United States Solid Waste and EPA530-R-96-014
Environmental Protection Emergency Response PB96-190-707
Agency (5305W) June 1996
&EPA Cost and Economic
Impact Analysis of the
CESQG Rulemaking
Reproduced on Paper that Contains at least 20% Post Consumer Fiber
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of the CESQG ftulemaking
U.S. Environmental Protection Agency
Office of Solid Waste
June 1996
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CONTENTS
1. Introduction . . 1
2. Identification and Characterization of Affected Parties 3
2 1 Generators of CESQG Waste . ' 3
2.2 CESQG Waste Managers 7
2 3 Accounting For State Requirements 9
3. Methodology for Estimating Costs 11
3 1 Overview 11
3 2 CESQGs with On-Site Disposal in Subtitle D Units 11
3 3 Construction and Demolition Waste Generators 13
3.4C&D Waste Landfill Owners . . 15
35 "High-End" Cost Analysis If C&JD Landfills Upgrade 20
4. Results of the Cost Analysis 23
4.1 CESQGs with On-Site Disposal in Subtitle D Units 23
4.2 Construction Waste Generators 23
4 3 Construction and Demolition Landfills 23
4.4 Total Costs to the Economy . 24
4.5 "High-End" Costs If 1.62 C&D Landfills Upgrade . . . . . . 25
5 Limitations of the Cost Analysis . . 29
5 1 Overall Limitations in the Analysis 29
5 2 Limitations in the Analysis of Costs to CESQGS Using On-Site Management 29
5 3 Limitations in the Analysis of Costs to C&D Waste Generators . . 30
5 4 Limitaitons in the Analysis of Costs to C&D Landfills 30
6 Potential Impacts on Small Entities 32
6 1 Regulatory Flexibility Act and EPA Guidelines . . 32
6.2 General Approach 33
6 3 Results 34
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1. INTRODUCTION
This report presents a cost and economic impact analysis for revisions to the Criteria
for Classification of Solid Waste Disposal Facilities and Practices (40 CFR Part 257) and
Identification and Listing of Hazardous Waste (40 CFR Part 261). These revisions have been
developed by the U S. Environmental Protection Agency (EPA) in response to Sections
3001 (d)(4) and 4010(c) of the Resource Conservation and Recovery Act (RCRA), and an
agreement reached between EPA and the Sierra Club pursuant to a lawsuit filed by the Sierra
Club in October 1993.
The revisions apply to generators and managers of conditionally exempt small quantity
generator (CESQG) waste. CESQGs generate hazardous waste in quantities of no more than
100 kilograms (kg) per month, or acutely hazardous waste in quantities of no more than 1 kg
per month. CESQGs may accumulate no more than 1,000 kg of hazardous waste or 1 kg of
acutely hazardous waste at one time. Currently, CESQG waste may be managed at a
hazardous waste facility or at a Subtitle D facility that is permitted, licensed, or registered by
a State to manage municipal or industrial waste.
The revisions to Part 25/establish facility standards for non-municipal solid waste
disposal facilities that may receive CESQG wastes; they would not affect municipal solid
waste landfills (MSWLFs), which are subject to the criteria found in 40 CFR Part 258 The
revised facility standards would include location restrictions, groundwater monitoring, and
corrective action. The revisions to Part 261 require CESQGs to manage their wastes at
MSWLFs or at non-municipal solid waste facilities subject to the revised Part 257 facility
standards.
Executive Order No. 12866 (FR V 58 No. 170, 51735, October 4, 1993) requires that
regulatory agencies determine whether a new regulation constitutes a significant regulatory
action. A significant regulatory action is defined as an action likely to result in a rule that
may:'
Have an annual effect on the economy of $100 million or more or adversely affect in a
material way the economy, a sector of the economy, productivity, competition, jobs,
the environment, public health or safety, or state, local, or tribal governments or
communities;
Create a serious inconsistency or otherwise interfere with an action taken or planned
by another agency;
Materially alter the budgetary impact of entitlements, grants, user fees, or loan
programs or the rights and obligations of recipients thereof; or
Raise novel legal or policy issues arising out of legal mandates, the President's
priorities, or the principles set forth in Executive Order 12866.
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To meet the requirements of EO 12866, this report includes an estimate of the
incremental costs of the rule and its potential effects on small businesses.
This Cost and Economic Impact Analysis was originally presented in May, 1995, accompanying
the proposed rulemaking, this report replaces that version. Changes made in this final version
include
Revised labor rate
Revised overall costs of the rulemaking, m anticipated scenario and "high-end"
scenario.
Clarifications of methodology used
The'report is organized as follows:
Chapter 2 discusses the parties affected by this rulemaking;
Chapter 3 describes the methodology used for the cost analysis;
Chapter 4 presents the results of the cost analysis;
*
Chapter 5 discusses the limitations of the cost analysis; and
Chapter 6 discusses potential effects on small businesses.
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2. IDENTIFICATION AND CHARACTERIZATION OF AFFECTED PARTIES
EPA's revisions to 40 CFR Parts 257 and 261 will have the potential to affect both
generators of CESQG waste and owners and operators of non-municipal solid waste disposal
facilities in which CESQG wastes are managed. This chapter discusses the parties that may be
affected by the rulemaking. Section 2.1 characterizes the number of CESQGs and the
quantities of waste they generate nationwide. Section 2.2 characterizes the number of
CESQG waste managers and the quantities of waste they manage nationwide In Section 2 3,
the number of generators and waste quantities affected by the rulemaking are estimated by
adjusting the national numbers to account for the existence of state requirements similar to
those contained in the rule.
2.1 GENERATORS OF CESQG WASTE
According to the National Small Quantity Hazardous Waste Generator Survey
(National SQG Survey), 455,000 establishments nationwide generated 201,600 tons of
CESQG waste in 1982. About 80 percent of CESQGs and 88 percent of CESQG waste were
associated with the non-manufacturing sector, while the remainder was associated with the
manufacturing sector.
Only a small fraction of the nation's 455,000 CESQGs will be affected by EPA's
rulemaking, however, as many CESQGs currently manage their wastes in ways that are not
covered by the rule (e g , disposal in municipal solid waste landfills, recycling). As discussed
in Chapter 1, this rule would apply only to CESQG wastes disposed in land-based Subtitle D
units other than municipal solid waste landfills (MSWLFs)
Three types of CESQGs are potentially affected by this rulemaking:
CESQGs who dispose their CESQG wastes along with their non-hazardous
industrial wastes in on-site Subtitle D landfills, surface impoundments, land
application units, or waste piles;
CESQGs who send their wastes off site to commercial industrial Subtitle D waste
management facilities; and
CESQGs who send their wastes off site to construction and demolition (C&JD)
waste landfills. ,
These parties are discussed in more detail below.
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2.1.1 CESQGs with On-site Disposal in Subtitle D Units
Manufacturing Sector
In 1985, EPA conducted the Screening Survey of Industrial Subtitle D Establishments
(Screening Survey) While this is an old survey, it is the most recent source available for this
information. The Screening Survey focused on 17 industries in the manufacturing sector
believed to be responsible for most of the Subtitle D waste generation in the U.S It was
designed to develop national and industry-specific estimates of the number of establishments
managing industrial non-hazardous wastes on site, specifically in land-based units (landfills,
surface impoundments, land application units, and waste piles), and the volume of Subtitle D
waste managed in these units. The Screening Survey also captured information on CESQG
waste generation and management.
The Screening Survey estimated that 12,000 establishments managed industrial non-
hazardous waste on site in land-based units in 1985. An estimated 3,742 of these
establishments were also CESQGs, 605 of whom managed their CESQG wastes .on site in
Subtitle D land-based units. These 605 establishments used surface impoundments (309),
waste piles (135), land application units (91), and landfills (69). The distribution of these
605 establishments among the 17 manufacturing industries surveyed is shown in Exhibit 2-1.
For the purposes of this cost analysis, EPA is assuming that all 605 CESQGs will be
affected by the rulemaking. EPA believes that this figure overestimates the number of
CESQGs that co-dispose industrial non-hazardous process waste and CESQG waste in on-site
Subtitle D land-based units. Recent conversations with trade associations representing the
Stone, Clay, Glass, and Concrete Industry and the Food and Kindred Products Industry
(which together comprise almost half of the 605 CESQGs with on-site management) have
indicated that most facilities no longer manage their CESQG waste in on-site disposal units.
The Screening Survey does not provide information on the volume of CESQG waste
generated by these 605 establishments. For the purposes of this analysis, EPA has assumed
that each CESQG generates 50 kg/month of hazardous waste (the midpoint of the range of 0-
100 kg per month that defines a CESQG)'. Thus, the total amount of CESQG waste disposed
in on-site Subtitle D units annually is estimated to be 400 tons.
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EXHIBIT 2-1.
Number of CESQGs with On-site Management
in Subtitle D Land-based Units
INDUSTRY
Stone, Clay, Glass, Concrete
Food and Kindred Products
Textile Manufacturing
Primary Iron and Steel
Pulp and Paper
Rubber and Misc. Products
Petroleum Refining
Selected Chemical and Allied
Products
Primary Nonferrous Metals
Electric Power Generation
Water Treatment
Transportation Equipment
Fertilizer &. Agricult. Chem.
Plastics and Resins Manuf.
Organic Chemicals
Inorganic Chemicals
Leather and Leather Products
*
TOTAL
NUMBER OF
ESTABLISHMENTS
160
131
50-
48
43
30
28
25
24
22
15
15
5
4
3
2
0
605
Source Screening Survey of Industrial Subtitle D Establishments (Westat, 1987)
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Non-manufacturing Sector
The National SQG Survey reported that certain CESQGs in the non-manufacturing
sector also disposed of their wastes in on-site landfills in 1982. EPA views this finding with
caution, however, since the National SQG Survey did not define the term "solid waste
landfill" Moreover, more recent studies in the State of Washington and Montgomery
County, Maryland, showed that none of the CESQGs in these locations disposed of their
hazardous waste in an on-site solid waste landfill. This finding suggests that CESQGs have
changed their management practices with regard to on-site disposal in landfills since the
National SQG Survey was performed. For the purposes of this cost analysis, EPA has
assumed that no CESQGs in the non-manufacturing sector manage their wastes in on-site
disposal facilities.
2.1.2 CESQGs with Off-site Disposal in C&D Landfills
Debris generated from the construction and demolition of structures such as buildings,
roads, and bridges may contain small quantities of materials that may meet the definition of
RCRA hazardous waste. Examples include excess materials used in construction and their
containers (e.g., adhesives, paints, roofing cement), waste oils, and other discrete items such as
batteries and mercury switches. Thus, firms involved in the construction or demolition of
structures are potentially affected by this rulemaking. EPA believes there to be approximatelv
194,000 construction firms (157,000 building contractors and 37,000 heavy construction
contractors) and 1,240 demolition firms in the U S.l Only a portion of these firms will be
affected by this rulemaking. Only those generating RCRA hazardous waste below the CESQG
threshold an4 currently sending this waste to a C&D landfill will be affected.
There is considerable uncertainty associated with the quantity of waste generated by
the construction and demolition of structures. Though an estimate of approximately 30
million tons per year has often been cited,2 this figure is clearly an underestimate of C&D
generation because it includes only the volume that had been sent to MSW landfills Recent
literature3 suggests that the quantity is more in the area of 100 million tons per year.
As will be discussed in Chapter 3, the compliance costs of the rule depend on the
proportion of C&D waste that is generated from construction vs. demolition activities. Again,
very little information was found in the literature. A survey of C&D waste generation in the
' 1987 Census of Construction Industries.
2 Characterization of Municipal Solid Waste in the United States, I960 to 2000, prepared for the U S
Environmental Protection Agency by Franklin Associates, July 1986.
3 An estimate that over 110 million tons of C&D waste are generated annually was provided by Mr
Lee Adelman, Waste Management Inc , proceedings of 1992 World Recycling Conference, June 2,
1992 An estimate that 80 to 120 million tons of C&D waste are generated each year is provided in
"C&D Debris Recycling, The Forgotten Goal?", C&D Debris Recycling, October 1994.
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European Community4 indicates that construction debris comprises 18 percent of C&D
waste, and demolition debris 82 percent Applying these percentages to the estimated 100
million tons of C&JD waste generated annually provides the following waste generation rates
Construction debris- 18 million tons
Demolition debris: 82 million tons
2.2 CESQG WASTE MANAGERS
Many types of Subtitle D solid waste facilities may be used for the disposal of CESQG
waste Manufacturing facilities that co-dispose industrial non-hazardous and CESQG waste
in on-site waste management units are one type of facility; these were discussed in Section
2 1 1 This section focuses on Subtitle D facilities that may receive CESQG waste from off
site (other than municipal solid waste landfills which are not subject to this rulemaking)
2.2.1 Commercial (Off-site) Subtitle D Industrial Waste Facilities
One type of facility that may receive CESQG waste is a commercial facility that co-
disposes industrial non-hazardous wastes and CESQG hazardous wastes received from off site
EPA estimates that there are 10 to 20 such facilities in the U S. (excluding commercial
facilities that also receive municipal solid wastes). Through meetings with trade associations
representing the commercial solid waste industry , EPA has found that CESQG disposal is
generally prohibited at these types of facilities. This is a result of permitting conditions as
well as decisions at the corporate level of individual companies not to accept CESQG waste
Industry representatives also indicate that these facilities already meet or exceed the
requirements outlined in this rulemaking. For the purposes of this cost analysis, therefore,
EPA has assumed that no commercial Subtitle D industrial waste facilities will be affected
2.2.2. Construction and Demolition Landfills
EPA estimates that 1,889 CSdD landfills receive wastes from off site in the U.S for
the purposes of this analysis, EPA assumed that these 1,889 landfills receive all of the C&D
4 Demolition and Construction Debns, Questionnaire About an EC Priority Waste Stream, European
Demolition Association, the Netherlands (undated)
5 List of Industrial Waste Landfills and Commercial and Demolition Waste Landfills, prepared by Eastern
Research Group, [nc , for the Office of Solid Waste, September 1994. In addition, there are an
unknown number of on-site CSdD landfills used for the disposal of CSdD waste generated at a
particular site These are typically closed following completion of the activity. Because these sites are
on privately-owned land and receive only waste generated at that site, little information exists on the
number of these landfills nationwide. On-site C&JD landfills are not considered in this cost analysis
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waste generated in the U.S.6 Exhibit 2-2 shows the estimated size distribution and average
capacity of these landfills EPA's approach for deriving the information presented in Exhibit
2-2 is explained below
The only information available on the size distribution of C&D landfills is the 1986
Subtitle D Study Phase I Report.7 According to this report, there were 2,586 C&D landfills
in existence in 1986, with the following the size distribution:
36 percent received > 500 tons per day;
21.7 percent received 30 to 500 tons per day;
74.7 percent received < 30 tons per day.
EXHIBIT 2-2.
Estimated Size Distribution and Capacities of the Nation's 1,889 C&D Landfills
SIZE
Large
Medium
Small
TOTAL
WASTE
ACCEPTANCE
RATE (tons per
day)
>500 tpd
30 - 500 tpd
<30 tpd
ASSUMED
ACCEPTANCE
RATE (tons
per day)
1 ,000 tpd
265 tpd
15 tpd
NUMBER
OF
LANDFILLS
97
600
1,192
1,889
For small and medium C&JD landfills, EPA assumed an average acceptance rate midway
between the lower and upper-bound waste acceptance rate for each size category For large
C&D landfills, EPA assumed an average acceptance rate of 1,000 tons per day. Although
there is no theoretical upper-bound waste acceptance rate for large C&D landfills, the
weighted average acceptance rate is likely to be closer to the 500 tons per day lower bound
because there are very few extremely large C&D landfills. Multiplying the number of landfills
in each size category by the tpd received yields an estimated annual C&D waste quantity
that is very close to the 100 million tons estimated for today. EPA therefore believes that the
acceptance rates presented in Exhibit 2-2 are a reasonable assumption for this analysis
Because the number of C&D landfills has decreased since 1986 (from 2,586 to 1,889)
6 The 100 million tons of C&D "waste" estimated in the literature is assumed to reflect the quantity
remaining after recycling. According to OSW's MSWLF survey, MSWLFs received 18 million tons of
C&D waste in 1985. The quantity sent to MSWLFs is assumed to be lower today, given the capacity
problems faced by MSWLFs. For this cost analysis, EPA has assumed that MSWLFs today receive an
insignificant portion of discarded C&D waste, and that all 100 million tons are sent to C&D landfills
This is a conservative assumption whose likely effect is to overestimate compliance costs.
7 U S EPA, Office of Solid Waste, Subtitle D Study - Phase I Report, October 1986
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while the estimated amount of waste disposed has remained essentially the same, EPA has
assumed that the size distribution of C&D landfills has shifted. Specifically, EPA has
assumed that the .number of mid-sized and large C&D landfills has increased, while the
number of small C&D landfills has decreased to a greater extent, resulting in a net decline in
the total number of C&D landfills. Exhibit 2-2 reflects EPA's revised estimate of the current
size distribution of the nation's 1,889 C&D landfills.
2.3 ACCOUNTING FOR STATE REQUIREMENTS
Many states have location restrictions, groundwater monitoring requirements, and/or
corrective action requirements in place for C&D landfills. This section explains how the
existence of these state requirements was accounted for in the national cost analysis. EPA did
not account for state requirements in the estimation of compliance costs for non-C&JD
CESQGs because the affected volumes and compliance costs for non-C&D CESQGs are
minimal.
EPA conducted a study of state regulatory requirements for C&D landfills in 1994 and
found that 24 states prohibit C&D landfills from receiving CESQG wastes. Of the 26
remaining states, eight have mandatory groundwater monitoring and corrective action
requirements at C&D landfills. EPA assumed that C&D landfills and C&D waste generators
located in these 32 states will be unaffected by the rulemaking.
Of the eight states that require both groundwater monitoring and corrective action at
C&D landfills, some states' groundwater monitoring requirements are less stringent than
specified in the revisions to Part 257 EPA's assumption that landfills in these states will be
unaffected by the rule may lead to an underestimate of compliance costs. On the other hand,
some landfills located in the 18 states assumed to be affected by the rule have groundwater
monitoring requirements without corrective action requirements. In this case, EPA's analysis
overestimates compliance costs for these landfills , by assuming that they will incur the full
costs of complying with the Part 257 requirements even though they are already required to
incur the costs of groundwater monitoring. EPA believes that these biases are, for the most
part, offsetting.
As discussed above, EPA assumed that there would be no compliance costs for C&D
waste generators or managers in any of the 32 states. EPA then calculated the number of
C&D landfills and quantity of waste in the 18 remaining states (referred to in the remainder
of this report as the "affected" states). According to a recent study conducted for the Office of
Solid Waste8, there are"718 C&D landfills in the affected states. To estimate the number of
C&D waste generators and the quantity of C&D waste generated in the affected states, EPA
apportioned the number of generators and quantity of waste to each state based on
population. Using this approach, EPA estimates that about 28 percent of all C&D waste
generators are located in the 18 affected states, and that they generate 28 percent of all C&D
wastes, or 28 million tons.
3 List of Industrial Waste Landfills and Commercial and Demolition Waste Landfills, prepared by Eastern
Research Group, Inc , for the Office of Solid Waste, September 1994.
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The next step was to apportion the 28 million tons of waste in the affected states to
the 718 C&JD landfills present in these states. Lacking any other data, EPA began by
assuming that in affected states, both the percent distribution of landfills across the size
categories and th£ average acceptance rate in each size category are the same as in the nation
as a whole EPA found, however, that these assumptions do not yield a waste generation rate
of 28 million tons per year in the affected states. Therefore, EPA adjusted the average
acceptance rates in each size category downward to reflect the lower average population per
landfill in the affected states (since demolition debris is assumed to be correlated with
population) EPA also divided the "medium" size category in half to allow for more detailed
analysis. The results, shown in Exhibit 2-3, were used as the basis for estimating compliance
costs in affected states.
EXHIBIT 2-3
Estimated Size Distribution and Capacities of the 718 C&JD Landfills in Affected
States
SIZE
Large
Medium
Small
TOTAL
WASTE
ACCEPTANCE RATE
(tons per day)
>500 tpd
500 - 265 tpd
265-30 tpd
<30 tpd
ASSUMED
ACCEPTANCE
RATE (tons per
day)
738 tpd
282 tpd
109 tpd
11 tpd
NUMBER OF
LANDFILLS
37
114
114
453
718
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3. METHODOLOGY FOR ESTIMATING COSTS
This chapter discusses EPA's methodology for estimating the national compliance costs
of the rulemaking. The chapter begins with an overview of the methodology, and then
presents a detailed approach for each type of affected party.
3.1 OVERVIEW
EPA estimated the national costs of this rulemaking to waste generators and managers
in 18 affected states. To estimate national costs, EPA first identified the compliance options
available to each affected party EPA then selected the compliance practice or practices likely
to be selected by each party based on technical feasibility, cost, and other factors. The next
step was to estimate the per-ton unit costs associated with each compliance practice; this was
based on information available in the literature or obtained through selected telephone
contacts with representatives of the C&D industry. National costs were estimated by
multiplying the per-ton costs of each compliance practice by the number of tons of waste
affected.
As will be discussed in more detail later in this chapter, EPA believes that compliance
behavior under this rule will favor separation of the small amounts of hazardous waste from
the bulk of the affected waste, with disposal of the hazardous components in a MSWLF or
Subtitle C facility EPA believes that the alternative scenario C&D landfill owners upgrade
their landfills to accept non-hazardous waste mixed with CESQG waste, and recover the costs
by charging higher tipping fees to waste generators would be more expensive to waste
generators than separating their wastes. If generators choose to separate wastes rather than
use upgraded landfills, there will be no demand for upgraded landfills, and landfill owners will
be unlikely to recover their upgrading costs through higher tipping fees. Thus, EPA's estimate
of national costs is based on the assumption that no C&JD landfills will upgrade in response to
this rulemaking. For the reader's information, EPA has also included at the end of this
chapter a "high-end" analysis of national costs if some C&D landfills do, for some reason, opt
to upgrade.
The next three sections discuss EPA's methodology for estimating national compliance
costs for each affected party.
3.2 CESQGS WITH ON-SITE DISPOSAL IN SUBTITLE D UNITS .
3.2.1 Compliance Practices
Manufacturing facilities with on-site land-based management will have three
compliance options under the rule:
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1 Upgrade the on-site units to meet the revised Part 257 requirements;
2 Separate the hazardous portion of the waste from the non-hazardous portion
SencfTTTe hazardous portion off site to a Subtitle C facility or a municipal solid
waste landfill (MSWLF), and continue disposing the non-hazardous portion on
site; or
3. Do not separate the hazardous portion of the waste from the non-hazardous
portion. Send all of the waste off site to a Subtitle C facility or a MSWLF
EPA contacted a small sample of firms in two industry sectors representing a large
proportion of CESQGs with on-site Subtitle D land disposal units: the Stone, Clay, Glass and
Concrete industry, and the Food and Kindred Products Industry. Representatives of both
industries reported that industry practice is to keep hazardous wastes separate from non-
hazardous wastes. If this is true of the ,other industries as well, the costs of separating
hazardous wastes from non-hazardous wastes are negligible, and option 2 is the least-cost
compliance option. The incremental costs of option 2 are only those associated with sending
the hazardous portion of the waste off site, which is less expensive than sending all of the
waste off site (option 3), or bringing on-site units into compliance with the Part 257 revisions
(option 1)
For costing purposes, EPA assumed that under option 2, the hazardous portion of the
waste would be sent to a Subtitle C facility. According to EPA's Municipal Solid Waste
Landfill Survey, in 1985 over 70 percent of MSWLFs explicitly refused to accept CESQG
waste. However, under today's rule, sending the CESQG waste to a MSWLF or upgraded
landfill would be acceptable as well.
3.2.2 Unit Costs
As noted above, the costs of separating out hazardous wastes were assumed to be
negligible or zero, as were the costs associated with continuing to dispose of the non-
hazardous portion of the waste on site.
There will be incremental costs for sending the CESQG wastes off-site for disposal.
While the generators have the option of sending the CESQG waste to a Subtitle C landfill,
MSWLF or upgraded C&D landfill, EPA used the most costly alternative for the purposes of
this analysis, i.e., sending the waste to a Subtitle C landfill. This scenario is not unreasonable,
since many MSWLFs choose not to accept CESQG wastes and there may not be an upgraded
C&JD landfill available nearby. The cost of pick-up and disposal of CESQG waste may vary
For the purposes of this analysis, EPA used an estimated cost of $430/ton.9 However, since
9 Because the volumes involved would be quite small, EPA has kept its analysis of the costs of
disposing these wastes simple A standard construction cost estimating guide provided a range of S130
to $300 per ton (with a midpoint of $215 per ton) for pickup and disposal of hazardous waste. Mean's
Construction Cost Estimating Guide, p. 25, 1991 This source did not indicate how the cost per ton might
be affected by the volume of wastes to be picked up. If costs per ton are higher for small quantities
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there is such a low volume of CESQG waste generated, fluctuations in this cost will not
dramatically affect national cost estimates.
3.2.3 National Costs
To estimate national costs incurred by the 605 CESQGs with on-site disposal in
Subtitle D units, EPA simply multiplied the estimated 400 tons of CESQG waste '° by the
estimated pickup and disposal cost of $430 per ton EPA has not adjusted the costs incurred
by these generators to account for state requirements that may be as stringent as those
imposed by this rulemakmg.
3.3 CONSTRUCTION AND DEMOLITION WASTE GENERATORS
EPA believes that construction waste generators will be affected by this rulemakmg,
but that demolition waste generators will not. Road and bridge demolition waste will be
unaffected because it typically does not contain CESQG waste. While there may be CESQG
types of wastes in buildings, EPA assumed that building demolition waste will not need to go
to an upgraded landfill. EPA assumed that a decision on the nature of building demolition
waste would occur once the building had been demolished. If the waste was determined to be
hazardous, the volumes would be far beyond the CESQG levels. Otherwise, if the waste is
determined to be non-hazardous, it would not need to go to an upgraded landfill
3.3.1 Compliance Practices
Construction waste generators who currently send their waste to a C&D landfill that is
not in compliance with the revisions to Part 257 will have two options:
I Separate the hazardous portion of the waste from the non-hazardous portion and
send the hazardous waste to a MSWLF, a C&D landfill that has been upgraded to
be in compliance with the Part 257 revisions (an "upgraded C&D landfill"), or a
Subtitle C facility; or
2 Do not separate the hazardous portion of the waste from the non-hazardous
portion, and send all of the waste to a MSWLF, an upgraded C&D landfill, or a
Subtitle C facility.
The compliance option that construction firms will select will depend on several
factors, such as the feasibility and cost associated with separating the hazardous from the non-
due to fixed costs of hiring a truck and dnver, the true costs of disposal would be higher While EPA
assumes that the midpoint of the reported costs, $215 per ton, is a reasonable assumption, for the
purposes of this analysis, a cost twice that amount, $430 per ton, was used. This cost is significantly
higher than the reported range, and will capture some of the uncertainty about increased costs due to
small volumes However, because the volumes involved are quite small, even a doubling of the
midpoint cost (from $215 to $430 per ton) does not significantly affect nauonal costs
10 See Section 2 1 1
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hazardous components of the waste; whether or not the waste will be accepted at a MSWLF,
the costs to transport the waste from the point of generation to the disposal site; and the
tipping fees charged by the different types of landfills.
EPA assumed that generators of construction waste would choose option 1 According
to the National Association of Demolition Contractors (NADC) ", it is relatively easy to keep
the hazardous components of construction waste (e.g , paints and solvents) separate from the
non-hazardous components. EPA believes that it will be less expensive for construction waste
generators to separate out the hazardous portion of construction waste and send it off site '
(option 1) than to send all of the waste off site (option 2). MSWLFs are unlikely to accept all
of this waste, given the capacity problems that many of them face. As will be discussed in
section 3.4.3 of this report, even if some C&D landfills choose to upgrade, the upgrading costs
are likely to be passed along to the waste generators, making disposal in an upgraded C&D
landfill expensive relative to the costs of option 1.
While generators will have the option of sending CESQG waste to MSWLFs or
.upgraded facilities, for costing purposes, under option 1, EPA assumed the CESQG waste
separated from construction waste will be sent to a Subtitle C facility, as was assumed for
CESQG separated from industrial non-hazardous waste (see Section 3.2.1).
«
3.3.2 Unit Costs
As noted above, EPA has assumed that construction waste generators will separate out
the hazardous portion of the waste and send it to a Subtitle C facility and keep sending the
non-hazardous portion to the non-upgraded C&D landfill they used prior to the rule.
EPA assumed that at most small construction sites, there would be no incremental
costs of separating out the CESQG wastes. It is assumed that CESQG waste would be
separated during routine site clean-up activities and disposed of in a container near the non-
hazardous waste dumpsters on site. The cost of this separation is assumed to be negligible.
For heavy construction establishments 12, EPA assumed that an unskilled worker at $17 32
per hour 13 would inspect sites and pick-up CESQG wastes periodically. One hour per week
per establishment was assumed for a yearly cost of $901 per establishment.
Incremental costs for the pickup and disposal of the CESQG wastes which are
separated out was assumed to be the same as for generators with on-site disposal. As
discussed in section 3.2.2., a unit cost of $430 per ton was used.
1' Telephone communication with Mike Taylor, Executive Director, NaUonal Association of
Demolition Contractors, September 19, 1994.
12 Where each "establishment" represents a group of job sites.
13 ($11 57 per hour for laborer with an approximate overhead rate of 1.5) Source for wage rate
Bureau of Labor Statistics.
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3.3.3 National Costs
The national costs of the rule for generators of construction waste are the sum of the
costs for (1) separating the hazardous and non-hazardous components of construction waste,
and (2) sending the hazardous portion off site to a Subtitle C facility
To estimate the national cost of separating out CESQG wastes, EPA multiplied the
estimated number of heavy construction establishments by the incremental cost per facility of
inspecting major sites to ensure CESQG wastes are separated. The 1987 Census of Construction
Industries reports there are approximately 37,000 heavy construction establishments in the
United States. This would work out to be approximately 10,000 heavy construction
establishments in the affected states. It was estimated that these establishments incur an
incremental separation cost of $901 per year.
To estimate the national costs of sending the hazardous portion of the waste to a
Subtitle C facility, EPA multiplied the quantity of hazardous waste separated from
construction waste by the transportation and disposal cost of $430 per ton. According to the
National Small Quantity Hazardous Waste Generator Survey, 2,270 tons of hazardous
construction waste are generated each year nationwide; this translates to 636 tons tn affected
states.
EPA assumed that there would be no increase in costs for disposing the non-hazardous
portion of construction wastes: these wastes are assumed to go to the same C&D landfill, and
to be charged the same tipping fee, as before the rule.
3.4 C&D WASTE LANDFILL OWNERS
3.4.1 Compliance Practices
Construction and demolition waste landfills that are not currently in compliance with
the Part 257 revisions may respond to the regulation in one of two ways:
\
1 Choose not to upgrade, and accept only C&D waste that does not contain
hazardous waste.
2. Upgrade and accept all C&D waste.
C&D landfill owners who choose not to upgrade may only receive C&D waste that
does not contain hazardous waste. EPA assumes that C&D landfills that choose not to
upgrade (option 1) will take steps to ensure that CESQG waste is not disposed of in their
landfills.
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C&D landfill owners who choose option 2 will upgrade the landfill to come into
compliance with the Part 257 revisions. EPA assumes that C&D landfill owners will choose
this option if they believe that it will be profitable to do so. In making this decision, they will
consider the cosw-ef upgrading, the additional tipping fees they would have tot charge waste
generators to recover these costs, and the extent to which waste generators would be willing to
pay the increased tipping fees Those waste generators with less expensive alternatives (e g.,
separation and disposal in a Subtitle C facility) would be likely to avoid paying the additional
tipping fees, and landfill owners would lose business. If landfill owners believe that most of
their customers will be unwilling to pay tipping fee increases large enough to cover the costs of
upgrading, they will probably choose not to upgrade.
Section 3.4.2 presents the units costs of each option, and Section 3.4.3 discusses the
number of landfills nationwide that EPA expects to select each option.
3.4.2 Unit Costs
Spot Checking Costs
C&D landfills that choose not to upgrade (option 1) will take steps to ensure that
CESQG waste is not disposed of in their landfills. C&D landfill owners are expected to
include in their contracts with haulers a clause specifically forbidding CESQG waste, and to
perform spot checks of the waste entering the facility. Based on conversations with the
National Association of Demolition Contractors (NADC),14 EPA assumed that an unskilled
worker would spend one hour a day spot checking the waste entering the facility to assure that
no CESQG waste is being disposed. At $17 32 per hour and 260 days per year, the resulting
annual cost per facility would be $4,500.
Upgrading Costs
C&D landfills owners that choose to upgrade (option 2) must first meet the location
restrictions (to be eligible to upgrade) and will then need to comply with the groundwater
monitoring and corrective action requirements.
Location Criteria:
Criteria that apply to existing landfills address floodplains; the revisions to Part 257
only add demonstration requirements for facilities located in floodplains or wetlands. EPA
has not included costs for location-related demonstrations in this cost and economic impact
analysis because these costs are expected to be small relative to the other costs of the'rule
'4Mike Taylor, Executive Director, National Association of Demolition Contractors, telephone
communication, February 14, 1995.
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Groundwater Monitoring:
The groundvvater monitoring requirements of the rule are similar to those imposed on
MSWLFs undef-Part 258 To estimate the costs for C&D landfills to comply with these
requirements, EPA used the costs estimated for existing MSWLFs to comply with the Part
258 groundwater monitoring requirements. The RIA for the MSWLF criteria revisionsI5
provides per-ton groundwater monitoring costs for each of seven MSWLF sizes (ranging from
10 to 1,500 tons per day), two post-closure care periods (10 years and 40 years), and two
assumptions concerning the duration of the remaining active life over which monitoring costs
can be amortized (10 years and 20 years). EPA used these costs to calculate per-ton
monitoring costs associated with a 30-year post-closure care period (the duration required
under the Part 257 revisions) and an assumed 15-year remaining active life for each size class
EPA then fit a smooth curve to these cost estimates to generate a simple function relating per-
ton monitoring costs to landfill size. This function was then used to estimate per-ton
monitoring costs for all but the smallest C&D landfill size category shown in Exhibit 2-3 (EPA
assumed that the smallest C&D landfills would not choose to upgrade because the per-ton
costs would be prohibitive). Typical groundwater monitoring costs for landfills in each size
category are shown in Exhibit 3-1 (per-ton costs are rounded).
EXHIBIT 3-1.
Groundwater Monitoring Costs for Different C&D Landfill Size Categories
SIZE
Large
Medium
Small
WASTE
ACCEPTANCE
RATE
(tons per day)
>500 tpd
500 - 265 tpd
265 - 30 tpd
<30 tpd
ASSUMED
ACCEPTANCE
RATE
(tons per year)
269,000 tpy
103,000 tpy
40,000 tpy
4,000 tpd
MONITORING
COSTS
(per ton)
51 01
$208
S3 97
NA
ANNUAL
MONITORING
COSTS
(per landfill)
$271.000
$214,000
5158,000
NA
Note Numbers are rounded
Corrective Action:
EPA used a similar approach to estimate corrective action costs for C&D landfills. The
RIA for the MSWLF criteria revisions provides information on the proportion of existing
MSWLFs that trigger corrective action in each of three landfill size'categories and .four
environmental settings, and provides per-ton corrective action costs for each landfill size and
environmental setting These per-ton costs were based on an assumed remaining life of 10
years.
IS
Regulatory Impact Analysis for the Final Criteria for Municipal Solid Waste Landfills, Prepared for EPA's
Office of Solid Waste, December 1990
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To apply these costs to C&D landfills, EPA adjusted them to reflect a 15-year
remaining life Otherwise, the clean-up technologies and per-ton clean-up costs for C&D
landfills that trigger corrective action are assumed to be the same as for MSWLFs of similar
sizes and in similar environmental settings. Based on the assumption that the distribution of
C&D landfills across the environmental settings is the same as MSWLFs, EPA calculated an
average per-ton corrective action cost for each size category. As with groundwater monitoring
costs, EPA fit a smooth curve to these cost estimates to generate a simple function relating
per-ton corrective action costs to landfill size. This function was then used to estimate per-
ton corrective action costs for landfills that trigger corrective action in all but the smallest of
the four C&D landfill size categories shown in Exhibit 2-3. Typical corrective action costs for
landfills in each size category are shown in Exhibit 3-2 (per-ton costs are rounded).
1 EXHIBIT 3-2.
Corrective Action Costs for Landfills that Trigger Corrective Action by C&D Landfill
Size Category
SIZE
Large
Medium
Small
WASTE
ACCEPTANCE
RATE (tons per
day)
>500 tpd
500 - 265 tpd
265 - 30 tpd
<30 tpd
ASSUMED
ACCEPTANCE
RATE (tons per
year)
269,000 tpy
103,000 tpy
40,000 tpy
4,000 tpd
CORRECTIVE
ACTION
COSTS
(per ton)
$104
Si 64
$2.78
NA
CORRECTIVE
ACTION COSTS
(per landfill that
triggers)
S280.000
$168,000
$110,000
NA
Note numbers may not add due to rounding
3.4.3 National Costs
To calculate the national costs of the rule, EPA first estimated the number of C&D
landfills that would upgrade to come into compliance with the Part 257 revisions. To do this,
EPA compared (1) the per-ton costs that waste generators would incur in separating out the
hazardous portion of their waste and sending it to a Subtitle C facility, to (2) the increased
tipping fees that C&D landfills would charge waste generators to recover the costs of
upgrading Presumably, if the costs to the waste generator under (2) exceeds that under (1),
the C&D landfill industry would, by and large, choose not to upgrade.
As discussed in Section 3.3.3, EPA estimates that it will cost generators of heavy
construction waste $901 per establishment to see that hazardous waste is separated.
Multiplying this per-establishment cost by 10,000 heavy construction establishments gives a
national cost of $9,010,000 for separating hazardous waste. It will cost construction waste
generators $430 to dispose of each ton of separated hazardous .waste. Multiplying this unit
cost by 636 tons of hazardous waste gives a national cost of $273,480. Thus, the total
national cost to construction waste generators under this scenario is $9,283,500. Dividing
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this national cost by the number of tons of construction waste generated in the affected states
(18 percent of 28 million tons, or 5,040,000 tons) gives an average per-ton
separation/disposal cost of Si 79
Tn 16
Exhibits 3-1 and 3-2 show the per-ton costs for groundwater monitoring and corrective
action for landfills that choose to upgrade. In Exhibit 3-3, these costs are combined to show
the per-ton costs of upgrading landfills in different size categories, both for landfills that
trigger corrective action and those that do not. If these costs are passed along equally to all
users of the upgraded landfill construction and demolition waste generators alike then
the increase in tipping fees would be equal to those shown in Exhibit 3-3. However, as noted
before, demolition wastes are assumed not to be CESQG wastes. Thus, demolition waste
generators are not affected by this rulemaking and will probably be unwilling to pay these
added tipping fees. If the upgrading costs are passed along only to the construction waste
generators, the increased tipping fees would be distributed across the 18 percent of C&D
waste generated by the construction industry, (1 / 0.18) or 5 6 times higher than those
reflected in Exhibit 3-3.
EXHIBIT 3-3.
Per-ton Costs of Upgrading C&D Landfills
(Ground-water Monitoring and Corrective Action)
SIZE
Large
Medium
Small
ASSUMED
ACCEPTANCE
RATE (tons per
day)
>500tpd
500 - 265 tpd
265-30 tpd
<30 tpd
COSTS FOR
LANDFILLS THAT
DO NOT TRIGGER
CORRECTIVE
ACTION (per ton)
S1.01
$2.08
$3.97
NA
COSTS FOR
LANDFILLS THAT
TRIGGER
CORRECTIVE
ACTION (per ton)
$2.05
$3.72
$6.75
NA
Based on this analysis, EPA assumed for the purposes of this analysis, that overall, the
least cost response to this rulemaking will be comprised of (1) separation and Subtitle C
disposal of hazardous waste on the part of construction waste generators, and (2) avoiding
receipt of CESQG wastes (no upgrading) on the part of C&D landfill owners.
Under this assumption, the only costs to C&D landfill owners will be those associated
with spot checking the waste entering the facility to assure that no CESQG waste is being
disposed To calculate national costs for this activity, EPA multiplied the per-landfill cost of
$4,500 bv the total number of landfills in the affected states (718).
l6The per-ton costs would be higher than this amount for firms that conduct inspections to assure that
hazardous waste is screened out (in this analysis, firms that,conduct heavy construction), and lower
than this amount for construction firms that do not. The $1.79 per-ton cost is a national average
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3.5 'HIGH-END" COST ANALYSIS -- IF C&D LANDFILLS UPGRADE
,\Jthough in the least cost of compliance scenario, no C&D landfills are expected to
upgrade in respojse to this rulemaking, EPA conducted an analysis to estimate "high-end"
costs if some landfills choose to do so. This scenario changes the national costs of the rule for
construction and waste generators and managers, as described below
3.5.1 C&JD Landfill Owners
The unit costs of upgrading C&D landfills to come into compliance with the Part 257
revisions are presented-in Exhibits 3-1 and 3-2. Calculating the national costs associated with
upgrading required an estimate of the number of landfills that upgrade under the hypothetical
"high-end" scenario.
I
EPA assumed that the larger C&D landfills with greater remaining capacity would
upgrade, and that the smaller C&D landfills with less remaining cap acity would not.
Therefore, EPA assumed that all of the landfills in each of the two largest size categories
would upgrade (37 landfills in the >500 tpd category and 114 landfills in the 265-500 tpd
category) EPA also assumed that 19 landfills in the 30-265 tpd category would upgrade 17
To calculate the national costs of groundwater monitoring for these 170 landfills, EPA simply
multiplied the number of upgrading landfills in each size category by the appropriate per-
landfill groundwater monitoring cost shown in Exhibit 3-1. A similar approach was used to
calculate corrective action costs, although here it was also necessary to estimate the number of
upgrading landfills that would trigger corrective action.
The RIA for the MSWLF criteria revisions estimated that about two-thirds of existing
MSWLFs would trigger corrective action under Part 258. Although the revisions to Part 257
are similar to Part 258 with regard to corrective action, EPA believes that the characteristics of
C&D landfills are such that they are less likely than MSWLFs to trigger corrective action To
estimate the proportion of C&D landfills that would trigger corrective action, EPA examined
C&D landfill leachate data provided by NADC. Specifically, EPA calculated the median
concentrations of constituents found in leachate from 21 landfills, and divided these
concentrations by a dilution/attenuation factor of 10 to approximate concentrations at a
monitoring well located at the waste management boundary.l8 These concentrations were
then compared to corrective action trigger levels such as Maximum Contaminant Levels
(MCLs) promulgated under the Safe Drinking Water Act or, for constituents without MCLs,
health-based levels in drinking water (reference concentrations for non-carcinogens and 10°
risk-specific doses for carcinogens).
Using this approach, 3 of the 21 landfills, or 14.3 percent, trigger corrective action
For this analysis, then, EPA assumed that 14.3 percent of C&D landfills that upgrade would
17This assumption was based on an analysis of capacity, and does not affect the national costs
significantly '
18 Median leachate concentrations were based on all samples, including those in which the constituent
tested for was not detected.
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trigger corrective action 19
For the remaining 548 landfills (those that do not upgrade and stop receiving CESGQ
waste), the costs 1Tre simply those associated with spot checking incoming loads, as discussed
in Section 342
3.5.2 Construction and Demolition Waste Generators
Disposal costs under the high compliance cost scenario will increase for construction
and demolition waste generators if the C&D landfill to which they currently send their waste
chooses to upgrade. Under this scenario, the waste generator would either continue to use the
same landfill at a higher cost, or take the waste to a different landfill, presumably at a greater
distance. For this analysis, EPA assumed that waste generators would continue to send their
waste to the' newly upgraded landfill and pay the increased tipping fees. To estimate the
increase in. tipping fees that would be charged by landfill owners, EPA simply divided the total
upgrading costs for the 170 landfills by the total number of tons received by those landfills
Implicit in this approach is that the upgrading costs will be passed along to all users of the
landfill, including demolition waste generators, who are not CESQG waste generators and are
not required to use upgraded landfills.
The total quantity of waste received annually by the 170 landfills assumed to upgrade
is 21.3 million tons, approximately 76 percent of the total generation of construction and
demolition waste in the affected states The total annual cost of upgrading these landfills is
$41 9 million (see Exhibit 4-5c). Therefore, the average per-ton cost of upgrading is estimated
to be $1.97 EPA assumes that this is equal to the incremental tipping fees these landfills will
charge for waste disposal.
To calculate costs associated with increased tipping fees for demolition waste going to
CSdD landfills that upgrade, EPA simply multiplied the quantity of demolition waste that will
go to upgraded landfills (82 percent of 21.3 million tons, or 17.5 million tons) by the
incremental tipping fee of $1.97 per ton (Exhibit 4-5b)
Similarly, to calculate costs associated with increased tipping fees for construction
waste going to C&D landfills that upgrade, EPA multiplied the quantity of construction waste
that will go to upgraded landfills (18 percent of 21.3 million tons, or 3.8 million tons) by the
incremental tipping fee of $1.97 per ton. In addition, generators of construction waste who
currently send their wastes to C&D landfills that do not upgrade will incur the costs of
separating out the hazardous portion of the waste and sending it to a Subtitle C facility.
However, not all construction waste will be going to an upgraded landfill. Thus, some
>c> Estimated monitoring well concentrations of iron, manganese, sulfates, and/or total dissolved solids
exceed secondary drinking water standards (SMCLs) at several additional landfills However, these
constituents are not among those the rule requires owners of C&D landfills to monitor for, and are not
of concern for health reasons (SMCLs are based on aesthetics) Therefore, EPA has not included these
landfills in estimating the proportion of C&D landfills that will tngger corrective action under the rule
-21 -
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construction sites will still need to separate their wastes. Inspection costs to ensure CESQG
wastes are separated for heavy construction establishments were presented in section 33 It is
uncertain, what portion of the 10,000 establishments assumed to "inspect" sites in section 3 3,
would contmue-tw-incur this cost under this scenario where the majority of large C&JD
landfills upgrade. To be conservative, EPA assumed 70 percent of these establishments will
continue to "inspect" the sites capture a reasonable upper-bound of facilities which might
continue to inspect and separate. To calculate separation and disposal costs for these
construction waste generators, then, EPA simply multiplied the costs estimated previously for
aH construction waste generators by 70 percent.
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4. RESULTS OF THE COST ANALYSIS
This chapter presents the results of the cost analysis. Sections 4.1 through 4.'3 present
the costs to each type of affected party, and Section 4 4 summarizes the costs to the economy
Section 4 5 examines costs under a hypothetical "high-end" scenario in which the majority of
large CStD landfills upgrade in response to the rulemaking; EPA believes this to be an unlikely
scenario
4.1 CESQGS WITH ON-SITE DISPOSAL IN SUBTITLE D UNITS
Exhibit 4-1 shows the estimated annual costs of the rule to CESQGs in the
manufacturing sector with on-site disposal. The total cost, estimated to be $172,000, is
relatively low because (1) the cost of separating the hazardous waste from the rest of the
waste is assumed to be negligible, and (2) the quantities of hazardous waste requiring off-site
disposal are very small.
EXHIBIT 4-1
Estimated Annual Costs to CESQGs With On-Site Disposal
Cost for Hazardous Waste
Pickup and Disposal (per ton)
$430
Tons of Hazardous Waste
Generated
400
Total Annual Cost
$172,000
4.2 CONSTRUCTION WASTE GENERATORS
Exhibit 4-2 shows the estimated annual costs of the rule to construction waste
generators in affected states, first for separating out the hazardous portion of the waste and
then for disposing of it. The bulk of the total annual costs are associated with the separation
process itself rather than from the disposal of the small quantity of separated hazardous waste.
4.3 CONSTRUCTION AND DEMOLITION LANDFILLS
C&D landfills are assumed not to upgrade in response to the rule, and to incur
compliance costs only from spot checking incoming waste at the landfill. Exhibit 4-3 shows
the estimated costs of the rule to C&D landfills.
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EXHIBIT 4-2.
Estimated Annual Costs to Construction Waste Generators
Cost of Separating
Hazardous Waste (per
construction
establishment)
$901
Number of Heaw
*
Construction
Establishments
10,000
Total Cost of Separation
$9,010,000
Cost for Hazardous
Waste Pickup and
Disposal (per ton)
$430
Tons of
Hazardous
Waste Separated
636
Total Cost of
Pickup and
Disposal
$273,000
Total Annual Cost
$9,283,500
Note numbers are rounded
EXHIBIT 4-3.
Estimated Annual Costs to C&D Landfills
Cost of Spot Checking
Incoming Waste (per landfill)
$4,500
Number of C&D
Landfills in Affected
States
718
Total Annual Cost
$3,231,000
4.4 TOTAL COSTS TO THE ECONOMY
The total costs to the economy, shown in Exhibit 4-4, are estimated to be $9.96
million These consist of (1) costs of hazardous waste disposal for a small quantity of
hazardous waste from CESQGs currently using on-site disposal; (2) costs to construction
waste generators to separate out the hazardous portion of their wastes and send it to Subtitle
C facilities; and (3) costs to C&D landfill owners to spot check incoming waste for CESQG
waste. Over 70 percent of the costs of the rule are associated with separating out the
hazardous portion of construction waste.
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EXHIBIT 4-4.
Estimated Costs to the Economy
Affected Parties
CESQGs with On-site Disposal
Construction
Waste
Generators
Hazardous Waste
Separation
Pickup and Disposal
Total Costs
Construction and Demolition Waste
Landfills
Total
Annual Costs (millions)
SO 17
$901
$0.27
$928
$323
$1265
4.5 "HIGH-END" COSTS -- IF 170 C&D LANDFILLS UPGRADE
Exhibits 4-5a through 4-5c show the estimated costs to construction waste generators,
demolition waste generators, and C&D landfills under the hypothetical scenario that 170
C&D landfills upgrade to come into compliance with the Part 257 revisions. Costs to
CESQGs with on-site disposal are the same under this scenario as presented above in Section
4 1.
EXHIBIT 4-5a.
Estimated Annual Costs to Construction Waste Generators
Cost of Separating
Hazardous Waste (per
construction
establishment)
$901
Number of Heavy
Construction
Establishments
7,000
Total Cost of Separation
$6,307,000
Cost for Hazardous
Waste Pickup and
Disposal (per ton)
$430
Tons of Hazardous
Waste Separated
445
Total Cost of Pickup
and Disposal
$191,000
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Incremental Tipping Fee
to Upgraded C&D
Landfills (per ton)
$1 97
Tons of Waste to
Upgraded C&D
Landfills
3,830,000
Total Cost of Disposal
in Upgraded C&D
Landfills
$7,545,000
1 Total Estimated Annual Costs to Construction Waste
Generators
$14,043,000
Note numbers may not add due to rounding
The incremental tipping fee of $1 87 per ton is based on the assumption that landfill
owners will pass along upgrading costs to all users of the landfill. If landfill owners do not
pass along these costs, this exhibit overstates the compliance costs of the rule to construction
waste generators. If landfill owners pass along these costs only to construction waste
generators (demolition waste generators are not CESQGs and therefore are not required to
use upgraded landfills), the compliance costs incurred by construction waste generators would
be higher than those shown in the exhibit.
EXHIBIT 4-5b.
Estimated Annual Costs to Demolition Waste Generators
Incremental Tipping Fee
to Upgraded C&D
Landfills (per ton)
$1 97
Tons of Waste to
Upgraded C&D
Landfills
17,466,250
Total Annual Cost
$34,480,000
As stated above, this analysis assumes that upgrading costs will be passed along to all
users of the upgraded landfill. If upgrading costs are not passed along, or are passed along
only to construction waste generators, the incremental costs of the rule to demolition waste
generators would be zero. About 85 percent of the upgrading costs are associated with
groundwater monitoring.
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EXHIBIT 4-5c.
Costs to C&D Landfills
Size Range
(Capacity in
Tons Per
Day)
0-30
30-265
265-500
- > 500
Total
Number
of
Landfiljs
Assumed
to Spot
Check
.Only
453
95
0
0
548
Number
of
Landfills
Assumed
to
Upgrade
0
19
114
37
170
Annual Cost
(millions)
Spot
Checking
$2.0
$0.4
0
0
$2.4
Monitoring
0
$30
$24.4
$10.0
$374
Corrective
Action
0
$03
$2.7
$1.5
$4.5
Total
$2.0
$3 7
$27 1
$11 5
$443
Exhibit 4-5d shows the total costs to the economy under the assumption that 170
landfills upgrade EPA estimates these costs to be $51 million per year. These consist of (1)
EXHIBIT 4-5d.
Estimated Costs to the Economy Under the Hypothetical "High-End" Scenario
Affected Parties
CESQGs with On-site Disposal
Construction Waste II Haz. Waste Separation1
Generators Pickup and Disposal1
1 Total
Demolition Waste Generators
C&JD Landfill Owners
Spot Checking2
Monitoring3
Corrective Action3
Total Upgrading Costs
Total
Annual Costs
(millions)
$0 17
$6.31
$019
$6.5
$0
$24
$37.4
$4.5
$41 9
$51.0
Note numbers may not add due to rounding
All increased costs attributed to landfill owners
I 70 percent of Construction Waste Generators separate
2 548 C&D landfills spot check
3 170 C&JD landfills upgrade
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costs of hazardous waste disposal for small quantity of hazardous waste from CESQGs
currently using on-site disposal; (2) costs to a subset of construction waste generators to
separate out the hazardous portion of their waste and send it to a Subtitle C facility; (3) costs
to a subset of C&D landfills for spot checking incoming wastes; and (4) costs to a second
subset of C&D landfills for upgrading.
Increases in tipping fees incurred by construction and demolition waste generators who
send their wastes to upgraded C&D landfills under this hypothetical high-end scenario are not
included in the costs to the economy. To estimate costs to the economy, it is necessary to
distinguish between opportunity costs and transfers: the former represent true social costs,
while the latter are payments that "net out," since the cost to one entity is exactly balanced
out by the gain to the entity receiving the payment. Changes in tipping fees paid by
generators are exactly balanced out by the increased revenues received by the C&JD landfills
Thus, these two categories are not included in the estimate of total costs to the economy.
As shown in Exhibit 4-5d, the high costs of the rule in this hypothetical high-end
scenario result mainly from the high costs associated with upgrading existing landfills.
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5. LIMITATIONS OF THE COST ANALYSIS
A number of assumptions and simplified methodologies were used in this analysis.
Important caveats and limitations are discussed in this chapter
5.1 OVERALL LIMITATIONS IN THE ANALYSIS
One important limitation of the analysis is the considerable uncertainty associated
with the quantities, management practices, and characteristics of construction and demolition
wastes. The analysis assumes that 100 million tons of C&D waste are generated annually,
based on two estimates presented in the literature. EPA also assumes that all of this waste is
currently sent to C&D landfills, this is a conservative assumption that likely overestimates
costs somewhat.
EPA found very little information on how much C&D waste is construction waste
versus demolition waste. There fs also uncertainty with respect to the frequency with which
construction and demolition waste generators are CESQGs. EPA has assumed that all
construction waste generators are CESQGs, and that no demolition waste generators are
CESQGs
Finally, with the exception of the hypothetical "high-end" analysis, EPA has developed
only point estimates of costs, not range estimates. The presentation of point estimates should
not be interpreted to indicate precision in the results.
5.2 LIMITATIONS IN THE ANALYSIS OF COSTS TO CESQGS USING ON-SITE
MANAGEMENT
EPA's estimate of the costs to CESQGs using on-site management is very rough.
Limitations include the following:
Separation costs are not included.
EPA assumed that all of the CESQG waste sent off site will go to Subtitle C
facilities. Some portion of this waste might be accepted at MSWLFs.
When CESQGs with on-site waste management units begin shipping the hazardous
portion of their wastes off site, they will begin using their on-site capacity at a
slightly lower rate This analysis does not account for the slight extension of the
useful life of on-site units as a result of the rule.
Because the affected waste quantities are very small, these uncertainties have correspondingly
small effects on the national cost estimate.
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5.3 LIMITATIONS IN THE ANALYSIS OF COSTS TO CONSTRUCTION AND
DEMOLITION WASTE GENERATORS
EPA assuTTted that it would be feasible, in all cases, to separate out the hazardous
portion of construction waste, and that the added costs would be attributable only to
inspection of construction sites. There is considerable uncertainty associated with the
activities and associated costs for separating out hazardous waste^T construction sites.
In the hypothetical "high-end" analysis, EPA assumed that owners of landfills opting to
upgrade would pass along all of the upgrading costs to the users of their landfills, and
calculated increased tipping fees based on this assumption. If landfill owners do not pass
along the upgrading costs, tipping fees will not increase, and the analysis overstates
compliance costs to both construction waste and demolition waste generators. If landfill
owners pass along the upgrading costs only to construction waste generators, the analysis
understates compliance costs to construction waste generators and overstates compliance costs
to demolition waste generators. Finally, the analysis does not account for any changes in
behavior on the, part of construction or demolition waste generators resulting from higher
tipping fees charged by landfill owners that upgrade; it assumes that all generators will
continue to send their waste to the same landfill as before the rule.
5.4 LIMITATIONS IN THE ANALYSIS OF COSTS TO C&D LANDFILLS
EPA's cost estimate is based on the assumption that no. C&DJin^fill'i wll fmfl it
profitable to upgrade after the rule is m effect. The cost comparison presented in Section
6 4 JS indicates that the (1) per-ton costs incurred by owners of landfills that upgrade are in
some cases lower than (2) the per-ton costs incurred by construction waste generators who
separate their wastes, but only for the largest landfills and only if they do not trigger
corrective action. It is possible that the economics favor upgrading under other circumstances
as well
' To analyze the hypothetical "high-end" scenario, EPA modeled total upgrade costs and
transportation costs as a function of the number of C&D landfills that chose to upgrade As
the number of landfills that upgrade increases, transpiration costs will decline on average
while total upgrade costs will increase. EPA found that the minimum sum of total
transportation costs and upgrade costs occurred when 162 landfills upgrade in response to this
rulemakmg. EPA's model assumes that landfills in the larger size categories will find it
economical to upgrade, while the smaller landfills will not.
There are several uncertainties associated with the estimate of upgrading costs in the
hypothetical "high-end" scenario:
The per-ton costs for groundwater monitoring and corrective action were assumed
to be the same as for MSWLFs.
EPA assumed that C&D landfills opting to upgrade would upgrade the entire
facility. Some C&JD landfill owners might choose instead to stop receiving CESQG
waste in the existing portion of the landfill, and to open a new, separate section
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which would receive only CESQG-containing waste. Under this scenario, only the
new section would be upgraded (assuming that this is allowed), and the upgrading
costs would be lower
C&D landfills were assumed to have a 15-year remaining life over which to
amortize the upgrading costs. No information was found on the remaining life of
C&D landfills.
The costs of making demonstrations in response to the location restrictions are not
included in the national cost estimates.
The analysis did not consider the possible construction of new C&D landfills; and
how competition from new landfills may affect tipping fees.
The analysis did not consider the effects of the rule on the generators of C&D
waste that currently use on-site C&D landfills.
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6. POTENTIAL IMPACTS ON SMALL ENTITIES
EPA anticipates that this rule will increase costs for two classes of facilities. CESQG
generators that still handle their CESQG waste on site are expected to send their CESQG
waste to Subtitle C facilities, at a maximum per-facility cost of $570 per year. Construction
waste generators will incur maximum additional per-firm costs of $1,469 per year, for
separation, transportation, and disposal of hazardous wastes.
The Regulatory Flexibility Act of 1980 requires federal agencies to assess the effects of
regulations on small entities and to examine alternatives to the regulations that may reduce
adverse economic effects on significantly impacted entities (5 U.S. Code 601 et. seq.). The Act
requires agencies to prepare a preliminary analysis for all rulemakings to determine if a
Regulatory Flexibility Analysis (RFA) is necessary.
This chapter examines the potential impacts of the rulemaking on small entities
Section 6.1 provides a description of the requirements of the Regulatory Flexibility Act and
the EPA guidelines for determining significant impacts on small businesses. The general
methodology used to determine whether the action may have significant impacts on small
entities is described in Section 6.2. Section 6.3 presents the results of the analysis for each
type of entity affected by the rulemaking.
This analysis is based on EPA's assessment of the most likely compliance behavior on
the part of affected entities EPA performed a high end analysis, predicated on an
assumption that C&D landfills upgrade to meet these standards. In this scenario, cost
impacts would be higher. EPA does not expect C&D landfills to upgrade, however, since they
would be unlikely to recover the high costs of upgrading. The analysis of effects on small
entities is predicated on an assumption that the owners of C&D landfills act rationally, and
choose not to upgrade. Therefore, the hypothetical "high-end" scenario described in Chapters
3 and 4 is considered to be an unlikely outcome of the rulemaking and is not addressed in this
chapter
6.1 REGULATORY FLEXIBILITY ACT AND EPA GUIDELINES
The Regulatory Flexibility Act requires federal agencies to determine whether their
actions will have a significant impact on a substantial number of small entities, including
businesses, nonprofit agencies, and governmental jurisdictions. The Act does not define the
key terms "small entity," ""significant impact," or "substantial number."
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In cases where the approximate severity of the impacts of a rule on small entities is
unknown, the EPA guidelines recommend undertaking an initial screening analysis.20 As one
possible method, the EPA guidelines suggest comparing the annual compliance costs under the
rulemakmg to oprrating characteristics of the affected firms, such as annual sales, operating
expenditures, net profits, or cash flow The results of the screening analysis are then used to
ascertain the potential economic impacts of the rulemakmg and to determine the level of
additional analysis needed.
6.2 GENERAL APPROACH
To obtain a preliminary indication of the potential impacts of the rule on small
entities, this analysis compares annual compliance costs to average annual sales revenue (or
average annual dollars of business done) for each type of affected facility. When available, the
analysis also examines annual compliance costs as a percentage of annual net income For the
purposes of a screening analysis, comparing compliance costs to revenues provides a
reasonable indication of the magnitude of the potential regulatory burden relative to a
commonly available measure of a company's business volume. If the compliance costs
represent a very small fraction of a typical firm's revenues (e.g., less than one percent), the
financial impacts are likely to be minimal. When the ratio of compliance costs to annual
revenue or net income is very high, additional analysis may be necessary to determine whether
or not affected entities can "pass on" these additional costs to their consumers or absorb the
additional costs themselves.
As discussed in previous chapters, three types of entities may be affected by this rule
CESQGs with on-site disposal in Subtitle D units (primarily manufacturing
facilities from various industries);
CESQGs with off-site disposal in C&D landfills (primarily construction
companies); and
C&JD waste landfills.
Each type of entity is examined separately because they face different compliance costs and
represent wholly different industries. The specifics of the analysis of each group are described
below in Section 6.3.
Data on the average annual "dollar value of business done," or revenues, for the
construction industries and the wrecking and demolition industry were obtained from the
1987 Census of Construction Industries. Data on the average annual sales revenues for the waste
disposal industry and for selected manufacturing industries with on-site disposal were
obtained from Robert Morris Associates, Annual Statement Studies for 1993 (RMA). Annual
compliance costs per facility were estimated based on the results of the national cost analysis
20 "Appendix E. Screening Analysis to Determine Seventy of a Rule's Impacts on Small Entities," from
EPA Guidelines for Implementing the Regulatory Flexibility Act
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Since the compliance cost estimates are in 1993 dollars, the revenue data from the'Census
were inflated to 1993 dollars based on the average gross domestic product (GDP) for 1987
and the estimated GDP for the final quarter of 1993.2I
While compliance costs are estimated on a per-facility basis, the financial data used for
this analysis is at the firm level (i.e., for an average parent company). The financial data for a
firm and an affected facility could differ if the firm operates more than one facility. This
analysis assumes that a firm operates only one facility, and could therefore underestimate the
potential impacts to firms with more than one affected facility.
Three possible criteria are provided in the EPA guidelines for defining "small entity "
First, "the cutoff can-be the point at which the adverse economic impact appears to rise or fall
substantially, for example, in the form of higher costs or closures." Second, "EPA can use the
point in the range of size segments that most closely approximates the Small Business
Administration's definitions." Third, "EPA can use the point at which the regulation
effectively includes a large number of regulated entities without covering a large portion of the
pollution problem (e.g., 50 percent of regulated entities, but only 10 percent of the discharge
of pollutant)."
For this analysis, the definition of a small entity varies by type of facility and by
industry For most industries examined, the analysis uses average annual sales data for the
smallest size range of companies (in terms of annual sales revenues or number of employees)
for which data are provided by RMA and Census. The specific definitions and data used for
each type of affected party are discussed below.
6.3 RESULTS
6.3.1 CESQGs with On-Site Disposal in Subtitle D Units
CESQGs in the manufacturing sector are not expected to be significantly impacted by
the rulemaking because (1) few facilities still manage their CESQG waste in on-site disposal
units; (2) industry practice is to keep hazardous wastes separate from non-hazardous wastes,
so separation costs are insignificant; and (3) the quantities of CESQG waste generated are
small, and the cost of disposing these wastes off site is correspondingly small.
Facilities that still handle their CESQG waste on site are expected to send their
CESQG waste to Subtitle C facilities. The costs for pickup and disposal of the CESQG waste
are estimated to be approximately $430 per ton.
Given that a CESQG, by definition, produces less than 100 kg of hazardous waste per
month, or 1.32 tons per year, the cost of disposing this waste off site is estimated to be less
21 Implicit price deflators for the gross domestic product are produced by the Bureau of Economic
Analysis in the Department of Commerce An annual average was not available for 1993 so revenues
were inflated using the final quarter GDP estimate. The resulting GDP mflator for converting the
1987 Census data to 1994 dollars is I 2263.
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than or equal to $568 per year per facility Exhibit 6-1 presents the potential impact of 5568
in additional waste disposal costs to small companies, or those with annual sales of $1 million
or less, in vanous-fregments of the Stone, Clay, Glass, and Concrete industry and Food and
Kindred prouucts industry." Impacts are measured by examining compliance costs as a
percentage of annual sales and as a percentage of net income. As Exhibit 6-1 shows, the
highest possible annual compliance costs represent only a small impact on the smallest
companies in these industries. The impacts on larger firms, with higher annual revenues, are
expected to be even lower.
EXHIBIT 6-1
Estimated Impacts on CESQGs with On-Site Management,
with Annual Revenues of $ I Million or Less
(1993 Dollars)
Industry
Cut Stone and Stone
Products3
(SIC Code 328 1)
Glass Products'"
(SIC Code 3231)
Concrete Brick, Block
and Other Products0
(SIC Code 3271 and
3272)
Dairy Products'*
(SIC Codes 202 1, 2022,
2024. and 2026)
Canned and Dned Fruits
and Vegetables*
(SIC Codes 2033 and
2034)
Maximum Estimated
Compliance Costs
$568
$568
$568
$568
$568
Annual Costs as
Percentage of
Annual Revenues
0 10%
0 09%
009%
0 10%
0.06%
Annual Costs as Percentage
of Annual Net Income
2.1%,
NA
72%
NA
NA
Impact percentages ace calculated using an average annual revenue of S563.700 and an average profit before taxes of
$27.058 These average numbers are calculated from data in RMA, 1993
22 The potential impact to facilities in these industries is examined to demonstrate that the potential
compliance costs represent a very small percentage of revenues and net income for this category of
facilities. Specific industries were chosen from the Stone, Clay, Glass, and Concrete, and Food and
Kindred products industries because facilities from these industries represent almost 50 percent of the
CESQGs that with on-site management, based on the Screening Survey of Industrial Subtitle D
Establishments (Westat, 1987) The impact of the additional costs to facilities in other industries is
expected to be similar
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Impact percentages are calculated using an average annual revenue of 5652,000, calculated from data in RMA, 1993
Average profit before taxes was not available for this size category
Impact percentages are calculated using an average annual revenue of $607.400 and an average profit before taxes of
57,900 These average numbers arc calculated from data in RMA, 1993 Although these smaller firms have
negative profits before taxes, on average, the loses are small, on the order of 1 percent The annual costs to
these companies under the rule represent a small percentage of these losses
Impact percentages are calculated using an average annual revenue of 5584,500, calculated from data in RMA. 1993
Average profit before taxes was not available for this size category
Impact percentages are calculated using an average annual revenue of 5877,000, calculated from of -57,900 These
average numbers are calculated from data in RMA, 1993 Although these smaller firms have negative profits
before taxes, on average, the loses are small, on the order of 1 percent The annual costs to these companies
under the rule represent a small percentage of these losses
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6.3.2 Construction Industry
There afe-approximately 194,000 construction contractors in the U.S., of which
approximately 157,000 are building contractors (residential, operative, and nonresidential)
and approximately 37,000 are heavy construction contractors (roads, bridges, etc.).23 Based
on the distribution of the national population, approximately 44,000 building contractors and
10,000 heavy construction contractors could be affected by the rule.24 In the cost analysis,
EPA assumed that building contractors will separate the hazardous and non-hazardous
portions of their waste and continue to dispose of the non-hazardous portion as in the
baseline. The hazardous portion is assumed to be disposed in a Subtitle C facility.
EPA has estimated that it will cost each of the 10,000 heavy construction contractors
$901 per year to separate out the hazardous portion of construction waste. It will also cost
$430 per ton, on average, to dispose of the hazardous portion of construction waste in a
Subtitle C facility Multiplying $430 per ton by a maximum of 1.32 tons of CESQG waste
per year, each heavy construction company faces a maximum disposal cost of $568 per year
under the rule. The total maximum increase in costs to construction companies is therefore
$1,469.
Exhibit 6-2 shows the cost impacts as a percentage of annual'revenues for four
segments of the construction industry: single family house construction, residential
construction other than single family, highway and street construction, and heavy
construction not elsewhere classified. To be conservative, all segments were assumed to incur
a maximum cost of $1,469, even though the cost analysis is based on the assumption that
only companies involved in heavy construction would incur inspection costs. As shown in the
exhibit, the increase in costs represents a small impact, less than one percent of annual
revenues, for all sizes and types of construction companies. The cost impacts as a percentage
of annual revenues are similar or lower for the other segments of the construction industry,
such as non-residential and elevated highway and bridge construction.
23 Based on data from the 1987 Census of Construction Industries.
24 The states affected by the rule represent approximately 28 percent of the U S population The
number of construction contractors to be affected is esumated by multiplying the total number of
contractors in the U S by 28 percent
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6.3.3 C&D Waste Landfills
This rule does not impose any new requirements on C&D landfills Under the
assumption that the landfills will choose not to upgrade, they will probably spot check
incoming loads to make sure that they do not contain CESQG wastes. EPA notes that C&D
landfills generally already implement source control programs, screening wastes before
accepting them This was confirmed in industry comments submitted to EPA on the proposal
for this rule '^ Inasmuch as this screening constitutes a baseline practice for the industry,.
EPA believes that landfills will not incur additional costs.
6.3.4 Conclusions
It is unlikely, given the assumptions applied in the analysis and the results of the
screening analysis, that any of the affected parties will be impacted significantly by this
rulemaking If there are changes in any of EPA's expectations regarding the behavior of firms
within the industries affected, it may be necessary to reexamine the potential impacts.
EPA anticipates that this rule will increase costs for two classes of facilities. CESQG
generators that still handle their CESQG waste on site are expected.to send their CESQG
waste to Subtitle C facilities, at a maximum per-facility cost of $570 per year. Construction
waste generators will incur maximum additional per-firm costs of $1,469 per year, for
separation, transportation, and disposal of hazardous wastes. In each case, EPA's analysis
shows that the impacts are less than one percent of annual revenues, for all sizes and types of
companies.
This determination is based on EPA's projection of the response of CESQG waste generators
and disposal facilities to today's rule. EPA performed a high'end analysis, predicated on an
assumption that C&D landfills upgrade to meet these standards. In this scenario, cost impacts
would be higher. EPA does not expect C&D landfills to upgrade, however, since they would
be unlikely to recover the high costs of upgrading. The analysis of effects on small entities is
predicated on an assumption that the owners of C&D landfills act rationally, and choose not
to upgrade.
"Comments from Sanifill of Texas, Inc. and Beck Readymix Concrete Co., date
August 11, 1995 (p. 2 of attachment, NCEP-00013).
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EXHIBIT 6-2
Estimated Compliance Costs and Impacts foflhe General Contractors - Single family Houses Industry (SIC Code 1521)
""'' , "£", '* * ' I
"^'.;, " .. i(!993 Dollars) , ' '
-:'7.^ "r -v"
Maximum Annual
Compliance Costs
per Company
Average Annual
Revenues per
Company*
(Thousands of
Dollars)
Average Annual
Costs as
Percentage of
Average Annual
Revenues
' ,v": ^F/f ' ^ Establishments with an average of
1 to 4
employees
$1.469
NA
NA
5 to 9
employees
$1,469
564
0.26%
10 to 19
employees
$1,469
1,292 "
0 11%
20 to 49
employees
'/ $1,469
B.
I 2,754
V
0 05%
50 to 99
employees
$1,469
6,508
002%
100 to 249
employees
$1.469
18.170
< 0.01%
250 to
499
employees
$1,469
70,683
<001%
500 to 999
employees
$1.469
NA
NA
1000+
employees
$1.469
NA
NA
* Average annual revenue is calculated based on data obtained from the 1987 G
dollars based on GDP
NA = Not Available
of Construction Industries report Estimates were inflated to 1993
-------
EXHIBIT 6-2 cont'd
Estimated Compliance Costs and impacts for the General Contractors -
Residential Buildings Other than Single Family Houses Industry (SIC Code 1522)
(1993 Dollars)
Maximum Annual
Compliance Costs
per Company
Average Annual
Revenues per
Company*
(Thousands of
Dollars)
Average Annual
Costs as
Percentage of
Average Annual
Revenues?
Establishments with an average of
1 to 4
employees
$1,469
280
052%
5 to 9
employees
$1.469
880
017%
10 to 19
employees
$1.469
2,039
*
007%
20 to 49
employees
$1,469
4,918
003%
50 to 99
employees
$1,469
14,124
001%
100 to 249
employees
$1,469
29,573
<001%
250 to
499
employees
$1,469
95,372
<001%
500to
999
employees
$ 1 ,469
NA
NA
1000 +
employees
$1,469
NA
NA
" Average annual revenue is calculated based on data obtained from the 1987 Census of Construction Industries report Estimates were inflated to 1993
dollars based on GDP
NA = Not Available
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EXHIBIT 6-2 cont'd
Estimated Compliance Costs and Impacts for the Highway and Street Construction Contractors Industry (SIC Code 1611)
(1993 Dollars)
I
Maximum Annual
Compliance Costs
per Company
Average Annual
Revenues per
Company*
(Thousands of
Dollars)
Average Annual
Costs as
Percentage of
Average Annual
Revenues
* } *- f><«'t£i£fJ''V
i.' . . » ' Establishments with an average of ' , »;v '_ '!*. -
'' "\'l~ ' i :
1 to 4
employees
$1,469
224
066%
5 to 9
employees
i
$1,469
663
022%
-
: 10 to 19
~ employees
$1,469
1,437
i i '
4
. / - *
i
oio%|
, ... - ' - ;
j 20 to 49
employees
j
! $1,469
3,568
0.04%
. 50 to 99
employees
$1,469
9.323
002%
100 to 249
employees
$1,469
21.146
<001%
250 to
499
employees
$1,469
45,829
< 001%
500 to 999
employees
$1.469
118,373
<001%
1000+
employees
$ 1 ,469
NA
NA
1 Average annual revenue is calculated based on data obtained from the 1987 Census of Construction Industries report Estimates were inflated to 1993
dollars based on GDP
NA = Not Available
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EXHIBIT 6-2 cont'd
Estimated Compliance Costs and Impacts for the Heavy Construction Contractors Industry
(SIC Code 1629)
(1993 Dollars)
Maximum Annual
Compliance Costs
per Company
Average Annual
Revenues per
Company*
(Thousands of
Dollars)
Average Annual
Costs as
Percentage of
Average Annual
Revenues
Establishments with an average of
1 to 4
employees
$1,469
161
091%
5 to 9
employees
$1,469
505
029%
10 to 19
employees
$1,469
1,121
0 13%
20 to 49
employees
$ 1 ,469
3,088
0 05%
50 to 99
employee
s
$1,469
7,124
002%
100 to 249
employees
$1,469
-
16,527
< 001%
250 to
499
employees
$1,469
44,901
< 001%
500 to
999
employees
$1,469
65.250
<001%
1000 +
eniployees
$ 1 ,469
237.759
*
< 001%
* Average annual revenue is calculated based on data obtained from the 1987 Census of Construction Industries report Estimates were inflated to 1993
dollars based on GDP
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