaning filtration residues). (2) SOGs currently managing
wastes in non-compliant facilities or facilities that would have
to be upgraded substantially (e.g., sanitary landfills or
treatment in surface impoundments). (3) SOGs required to ship
long distances to off-site facilities. (4) SOGs located in
isolated areas not served by transporters, and (5) SOGs whose
profitability is low under baseline conditions.
8-10
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EXHIBIT 8-2
MOST AFFECTED MODEL PLflNTS
SIC INDUSTRY NAME
INDUSTRY 6ROUP
PRIMARY WASTE
SIZE
Sales Criteria only:
7216 DRY CLEANING PLANTS, EXCEPT RUG
7622 RADIO AND TELEVISION REPAIR
7333 COMMERCIAL PHOTOGRAPHY AND ART
2751 COMMERCIAL PRINTING, LETTERPRESS
7992 PUBLIC GOLF COURSES
7342 DISINFECTING AND EXTERMINATING SERVICES
2752 COMMERCIAL PRINTING, LITHOGRAPHIC:
7397 COMMERCIAL TESTING LABORATORIES
4832 RADIO BROADCASTING
7332 BLUEPRINTING AND PHOTOCOPYING
1721 PAINTING, PAPERHAN6IN6, AND DECCFATIN6
7261 FUNERAL SERVICE AND CREMATORIES
2434 WOOD KITCHEN CABINETS
1741 MASONRY AND OTHER STONEUORK
3471 PLATING AND POLISHING
7391 RESEARCH AND DEVELOPMENT LABORATORIES
Profit Criteria only:
LAUNDRIES
EQUIPMENT REPAIR
PHOTOGRAPHY
PRINTING/CERAMICS
PESTICIDE END-USERS
PESTICIDE APPLICATION SERVICES
PRINTING/CERAMICS
ANALYTIC AND CLINICAL LABS
EQUIPMENT REPAIR
PHOTOGRAPHY
CONSTRUCTION
OTHER SERVICES
FURNITURE/HOOD MANUF i REFINISH
CONSTRUCTION
METAL MANUFACTURING
ANALYTICAL AND CLINICAL LABS
FILTRATION RESIDUE FROM DRY CLEANING SMALL
I8NITABLE UASTES SMALL
SOLUTION OR SLUDGES UITH PHOTO SILVER SMALL
PHOT6RAPHIC UASTES SMALL
PESTICIDE WASHING AND RINSING SOLUTION SMALL
PESTICIDE WASHING AND RINSING SOLUTION SMALL
PHOTOGRAPHIC WASTES SMALL
STRONG ACID OR ALKALINE WASTES SMALL
IGNITABLE WASTES MEDIUM
PHOTOGRAPHIC WASTES SMALL
IGNITABLE PAINT WASTES SMALL
WASTE FORMALDEHYDE SMALL
IGNITABLE WASTES SMALL
STRONG ACID OR ALKALINE WASTES SMALL
SPENT PLATING WASTES MEDIUM
SPENT SOLVENTS SMALL
7997 MEMBERSHIP SPORTS flND RECREATION CLUBS PESTICIDE END-USERS
7218 INDUSTRIAL LAUNDERERS LAUNDRIES
2452 PREFABRICATED WOOD BUILDINGS CONSTRUCTION
PESTICIDE WASHING AND RINSING SOLUTION MEDIUM
FILTRATION RESIDUE FROM DRY CLEANING MEDIUM
IGNITABLE PAINT WASTES LflRGE
Both Criteria:
7217 CARPET AND UPHOLSTERY CLEANING
7349 BUILDING MAINTENANCE SERVICES, N.E.C.
3471 PLATING AND POLISHING
782 LAHN AND GARDEN SERVICES
7395 PHOTQFINISHIN6 LABORATORIES
LAUNDRIES
OTHER SERVICES
METAL MANUFACTURING
PESTICIDE APPLICATION SERVICES
PHOTOGRAPHY
7997 MEMBERSHIP SPORTS AND RECREATION CLUBS PESTICIDE END-USERS
FILTRATION RESIDUE FROM DRY CLEANING SMALL
WASTES UITH AMMONIA SMALL
SPENT PLATING WASTES SMALL
PESTICIDE WASHING AND RINSING SOLUTION SMALL
SOLUTION OR SLUDGES WITH PHOTO SILVER SMALL
PESTICIDE WASHING AND RINSING SOLUTION SMALL
-------
BASIS FOR SELECTION OF
PROPOSED REGULATION CHAPTER 9
This chapter summarizes the costs and benefits of
alternative approaches for regulating SQGs, and describes the
Agency's rationale for selecting the proposed regulation. The
choice of a regulatory strategy for SQGs was influenced by
several considerations, which are summarized first. We then
briefly summarize the findings of the cost, benefit and impacts
analyses for the proposed rule and alternatives.
Some aspects of the proposed regulation are dictated by the
requirements of the HSWA. In particular, EPA did not consider
eliminating minimum manifest requirements for SQGs, and did not
consider allowing SQGs to dispose of wastes at facilities except
those subject to some set of requirements under Subtitle C of
RCRA (and except for discharge via sewers to POTWs, under the
provisions of the Clean Water Act.) While this RIA does not
consider the costs and benefits of eliminating such requirements
explicitly, it is likely that such an analysis would show that
eliminating requirements for manifests and management at some
sort of regulated facility would pose risks that outweighed
savings in regulatory costs to SQGs.
Use of a manifest does not impose significant costs on SQGs,
beyond the costs associated simply with evaluating whether wastes
are hazardous. Since this evaluation is a necessary condition
for any assurance that wastes will be managed properly and is
currently required, the Agency concluded that elimination of a
manifest requirement would not be justified.
9-1
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Although management of wastes at facilities regulated under
Subtitle C of RCRA imposes greater costs on SQGs/ the Agency
again expects that^ the risk reductions achieved by ensuring that
wastes are managed in facilities designed to handle hazardous
waste (and subject to some requirements under RCRA) are likely to
outweigh potential costs. The analysis of reductions in risk
presented in Chapter 7 considered only a small part of the
effects of requiring Subtitle C management the effects of
eliminating disposal at Subtitle D landfills. The analysis of
responses in Chapter 7 suggests that many SQGs will not have to
change waste management practices (although the predicted changes
in practice are likely to be understated for on-site treatment).
Therefore, a major part of the benefits resulting from Subtitle C
management are likely to result from more careful monitoring and
management in existing practices. These benefits are difficult
to quantify, but are likely to significantly decrease the
potential for releases of SQG wastes.
In addition, the analysis presented in Chapter 8 suggests
that the costs of Subtitle C management are not likely to impose
significant burdens on most SQGs. This result is attributable to
the small quantities of waste requiring management and the fact
that most SQGs will not have to make significant changes in
practices requiring large capital outlays. Cost may be
significant in isolated cases, where off-site management is
costly for particular wastes or in particular locations. On the
whole, however, requiring Subtitle C management does not appear
to impose significant costs for most SQGs.
EPA did not consider proposing a shorter period for on-site
storage exempt from Subtitle C storage facility requirements
than the 180 and 270 day provisions specified in the HSWA. In
designing the current LQG requirements, EPA made the
determination that storage for short periods (less than 90 days)
on-site prior to subsequent management posed less risk than
longer-term storage practices. The longer period proposed for
SQGs is not likely to increase risks, given that the storage
period is still limited, that the quantities stored subject to
reduced requirements could not exceed 6000 kg (equivalent to
approximately 30 drums), and that under the proposal such storage
would be subject to some requirements.
Beyond those minimum provisions, the HSWA allow EPA to issue
standards for mancigement of SQG hazardous wastes' that are less
stringent than those currently imposed for LQGs, as long as the
standards are "protective of human health and the environment."
9-2
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SQGs are very diverse in the types of wastes generated and the
practices currently used to manage those wastes, as are LQGs.
Therefore, the regulations must anticipate a wide range of
circumstances that may pose very different risks to human health
and the environment. Given that the costs imposed on SQGs as a
result of the proposed regulation may be significant in some
cases, and that the risks from current SQG practices are likely
to vary greatly, there is substantial po
different standards for situations presenting different levels of
risk.
To date, however, EPA has not identified any type of SQG
waste for which requirements could be reduced while assuring
protection of human health and the environment. The variations
in requirements by waste type in the current regulations for LQGs
(lower SQG exemption levels for acutely-hazardous wastes;
restrictions on land disposal of liquid, ignitable and reactive
wastes; higher performance requirements for incineration for
certain highly-toxic dioxin wastes; and reduced requirements for
certain types of recycling activities) appear to be appropriate
for SQGs as well. Furthermore, the extant requirements include
many performance-based standards, which must be interpreted in
individual circumstances, including types and quantities of
waste. Therefore, the costs associated with the proposed
requirements will automatically reflect differences between SQGs
and LQGs to some extent. Further, the analysis of potential SQG
responses to the proposed rule suggests that even the minimum
requirements the Agency might consider for SQG wastes are likely
to discourage many types of on-site management. The Agency
therefore concluded that the tailoring of requirements for on-
site management would not result in significant benefits to SQGs.
(The basis for this conclusion is discussed in more detail later
in this chapter.)
Finally, EPA did not consider reducing requirements for off-
site facilities that accept hazardous wastes only from SQGs.
Such facilities may manage large quantities of waste in total,
even though the wastes are individually generated in small
amounts. It is likely that risks to human health and the
environment are more a function of the total quantities managed
and the degree of variability in the wastes accepted, than of the
quantities in which the wastes are originally generated. Thus,
off-site facilities managing SQG wastes are not likely to present
less risk than similar facilities that accept LQG wastes. Such
facilities may even present greater risks than on-site
facilities managing large quantities of a single type of waste,
9-3
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because management of diverse waste streams may require the use
of more-generally applicable technologies that are less well
suited to control of risks than dedicated facilities, and may
increase the chances of adverse interactions among wastes.
For these reasons, the Agency concluded that there is no
basis for reducing Part 264 and 265 requirements for off-site
facilities that accept SQG wastes. The practical consequences of
this decision are not likely to be great, however, since to be
economically viable most commercial facilities would have to
accept wastes from LQGs as well as from SQGs, and thus most off-
site facilities are likely to be subject to full Subtitle C
requirements already.
The analysis of benefits of the proposed rule presented in
Chapter 7 does not allow quantitative estimates of the benefits
of the proposed rule or alternatives, and hence does not allow
quantitative comparisons of the costs and benefits of the
proposed rule and alternatives. Some measure of the relationship
between the costs and benefits of the proposed rule is provided
by the two ratios., First, the costs associated with shifts in
management practices represents $213 per MT of waste for which
practices will change under the proposed rule. (This figure is
derived from the cost analysis reported in Chapter 6. As noted
there, predicted changes in management practice include only
shifts from Subtitle D landfills. Hence, the aggregate costs and
quantities shifted are both understated. Although the ratio of
cost to quantities, may not be.) Second, the costs associated
with imposition of notification, manifest, shipping, and limited
storage requirements represent $148 per MT of waste subject to
these requirements (all SQG wastes).
The remainder of this chapter discusses the alternatives
that were explicitly considered by EPA.
ALTERNATIVES FOR GENERATOR REQUIREMENTS
Chapter 2 describes three alternative strategies for
regulating SQGs with respect to generator requirements under 40
CFR Part 262. For reasons discussed previously, EPA did not
consider waiving or reducing requirements that SQGs determine
whether their wastes are hazardous, according to the criteria
established under 40 CFR Part 261. EPA expects that this
requirement will pose difficulties for some SQGs, and is
developing an education program to assist SQGs with this and
9-4
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other aspects of the proposed regulation. For reasons described
in Chapter 4, EPA also did not consider eliminating the
requirement that SQGs obtain an EPA identification number.
The alternatives that were considered for generator
requirements differed with respect to:
o manifest requirements. including completion of at
least three copies of manifests, a requirement
that missing shipments be tracked by generators
and exception reports be filed for any that cannot
be resolved, and requirements for three-year
retention of manifests and exception reports;
o requirements for short-term storage. including a
limited set of performance standards in place of
more explicit requirements for contingency
planning, personnel training, inspections, and
waste analyses, and limited requirements for
documenting compliance with those performance
standards; and
o reporting requirements. including elimination of
the biennial report for SQGs.
SQGs will incur lower costs as a result of the reduced
manifest requirements, although the savings may not be large.
Further, many SQGs will undoubtedly comply with the round-trip
manifest requirements in any event, because they wish to receive
signed copies from destination facilities for their own purposes,
or because transporters and TSDFs will not accept one-way
manifests in practice. The major drawback of the proposed
manifest system results from the reduced information available to
enforcement personnel. The Agency is seeking comments that would
clarify the benefits lost by the proposed reductions in
requirements, as well as the size of the cost savings for SQGs.
With respect to requirements for accumulation facilities,
EPA is proposing a set of reduced performance standards for SQGs.
The requirements will include all provisions of the existing
short-term storage requirements that bear directly on risks,
including requirements that incompatible or reactive waste not be
mixed, that SQGs evaluate waste characteristics to determine
appropriate storage methods, that containers be compatible with
wastes and not be leaking, that containers be marked to allow
9-5
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monitoring of allowed storage periodsf and the like. SQGs will
also be required to perform routine weekly inspections, and
provide adequate emergency procedures. SQGs will be required to
educate employees as to the potential hazards of their wastes,
the proper means for handling those wastes, and emergency
procedures. The major differences in requirements have to do
with documentation. SQGs will not be required to prepare formal
contingency or personnel training plans. Since relatively simple
procedures are likely to comply with the performance requirements
for most SQGs, such plans and associated recordkeeping
requirements are potentially burdensome and may not be needed to
monitor compliance. The Agency will invite comments, however, on
the need to impose a formal contingency plan.
lEc was not able to estimate quantitatively any increases in
risk to human health and the environment that might result from
reducing requirements for short-term storage by SQGs. As is the
case with the manifest system, the major differences are likely
to involve enforceability of the regulations. Further
information is needed on the role of written contingency plans,
training plans, and other such documentation and recordkeeping in
monitoring and enforcement, to determine whether such
requirements for the relatively small SQG operations will hinder
efforts to enforce the regulations. As discussed in Chapter 6,
the proposed recordkeeping requirements does result in savings to
SQGs, averaging $3,200 in initial outlays and $770 annually for
the typical generator.
ALTERNATIVES FOR ON-SITE TSDFs
Chapter 2 describes three strategies for regulating SQGs
that treat, store or dispose of their wastes in on-site
facilities. The Agency recognizes that the costs of the existing
Part 264 and 265 requirements will discourage on-site treatment,
storage and disposal, and may burden SQGs for whom off-site
alternatives are limited or costly. The Agency is nonetheless
proposing full :?art 264 and 265 requirements for on-site
treatment, storage and disposal for SQGs. In part, this decision
is based on a belief that on-site waste management by SQGs may
not be protective if subject to reduced requirements. Many SQGs
may not have the technical expertise and facilities required to
manage wastes properly, and their wastes would be better managed
by more sophisticated off-site facilities. Increased incentives
for off-site management will result in increased transportation
of SQG wastes, with attendent hazards. As shown in Chapter 7,
9-6
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however, it is unlikely that the added risks from increases in
transportation would be sufficient to offset risks from improper
on-site waste management practices.
While the costs associated with full Part 264 and 265
requirements for on-site management are potentially significant,
in practice only a small number of SQGs are likely to incur
additional costs relative to tailored standards. Some SQGs who
generate dilute wastes that would be costly to transport might
have no economic alternatives to on-site management. These cases
are likely to be rare or non-existent, however, because wastes
generated in large enough quantities to be difficult to send off-
site are also likely to exceed 1000 kg (approximately 5 drums)
per month. In most cases, the economies of scale inherent in
any waste management technology that would adequately manage
hazardous wastes would dictate off-site management. Furthermore,
SQGs are unlikely to elect to continue any on-site in a landfill,
surface impoundment, waste pile or land application facility
which would subject them to the possibility of corrective action
for potential ground water contamination. Finally, the full
requirements do not apply to certain on-site waste management
activities recycling and treatment in tanks and containers
within 180 days. Thus, only on-site treatment in land-based
facilities, long-term storage, and disposal technologies are
likely to be discouraged by full Part 264 and 265 requirements.
These are precisely the activities that may result in
accumulations overtime of large quantities of hazardous wastes
that may pose significant hazards to human health and the
environment.
While the costs and benefits of specific tailored
requirements were not evaluated in this RIA, then, a general
review of likely responses to proposed and alternative
requirements for on-site management did not suggest that
extensive tailoring would be cost-effective. However, the Agency
is seeking comment on potential reductions in requirements for
SQGs that might reduce costs for SQGs without significantly
reducing regulatory benefits.
9-7
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APPENDIX A
CONTACTS
TRADE ASSOCIATIONS
The Neighborhood Cleaners Association
(New Jersey)
Associated Industries of Massachusetts
Association of Washington Businesses
(Washington)
Automotive Service Council
(Michigan Branch)
Automotive Service Council
(National Office)
Automotive Service Industry Association
Massachusetts Waste Management Report
Maine School Management Association
Michigan Dry Cleaners Institute
National Association of Photographic Manufactures
National Paint and Coatings Association
Northeast Fabricare Institute
(Bellingham, Massachusetts)
Small Business Association of New England
Tennessee Manufacturer's Association
A-l
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SANITARY LANDFILL OWNERS/OPERATORS
Odie Lindering, Supervisor
Arapahoe County Landfill, County Landfill
Colorado
Dave Hogan, City Engineer
City of Cedar .Rapids Landfill
Iowa
George Simmons
Topeka Waste Systems
Topeka, Kansas
Bob Hansen
City of Olathe, Kansas
Shird Robinson
SCA Services Landfill
Kentucky
George Sutherland
Sawyer Environmental
Hamden, Maine
Allen Jones
Prince George's County Landfill
Maryland
Dennis O'Neill
Metropolitan Service District Landfill
Oregon
Morris Holman
Landchester Sanitary Landfill
Pennsylvania
Joseph Brancato
Westerly Landfill
Rhode Island
A-2
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TRANSPORTERS
Solid Waste;
Charles Bowen, Jr.
United Waste Company
Atlanta, Georgia
Bob Sparks
Grant's Trash Disposal
Bangor, Maine
Tom Hall
American Waste
Tulsa, Oklahoma
Hazardous Waste
Gary Shupe, Manager
Ashland Chemical Co.
South Carolina
Carter Gray, Attorney
Earth Industrial Management
Tennessee
Ken Morton
New England Marine Corporation
Vermont
Larry Stone, V.P.
Commercial Disposal, Inc.
Springfield, Massachusetts
In addition, we contacted owners and operators operating in three
other states: California, Iowa, and Texas.
A-3
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COMMERCIAL TREATMENT, STORAGE AND DISPOSAL FACILITIES
We spoke to owners, operators and sales personnel at twelve
commercial TSDFs. These facilities operated one or more of the
following management practices: landfill, underground injection
wells, incinerators, neutralization or distillation. These
facilities were located in the following states: Michigan,
Texas, Massachusetts, Ohio, Pennsylvania, Oklahoma, Colorado and
Iowa.
OTHER CONTACTS
William Rathje
University of Arizona
Bureau of Applied Research in Anthropology
L. Jackson Russell
Association of Bay Area Governments
Nicholas Nocca
Temple, Barker, Sloane
Lexington, Massachusetts
Stephen James
U.S. EPA
ORD MERL
Cincinnatti, Ohio
Jim Michael
U.S. EPA
Solid Waste & Emergency Response
Washington, DC
A-4
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STATE CONTACTS
ALASKA
David DiPraglia
Department of Environmental Conservation
ARKANSAS
Vivian Leigh
Environmental Office
CALIFORNIA
George Rose
Associate Governmental Program Analyst
Toxic Substances Control Division
Procedures & Regulations Development Section
Department of Health
John Masterman; Kitt Davis; Kate Williams
Permitting Unit
Program Management Section
COLORADO
Joan Sowinksi
Hazardous Waste Division
FLORIDA
Raoul Clarke
Environmental Supervisor
Solid/Hazardous Waste Section
Department of Environmental Regulation
ILLINOIS
Robert Kukyendall
Manager
Illinois Environmental Protection Agency
Land Pollution Control Division
Field Operations, Permits & Compliance Monitoring Sections
A-5
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INDIANA
Jim Hunt
Environmental Management Board
Compliance Monitoring Section
IOWA
Rod Fleiger
Field Services Division
Department of Water, Air & Waste Management
Central Assistcince & Solid Waste Branches
KANSAS
John Goetz
Department of Health & Environment
Bureau of Wastes Management
Hazardous Wastes Division
KENTUCKY
Jim Determann
Department of Environmental Protection
Division of Waste Management
Abby Meyer/ Environmentalist
Program Development Branch
LOUISIANA
Karen Fisher-Brasher
Environmental Program Specialist
Office of Environmental Affairs
Department of Natural Resources
Cecil Danford; Richard Carlton
Office of Environmental Affairs
Department of Natural Resources
MAINE
Richard Baker,
Environmental Services Specialist
Department of Environmental Protecton
Bureau of Oil S Hazardous Materials Control
Enforcement Section of Licensing and Enforcement Department
A-6
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MARYLAND
Jim Pittman -
Office of Solid Waste
MASSACHUSETTS
Linda Benevides, Principal Sanitary Engineer
Department of Solid Waste and Sewage
Department of Environment Quality Engineering
Division of Hazardous & Solid Wastes
Licensing & Engineering Branch
Nancy Wren
Small Quantity Generator Program
Division of Hazardous & Solid Wastes
MICHIGAN
Joan Peck
Department of Natural Resources
Hazardous Waste Division
MINNESOTA
Karen Ryss
Pollution Control Agency
Solid and Hazardous Waste Division
Program Development Sector
MISSOURI
Kenneth Purvis, Environmental Specialist
Waste Management Program
Department of Natural Resources
NEW HAMPSHIRE
Chuck Knox, Engineer
Department of Health & Welfare
Division of Public Health Services
Office of Solid Waste
Dawn Channing
Office of Waste Management
A-7
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NEW JERSEY
Kurt Whitford
Program Development Specialist
Bureau of Hazardous Waste Classification and Management
Solid Waste Administration
NEW YORK
James Moran
Supervisor, Manifest Section
Department of Environmental Conservation
Bureau of Hazardous Waste Operations
Divison of Solid Waste
Sal Carlomagno
Bureau of Hazardous Waste Operations
OHIO
Ben Pfefferle, Attorney
Division of Hazardous Materials Management
Ohio Environmental Protection Agency
OREGON
Fred Bromfeld
Hazardous Waste Operations
Department of Environmental Quality
Solid Waste Management Division
PENNSYLVANIA
Mike Arnold, Environmental Chemist
Bureau of Solid Waste Management
Department of Environmental Resources
RHODE ISLAND
Julie Miller; Alicia Good
Department of Environmental Management
Division of Air & Hazardous Materials
A-8
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SOUTH CAROLINA
John Cain; Jack Kendall
Bureau of Solid/Hazardous Waste Management
Department of Health and Environmental Control
TENNESSEE
Edward Williams
Administrative Services Assistant to Chief of Planning
Division of Solid Waste Management
VERMONT
Harold Garabedian
Acting Chief of Hazardous Materials Progam
Division of Environmental Engineering
Air & Solid Waste Program
Hazardous Materials Management Program
VIRGINIA
Pat Grover
Department of Health, Division of Solid Waste
and Hazardous Waste Management
Bureau of Hazardous Waste Management
WEST VIRGINIA
Mark Casdorph
Department of Natural Resources
Division of Water Resources
Solid & Hazardous Waste/Ground Water Branches
WASHINGTON
Tom Cook; Dan Kruger
Department of Ecology
Office of Hazardous Waste & Air Quality
Division of Hazardous Waste & Solid Waste Management
Hazardous Waste Section
WISCONSIN
Gary Edelstein, Environmental Engineer
Department of Natural Resources
A-9
-------
APPENDIX B
REFERENCES
1. Abkowitz, Mark, Eiger, A, and Srinivasan, S. Assessing the
Releases and Costs Associated with Truck Transport of
Hazardous Wastef Final Report, prepared for EPA Office of
Solid Waste, January 1984.
2. Abt Associates, National Small Quantity Hazardous Waste
Generator Survey, Final Report, prepared for EPA Office of
Solid Waste, February 1985.
3. American Law Institute-American Bar Association, "Hazardous
Wastes, Superfund, and Toxic Substances", Course of Study
Materials, 1984 (co-sponsored by the Environmental Law
Institute).
4. Arthur D. Little, Inc, Characterization of Hazardous Waste
Transportation and Economic Impact Assessment of Hazardous
Waste Transportation Regulations, prepared for EPA Office of
Solid Waste, 1978.
5. Arthur D. Little, Inc., Evaluation of Emission Controls for
Hazardous Waste Treatment Storage and Disposal Facilities,,
Draft Final Report, prepared for EPA Office of Air Quality
Planning and Standards, August 1, 1984.
6. Association of Bay Area Governments, "Evidence of
Inappropriate Disposal of Hazardous Waste from Small
Quantity Generators", Technical Memorandum No. 11, April
1984.
7. Association of State and Territorial Solid Waste Management
Officials, State Small Quantity Hazardous Waste Generator
Survey. Draft Report, Vols 1 and 2, September 1983.
8. Battelle, Inc., Assessment of State and Locaj. Notification
Requirements for Transportation of Radioactive and Other
Hazardous Materialsr October 24, 1984.
B-l
-------
9. Battelle, Inc., Pacific Northwest Labs, Hazardous Material
Transportation Risks in the Puget Sound Region, prepared for
DOT Transportation Systems Center, 1981.
10. Bleiweiss, Shell J. "Environmental Regulation and the
Federal Common Law of Nuisance: A Proposed Standard of
Preemption", The Harvard Environmental Law Review,, Vol. 7,
No. 1, 1983.
11. Booz-Allen & Hamilton, Inc., Review of Activities of Firms
in the Commercial Hazardous Waste Management Industry; 1983
Updater prepared for EPA Office of Policy Analysis,
November 30, 1984.
12. Booz-Allen & Hamilton, Inc. and Putnam, Hayes & Bartlett,
Inc., Hazardous Waste Generation and Commercial Hazardous
Waste Management Capacity. prepared for EPA Office of
Planning and Evaluation and Office of Solid Waste, 1980.
13. The Cadmus Group, Inc., A Study of State Programs for the
Regulation oJL Small Quantity Generators of Hazardous Wastef
prepared for EPA Office of Solid Waste, July 1984.
14. Crusberg, T.C. and Smith, D.L., "Analyzing Transportation
Related Hazardous Materials Spills in New England", Journal
of the American Water Works Association, October 1982, pp.
489-505.
15. Environ Corporation, Small Quantity Generator Waste
Characterization, December 18, 1984.
16. Environmental Information Limited, Industrial & Hazardous
Waste Management Firms, 1984.
17. Fungaroli, A.A. Pollution of Subsurface Water by Sanitary
Landfills. Vol. 1, based on research sponsored by EPA, 1971.
18. Florida State University, Institute of Science and Public
Affairs, Ha2:ardous Waste Management Program, Proceedings of
USEPA Working Meeting Concerning Requirements for the
Monitoring and Management of Hazardous Waste at RCRA
Subtitle D_ Fcicilitiesf April 1985.
19. Greenman, Charles P., "Joint and Several Liability
CERCLA's Big Bite," Hazardous Materials and Waste Management
Magazinef November-December, 1984, pp. 21-26.
B-2
-------
20. Fred C. Hart Associates, Inc., Analysis o_£ £]ie. Technology.
Prevalence and Economics of Landfill Disposal of Solid
Wastes in the United States,, prepared for EPA Office of
Solid Waste, February 19, 1979.
21. The Hazardous Waste Consultant, "Liability and Victim
Compensation A Review of Principles and Statutes,"
November/December 1983.
22. Hinds, Richard, "Liability under Federal Law for Hazardous
Waste Injuries," The Harvard Environmental Law Review. 1982:
Vol. 6:1.
23. ICF, Inc., Analysis pf the Human Health Risk Associated with
Hazardous Waste Storage in Containersf prepared for EPA
Office of Policy, Planning and Evaluation, December 1983.
24. ICF, Inc., memo dated 31 May, 1985 "SQG Waste Risk Analysis"
presenting preliminary results.
25. ICF, Inc., Feasibility of SQG Manifest Changes and
TRansporter Assumption of Generator Manifest Duties.
prepared for EPA Office of Solid Waste, preliminary draft
report, April 1985.
26. ICF, Inc., Development Planning and Research Associates,
Inc., and Pope-Reid Associates, Inc., Economic Analysis cJL
Resource Conservation and Recovery Act Regulations for Small
Quantity Generators, Draft Report, prepared for EPA Office
of Solid Waste, May 1985.
27. ICF Inc., Clement Associates, Inc. and SCS Engineers, Inc.,
RCRA Risk/Cost Pol icy Model Project, Phase 2 Report,
prepared for EPA Office of Solid Waste, June 15, 1982.
28. ICF Inc., Clement Associates, Inc. and SCS Engineers, Inc.,
The RCRA Risk/Cost Analysis Modelf Phase III Report,
prepared for EPA Office of Solid Waste, March 1, 1984.
29. ICF, Inc., Sobotka & Co., Inc., Pope-Reid Associates, Inc.,
and Geraghty & Miller, Liner Location Risk and Cost Analysis
Modelf Draft Report, prepared for EPA Office of Solid Waste,
Economic Analysis Branch, January 1985.
B-3
-------
30. Industrial Economics, Inc., "Commercial Facilities Data
Base," prepared for EPA Office of Solid Waste, Economic
Analysis Branch, September 1984.
31. Industrial Economics, Inc., Draft Regulatory Analysis for
Proposed RCfcA Regulations on Burning o£ Hazardous Wastes,
prepared for EPA Office of Solid Waste, January 1984.
32. Industrial Economics, Inc., "Prices for Treatment and
Disposal Services at Commercial Hazardous Waste Management
Facilities", Draft Memorandum for EPA Office of Solid Waste,
August 15, 1984.
33. JRB Associates, Failure Incident Analysis; Evaluation of
Storage Failure Points. Draft report, prepared for EPA
Office of Solid Waste, March 1982.
34. JRB Associates, "RCRA/Pretreatment Issues Paper, Draft
Paper," May 29, 1984.
35. JRB Associates, Storage of RCRA Hazardous Wastes;
Preliminary JiisJt Assessment. Draft report, prepared for EPA
Office of Solid Waste, February 26, 1982.
36. JRB Associates, "FIT File Container Failure Incidents",
Memorandum, November 30, 1982.
37. Jones, L.W. ,, Myers, T.E. , and Larson, R.J., Study Q£
Cndisposed Municipal and Treated/ Untreated Industrial
Wastes, prepared for EPA Office of Research and Development,
1984.
38. Locke, J.H. jr Dunster, H.J., Pittom, L.A. , Investigation of
the Potential Risks to the Public from Industrial
Installation's in the Canvey/Thurrock Area of Essex, prepared
for the Health and Safety Executive, UK, May 1978.
39. Massachusetts Continuing Legal Education, Inc., Hazardous
Materials Regulations and Litigation; Liability Prevention,
Settlement ajld Litigation Strategies. 1984.
40. Midwest Research Institute, Comparison of Risks and Costs of
Hazardous W_ajLt£_ Alternatives; Methods Development and Pilot
studies. Draft Final Report, prepared for EPA Office of
Policy Analysis, November 19, 1984.
B-4
-------
41. Moshman Associates, Inc., Financial Responsibility for
Transporters of Hazardous Waste, prepared for EPA Office of
Solid Waste, 1979.
42. National Solid Waste Management Association, Unpublished
data, "Examples of Effects of Small Quantities of Hazardous
Waste in Trash", summarized in Ref. xx (ABAC)
43. The Operations Council, American Trucking Associations,
Inc., Fundamentals of Transporting Hazardous Wastes. 1980.
44. Pohland, F.G. and Harper, S.R., Critical Review and Summary
of Leachate and Gas Production from Landfills. prepared for
EPA Office of Research and Development, May 1985.
45. Pope-Reid Associates, Inc., Assessment of £hjg. £a±e. of SQG
Hazardous Wastes in POTWsf prepared for EPA Office of Policy
Analysis, preliminary draft dated February 1985, and
associated worksheets and memos provided by PRA.
46. Research Triangle Institute, Regulatory Impact Analysis for
Characteristic Approach fro Regulation of 40 Organic
constituents,. Draft report, prepared for EPA Office of Solid
Waste, September 1984.
47. Sandia Labs, Severities of Transportation Accidents.
prepared for DOT Office of Hazardous Materials and ERDA
Division of Waste Management and Transportation, July 1976.
48. Sobotka & Co., Inc., Profile of Hazardous Waste Shipments,.
prepared for the U.S. Department of Transportation, February
22, 1985.
49. Temple, Barker, and Sloane, Inc., Economic Impacts of RCRA
Approaches to the Regulation of Generators of Small Volumes
of Hazardous Wastes. January 5, 1980.
50. Temple, Barker, and Sloane, Inc., Regulatory Impact Analysis
for Proposed Standards for the Management of Recycled Oil
(Draft 4QCFR266). Draft Report, prepared for EPA Office of
Solid Waste, October 26, 1984.
51. Transportation Research Board, National Academy of Sciences,
National Research Council, Transportation of Hazardous
Materials; Toward A. National Strategy. 2 vols., 1983.
B-5
-------
52. TRW, Technical Environmental Impacts of Various Approaches
for Regulating Small Volume Hazardous Waste Generators.
December 10, 1979.
53. U.S. Department of Transportation, Transportation Systems
Center, Risks of Hazardous Spills from Unmarked Packages or
Containers f September 1982.
54. U.S. EPA, Effluent Guidelines Division, Guidance Manual £p_r_
Electroplating and Metal Finishing Pretreatment Standards.
February 1984.
55. U.S. EPA Office of Solid Waste, Draft Environmental Impact
Statement on the Proposed Guidelines for the Landfill
Disposal fif. Solid Waste r 1979.
56. U.S. EPA, Office of Water Enforcement and Permits, Overview
of the National Pretreatment Program. September 1984.
57. U.S. General Accounting Office, Illegal Disposal
Hazardous Waate; Difficult to Detect or Deter. February 22,
1985.
58. Versar, Inc., and American Management Systems, Hazardous Air
Pollutants; Air Exposure and Preliminary Risk Appraisal for
i5. U.S. Counties,. Appendix F-3: "Treatment, Storage and
Disposal Facilities and Superfund Sites", prepared for EPA
Office of Policy Analysis, September 1984.
59. Westat, Inc.,, National Survey of Hazardous Waste Generators
and Treatment, Storage and Disposal Facilities Regulated
under RCRA jji 1981 f prepared for EPA Office of Solid Waste,
April 1984.
B-6
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APPENDIX C
DETAILED MANAGEMENT PRACTICES BY INDUSTRY AND WASTE
This Appendix presents detailed tabulations of the SQG
Survey results. Exhibits C-l through C-12 report management
practices by industry and Exhibits C-13 through C-l9 report the
same practices by waste. All of the industry data and data for
the vier largest-quantity waste streams were calculated using
percentages reported in the Survey Report (Reference 2), with two
exceptions described below. Results for the remaining waste
streams were estimated by lEc, based on tabulations of the number
of generators reporting each practice for each waste. The
distributions of quantities were adjusted to reflect differences
in the average quantities (for all wastes) managed by each
practice. Distributions for the remaining wastes were not
developed for storage or transportation practices.
The Survey Report data were adjusted by lEc as followsif (1)
Waste quantities were adjusted to exclude used lead-acid
batteries (see Chapter 3 for a discussion of the reasons for this
exclusion). (2) Storage values for total storage and storage for
less than 180 days (for both numbers of generators and waste
quantities) were calculated by lEc and represent minimum values/
due to limitations in the data available in the Survey Report.
Only two industry groups were surveyed for lead-acid
batteries: Vehicle Maintenance and Motor Freight Terminals. We
excluded lead-acid batteries from the waste quantities for each
practice in these two industries based on two assumptions:
(1) How a generator stores, transports and notifies
depends more on the generator than on the specific
waste. Therefore, we applied industry specific
percents to totals adjusted to exclude batteries,
to estimate quantities without batteries for each
practice.
(2) How a generator manages a waste (i.e. on- or off-
site, disposed or recycled, etc) depends more on
the waste type than on the generator or industry.
Therefore, we applied percents for batteries for
each practice to totals for batteries in each
C-l
-------
industry group, and subtracted from totals
including batteries for each practice to estimate
quantities without batteries for each practice.
It is not possible to determine from the Survey Report how many
generators would no longer be found to generate 100 to 1000 kg
per month due to the exclusion of batteries.
The figures for total storage and storage for less than 180
days numbers in this Appendix reflect minimum values (for both
number of generators and waste quantities). The Survey Report
does not distinguish between generators storing 1 to 7 days and
generators not storing (0 days). Therefore, lEc calculated
minimum number of generators storing and waste quantity stored by
summing the values for 8 to 90 days, 91 to 180 days, and over 180
days. Similarly,, we calculated minimum number of generators
storing (and waste quantity stored) for less than 180 days by
summing values for 8 to 90 days and 91 to 180 days. Numbers for
storage over 180 days are available directly from the Survey
Report. Therefore, the values in this Appendix for total storage
and storage for less than 180 days do not include generators
storing (and wastes stored) for 1 to 7 days, because they cannot
be seperated from generators not storing (and wastes not stored),
and thus understate the true values.
The following Exhibits are provided in this Appendix:
Exhibit C-l Summary: SQGs Generating >100 kg/month by Industry
Exhibit C-2 Overview of Management Practices by Industry
Exhibit C-3 On-site Management by Industry
Exhibit C-4 On-site Disposal by Industry
Exhibit C-5 On-site Treatment by Industry
Exhibit C-6 On-site Recyling by Industry
Exhibit C-7 Off-site Management by Industry
Exhibit C-8 Overview of Storage by Industry
Exhibit C-9 On-site Storage by Industry
Exhibit C-10 Off-site Storage by Industry
Exhibit Oil Transportation Methods by Industry
Exhibit C-12 Notification Methods by Industry
Exhibit C-13 Summary of Treatment Practices by Waste
Exhibit C-l4 Summary of Recycling Practices by Waste
Exhibit C-l5 Overview of Storage by Waste
Exhibit C-16 On-site Storage by Waste
Exhibit C-17 Off-site Storage by Waste
Exhibit C-l8 Transportation Methods by Waste
Exhibit C-19 Notification Methods by Waste
C-2
-------
EXHIBIT C-l
SUWWRY: SOGS GENERATING (100 KG/MONTH BY INDUSTRY
INDUSTRY
Pesticide End-Users
Pesticide Roohcators
Cheaical Manufacturing
Uood Preserving
Foraulators
Laundries
Other Services
Photography
Textile Manufacturing
Vehicle Maintenance
Equipment Repair
Metal Manufacturing
Construction
Motor Freight Terminals
Furniture Mfg/Refinish
Printing
Cln. Rgents/Coswtics
Other Manufacturing
Paper Industry
Laboratories
Education/Voc. Shoos
Uwlesaie/Retail Sales
TDTflL
NUMBER OF SEfCRflTORS
Nuiber Percent
1,660
391
107
395
2,515
2,409
2,817
124
82,528
269
11,076
1,117
45
579
3,420
265
946
83
1,286
241
575
.21
1.5*
.3*
.IX
.3*'
2.2*
2.1*
2.5*
.1*
73.0%
.2*
9.8*
1.0*
*
.5*
3. OX
.2*
.8*
.1*
1.1*
.2*
.5*
HASTE
MT/Year
918
6,451
2,223
688
2,145
8,272
6,891
16,095
602
48t899
650
58,159
2,974
59
3,100
13,178
1,454
4,871
4%
5,909
888
2,882
QUANTITY
Percent
.5*
3.4*
1.2*
.4*
1.1*
4.4*
3.7*
8.6*
.3*
26.0*
.3*
31.0*
1.6*
1.7*
7.0*
.8*
2.6*
.3*
3.1*
.5X
1.5*
113,079 100. OX 187,804 100. OX
AV. QUflNT./MONTH
(Kg/Month)
331
324
474
536
453
274
238
476
405
. 49
-201
438
222
109
446
321
457
429
498
383
307
418
138
Uaste quantities for Vehicle Maintenance and Motor Freight Teninals adjusted to exclude
lead acid batteries.
-------
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APPENDIX D
DESCRIPTION OF TRANSPORTATION AND STORAGE COST ANALYSIS
This appendix discusses the methodology and assumptions used
in developing the transportation and storage cost analyses
presented in Chapter 5. lEc developed this analysis to identify
factors likely to effect SQG compliance costs, and to assess the
combined effects of storage and transportation costs on SQGs1
decisions about shipment frequencies.
THE TRANSPORTATION COST MODEL
Collecting hazardous wastes from a single generator and then
taking this shipment to a TSDF is the most common scenario for
collection of LQG wastes by commercial transporters. I/ Most
transportation cost estimates or cost models developed previously
for EPA reflect this type of transportation. In the case of
collections from SQGs, transporters must usually make more than
one stop in order to fill up even a small truck. (The lEc model
assumes the use of a truck with a 30 drum capacity.) These
multi-stop collections are referred to as "milk runs". After
consolidating wastes at his site to achieve a full or nearly-full
truckload shipment, the transporter will typically run a large
stake truck to the TSDF, especially if the TSDF is located at a
significant distance from the transporter's site. The economics
of milk runs differ from those of a single collection-point
shipment of equivalent size for several reasons:
1. On a milk run, more time will be spent per ton of
waste shipped on "administrative" duties (at both
the generator's and the TSDF's site), such as
manifest handling and checking labels and
placards, because more manifests and generators
are involved.
I/ Tank trucks commonly used to transport liquid wastes hold
6,000 gallons, and stake trucks for transporting containerized
wastes typically hold 80 fifty-five gallon drums.
D-l
-------
2. There is likely to be more handling of the wastes
themselves in a milk run scenario, because
containers may be unloaded from a small truck and
placed onto a larger truck at the transporter's
site.
3. On a milk run, a small truck is likely to be used
to collect waste from the generators, and a larger
truck used for shipment to the TSDF, while
shipments from LQGs are likely to be transported
solely in a large truck.
4. On a milk run, each generator is responsible only
for the transportation costs which are directly
attributable to collecting his wastes, and for a
fraction (in proportion to the amount of the truck
his wastes utilizes) of the costs for delivery to
a TSDF, while the full amount of the costs
associated with the collection and delivery to the
TSDF is attributable to a single shipper in the
typical LQG case. Transporters' charges are
likely to reflect the generator's contributions to
the cost.
In general, then, on a milk run there are two cost compo-
nents: those associated with the milk run collections and those
associated with the trip to the TSDF. As discussed above, the
SQG is likely to be assessed the full amount of any costs solely
attributable to collecting and handling his shipment
(loading/unloading time, administrative duties, the portion of
costs for the collection run attributable to his stop, etc.), as
well as a portion of the costs of shipping wastes to the TSDF
(e.g. in proportion to the space which his wastes utilize on the
truck). Some transporters assess a fixed minimum charge for each
collection from SQGs, in addition to a per-mile fee, in order to
recover the fixed administrative and other costs associated with
each stop on a milk run. lEc's cost model does not assess mini-
mum charges per se, but reflects charges for administrative and
other duties by applying a per-hour charge for such activities.
In the transportation model, we assumed that milk runs would
be made in a truck with a capacity of 30 fifty-five gallon drums
and that trips to TSDFs would be made in a stake truck with a
capacity of 80 fifty-five gallon drums. Trucks are assumed to
travel at an average speed of 30 mph while on milk runs and 45
mph while traveling to the TSDF. Loading and unloading time was
D-2
-------
assessed based on the number of drums handled: 1 - 10 drums
incur a one hour fee; 11 - 20 drums incur a two hour fee; and 21
- 30 drums incur a three hour fee. (Since regulations allow SQGs
to store a maximum of 6000 gallons without a permit, no more than
30 drums are likely to be shipped at one time.) These charges
reflect the fact that the number of drums in a shipment affects
handling time. The model assumes that milk runs will not involve
any overtime charges (e.g., that they will be conducted within an
eight-hour day) and that shipments to the TSDF need not occur in
the same day as the milk run is made (since transporters can
store for up to 10 days without a permit). Shipments made to
TSDFs are assessed a premium charge in the cost model if the
round-trip distance to the TSDF cannot be traveled within one
eight-hour day.
The model can consider different truck capacity utilization
rates for the trip to the TSDF. Generators are assessed a por-
tion of the cost of the trip to the TSDF based on the size of his
shipment and the total capacity utilization of the truck. For
example, for a truck with an 80 drum capacity, a generator
shipping 20 drums will be assessed one-fourth of the cost of
running the truck to the TSDF if the truck is 100 percent
utilized (carrying 80 drums). If the truck carries a load of
only 40 drums (50 percent utilized), then a generator shipping 20
drums will be assessed one-half of the cost of running the truck
to the TSDF.
The actual costs used in the model are shown in Exhibit D-l
and are expressed in 1984 dollars. Capital and operating costs
differ for the different sizes of truck. The truck capital
costs, and the costs of the driver's salary, supervision,
licenses, insurance, and general and administrative cots are
annualized and calculated on a dollar per hour basis, based on
an assumed number of hours of use per year. (Long-distance
trucks have higher utilization rates because they are operated,
on average, more than eight hours per day, according to sources
in the commercial transportation industry.) Each transportation
scenario involves a fixed charge per hour for each hour that the
truck is traveling or in use for loading/unloading and admini-
strative duties. Operating costs include costs of fuel, tires,
maintenance and repair; these costs vary in proportion to the
number of miles traveled and are calculated based on the round-
trip distance to the TSDF and the distance traveled to each SQG.
General and administrative costs and a small profit rate are also
included in these costs, as described in the notes to Exhibit D-
1.
D-3
-------
The model can be run for SQGs with different generation
rates and for a different number of shipments per year. However,
the maximum shipment size is 6,000 kilograms and the minimum
number of shipments per year considered is 1.33 (once every 270
days) since a SQG cannot store more than 6,000 kilograms or for
longer than 270 days without a permit and we assume that SQGs
will not want to bear the costs associated with obtaining a
storage permit.
COMPARISON OF TRANSPORTATION AND STORAGE COSTS
lEc developed a comparison of transportation and storage
costs which incorporates the storage costs developed for the
compliance cost estimates discussed in Chapter 6. The
methodology allows comparison of storage and transportation costs
at different generation rates and shipment frequencies. As
discussed in Chapter 5, frequency of shipment affects annual
transportation costs per metric ton, in that more shipments for a
given quantity of waste results in higher annual transportation
costs due to the fixed cost of pickups. On the basis of
transportation costs alone, then, generators would seek to
minimize shipment frequencies. However, reducing the number of
waste shipments increases the length of time for which wastes are
stored, and the costs of such storage. Therefore, lEc developed
an analysis of the minimum annual costs for transportation and
storage, under different scenarios, and the number of shipments
and storage time associated with the minimum cost. The
comparison of storage and transportation costs serves two
purposes:
1. It indicates the optimal length of time for waste
storage and the optimal number of waste shipments
under different scenarios, and facilitates
comparison of costs incurred under different
scenarios; and
2. It indicates whether allowing SQGs to store for
extended time periods (180 or 270 days) will be
beneficial to the SQGs.
The estimated storage costs include two components: (1) the
cost of regulatory compliance (under options G-2 and F-2), and
(2) the costs of space used for storage. Actual costs and cost
assumptions are described in Exhibit D-2. The regulatory
D-4
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compliance costs used in the analysis reflect the annualized
costs developed by PRA. Estimates for space costs can be varied
to reflect approximate relative values of space in urban or rural
areas. In calculating total storage and transportation costs,
the cost to the generator of storage and pre-transportation
requirements and the price charged by the transporter were
considered. The optimal storage period (and optimal number of
shipments per year) is achieved when the combined storage and
transportation costs are minimized.
D-5
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EXHIBIT D-l
TRANSPORTATION ODST ASSUMPTIONS FOR SMALL QUANTITY GENERATORS
LONG HAUL TRUCK
Truck Capacity (kg)
Drum Capacity
Truck Capital Cost
Capital Recovery Factor
Annual Capital Costs
Driver's Salary
Supervision
Insurance
License & Taxes
General & Admin.
Profit
Other Fixed Costs
Total Fixed Costs
Hours of Truck Use
Fixed Cost/Hour
Fuel & Oil
Tires, Maint. & Repair
General & Adnin.
Profit
Variable Costs/Mile
CASE A Util. Rate (%)
CASE B Util. Rate (%)
OTHER FACTORS
Prenium Cost/Overnight
Short-Haul Speed (mph)
Long-Haul Speed (inph)
Drum Capacity (kg)
Loading Time (hours)
1
1 SHORT HAUL TRUCK
16,000
SO
85,000
15.49%
13,167
30,500
1,500
4,400
4,200
5,377
2,957
48,934
62,101
2,080
29.86
.24
.15
.04
.02
.45
100
50
50
30
45
200
1
1
I/I
4/1
1
1
VI
3/1
I/I
I/I
6/1
7/1
1
i
i
1
I
8/1
1
i
I
I/I
I/I
6/1
7/1
1
1
1
1
3/
3/
3/
5/
Truck Capacity (kg)
Drum Capacity
Truck Capital Cost
Capital Recovery Factor
Annual Capital Costs
Driver's Salary
Supervision
Insurance & Taxes
License
General & Admin.
Profit
Other Fixed Costs
Total Fixed Costs
Hours of Truck Use
Fixed Cost/Hour
Fuel
Tires & Lubrication
Maintenance
General & Admin.
Profit
Variable Costs/Mile
6,000
30
34,300
15.49%
5,313
18,000
1,500
4,200
200
2,921
1,607
28,428
33,741
1,600
21.09
.11
.04
.06
.02
.01
.24
2/
4/
3/
3/
2/
3/
6/
7/
9/
2/
2/
2/
6/
7/
-------
NOTES TO EXHIBIT D-l
I/ Based on estimates from Abkowitz, et.al., "Assessing the
Releases and Costs Associated with Truck Transport of
Hazardous Wastes," prepared for the Office of Solid Waste,
January 1984; adjusted to 1984 dollars and rounded.
2/ Based on estimates developed by Arthur D. Little, as reported
in Abkowitz, et. al.; adjusted to 1984 dollars and rounded.
3/ Based on transporter estimates.
4/ Based on 8 years, 5% real rate of return.
5/ Loading time is determined based on the number of drums
handled:
1-10 drums = 1 hour loading/unloading time
11 - 20 drums = 2 hours loading/unloading time
21 - 30 drums = 3 hours-loading/unloading time
Transporters report that for more than 30 drums, fork-lifts
and pallets will be used, so that loading times are not
likely to exceed three hours.
6/ General and aidministrative costs represent 10% of the total
annual costs.
7/ Profit is calculated as 5% of total annual costs.
8/ 40 hrs/wk. * 52 wks/yr. * 100% utilization (based on
transporter estimates).
9/ 40 hrs/wk. * 52 wks/yr. * 80% utilization (based on
transporter estimates).
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EXHIBIT D-2
COST ASSUMPTIONS USED TO DETERMINE
OPTIMAL STORAGE PERIODS*
SQG Profile
Distance to SQG 75 I/
Distance to Disposal Site (mi.) 200
Drum Capacity (kg) 200
Generation Rate (kg/mo) 500
Transportation Costs
Long Haul
Fixed Costs ($/hr) 29.86 2/
Variable Costs ($/mi.) .45 2/
Short Haul
Fixed Costs ($/hr) 20.28 2/
Variable Costs ($/mi.) .24 2/
Storage Costs (annualized)
<=180 days 1,226 3/
>180 & <=270 days 1,923 3/
>270 days 8,702 3/
Space Costs ($/sq. ft.) 10 I/
Space/drum (sq. ft.) 4
Space Cost/drum 40
Pre-Transportation Costs (annualized)
<=270 days 263 3/
>270 days 180 3/
NOTES:
* All costs are in 1984 dollars.
I/ This number varies, based on the SQG location
scenario under consideration (urban vs. rural).
2/ This number is based on the assumptions used
in lEc's transportation cost model.
3/ This number is derived from storage cost
estimates developed by ERA for the SQG economic
impact analysis. In cases where ranges of costs
were reported, midpoints were calculated and
used for the purposes of this analysis.
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