Economic Analysis for Listing of
Inorganic Chemicals, Notice of Final
Rulemaking
U.S. Environmental Protection Agency
Office of Solid Waste
1200 Pennsylvania Ave.
Washington, DC 20460
October 2001
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Economic Analysis for Listing of
Inorganic Chemicals, Notice of Final
Rulemaking
October 2001
U.S. Environmental Protection Agency
Office of Solid Waste
1200 Pennsylvania Avenue
Washington, DC 20460
-------
CONTENTS
Chapter Page
1 Introduction and Executive Summary 1-1
1.1 Organization of the Economic Impact Analysis 1-1
1.2 Executive Summary 1-2
2 Industry Profile 2-1
2.1 Industry Profile for Antimony Oxide 2-1
2.1.1 The Supply of Antimony Oxide 2-1
2.1.2 The Demand for Antimony Oxide 2-2
2.1.3 Industry Organization 2-3
2.1.4 Markets 2-5
2.2 Industry Profile for Titanium Dioxide 2-6
2.2.1 The Supply of Titanium Dioxide 2-6
2.2.2 The Demand for Titanium Dioxide 2-8
2.2.3 Industry Organization 2-9
2.2.4 Markets 2-10
2.3 Wastes from the Production of Inorganic Chemicals 2-13
2.3.1 Listings 2-14
3 Methodology and Data Limitations 3-1
3.1 Description of Affected Facilities 3-1
3.2.1 Affected Facilities Producing Antimony Oxide 3-1
3.2.2 Affected Facilities Producing Titanium Dioxide 3-2
3.3 Characteristics and Limitations of the Economic Impact
Analysis Method 3-4
4 Costs of the Proposed Listing 4-1
4.1 Antimony Oxide 4-1
4.1.1 Review of Baseline and Compliance Waste
Management Practices 4-1
4.1.2 Cost Analysis 4-2
4.1.3 National Costs 4-7
4.2 Titanium Dioxide 4-8
4.2.1 Review of Baseline and Compliance Waste Management
Practices 4-8
4.2.2 Cost Analysis 4-9
4.2.3 National Costs 4-12
111
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CONTENTS (continued)
Chapter Page
4.3 Total Annualized National Costs 4-12
5 Economic Impacts 5-1
5.1 Economic Impact Analysis—Antimony Oxide Sector 5-1
5.1.2 Estimated Economic Impacts on Affected Antimony
Oxide Facilities and Firms 5-1
5.2.1 Estimated Economic Impacts on Affected Facilities
and Firms—Antimony Oxide 5-1
5.2 Economic Impact Analysis—Titanium Oxide 5-3
5.2.1 Estimated Economic Impacts on Affected Facilities and
Firms 5-4
6 Federalism Analysis 6-1
7 Conclusion 7-1
8 References 8-1
IV
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LIST OF TABLES
Number Page
1-1 National Costs of Implementing the Proposed Listing 1-3
2-1 Characteristics of Major Antimony Oxide Producers 2-3
2-2 Company-Level Financial Information: Antimony Oxide 2-4
2-3 Production, Consumption, Imports and Exports of Antimony
Oxide (MT) 2-5
2-4 Antimony Oxide Prices ($/lb) 2-6
2-5 Characteristics of Titanium Dioxide Producers 2-11
2-6 Company-Level Financial Information: Titanium Dioxide 2-12
2-7 Wastes and Facilities Affected 2-14
3-1 Antimony Oxide Facilities 3-2
3 -2 Summary of Baseline and Listing Compliance Waste Management
Practices for Antimony Oxide Facility 3-3
3 -3 Titanium Dioxide: Chloride-flmenite Process, DuPont Edge Moor,
DEPlant 3-3
4-1 Baseline and Compliance Management Unit Costs ($2000) 4-3
4-2 Antimony Oxide Costs: Disposal Option 4-5
4-3 Antimony Oxide Costs: Recycle Option 4-6
4-4 Total Costs of the Listing for the Antimony Oxide Sector 4-7
4-5 Total Annualized Costs of the Proposed Listing: Antimony Oxide 4-8
4-6 Baseline and Compliance Management Unit Costs ($2000) 4-10
4-7 Titanium Dioxide Costs: Ferric Chloride Filter Solids Generated by
DuPont Edge Moor 4-11
4-8 Incremental Treatment and Disposal Costs for TiO2 Facilities
Changing to Listed Wastes ($2000) 4-12
4-9 National Costs of Listing 4-13
5-1 Economic Impacts for Companies Choosing Nonrecycling
Compliance Scenario 5-2
5 -2 Economic Impacts for Companies Choosing a Recycling Compliance
Scenario: Facility Impacts 5-2
5-3 Economic Impacts for Companies Choosing Nonrecy cling Compliance
Scenario 5-3
5 -4 Economic Impacts for Companies Choosing a Recycling Compliance
Scenario 5-3
5-5 Company Impacts—DuPont 5-5
5-6 Facility Impacts—DuPont Edge Moor 5-5
v
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LIST OF TABLES (continued)
Number Page
6-1 Summary of Upperbound State and Local Expenditures Associated
with the Inorganics Proposed Listing of Hazardous Waste 6-4
VI
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SECTION 1
INTRODUCTION AND EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) is directed by Congress in Section
3001(e)(2) of the Resource Conservation and Recovery Act (RCRA) (42 U.S.C §6921(e)(2)) to
determine whether to list as hazardous waste a number of different wastes including those from the
inorganic chemicals industry. A lawsuit by the Environmental Defense Fund in 1989 resulted in a
consent decree approved by the court that sets out an extensive series of deadlines for making the
listing determinations required by Section 3001(e)(2). The deadlines include those for making final
listing determinations as well as for concluding various related studies or reports on the industries of
concern. This document, an economic impact analysis of the affected industries, is one of the
documents supporting the listing determination.
1.1 Organization of the Economic Impact Analysis
This report is organized into eight chapters. The first chapter (the Introduction and
Executive Summary) provides an introduction to the report and summarizes the study's conclusions.
Chapter 2 presents background information on the industries that will be affected by the listing. It
presents an industry profile of the two sectors of the inorganic chemicals industry that will be
affected by the listing, discussing supply-side and demand-side dynamics, industry organization, and
the markets for each of the chemicals. Chapter 3 explains the methodology used by the Agency to
conduct the economic analysis and describes any data limitations encountered and assumptions
used. The economic analysis methodology is explained in detail and the limitations of the economic
analysis methodology are discussed. In Chapter 4, the baseline and compliance waste management
practices are explained. The chapter then analyzes the costs of the listing for each of the affected
sectors and presents the national costs of the listing. Chapter 5 presents the results of the economic
impact analysis. Chapter 6 considers the impact of this listing in light of other regulatory
requirements. Chapter 7 presents the conclusions of the economic analysis. Chapter 8 provides
references used in this report. Under Executive Order 12866, economic analyses of Agency
rulemakings are to address both the costs and benefits of regulation and alternative approaches.
Because of data limitations, the Agency was unable to quantify all benefits associated with this
regulation. The reader is referred to the background document Risk Assessment for Listing
Determination of Inorganic Chemical Manufacturing Wastes1 for a description of individual
risks posed by wastes identified for listing under this proposal.
U.S. Environmental Protection Agency. August 2000. Risk Assessment for Listing
Determination of Inorganic Chemical Manufacturing Wastes.
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1.2 Executive Summary
The consent decree approved by the court sets out an extensive series of deadlines for
making the listing determinations required by Section 3001(e)(2). The deadlines include those for
making final listing determinations as well as for concluding various related studies or reports on the
industries of concern. The antimony oxide and titanium dioxide processes are two of the 14
specific production processes identified within the inorganic chemicals industry in the consent
decree and are the only two processes that generate wastes that EPA, based on its risk assessment,
found reason to model for risks. This report provides analytic support to the Agency's notice of
final rulemaking effort.
After sampling and analyzing the wastes generated by these inorganic chemical producers,
the Agency proposed to list as hazardous wastes specified wastes from the antimony oxide sector
and the titanium dioxide sector. The wastes specified in the proposed rule were thought, based on
the data and analysis available, either to present individual risks that warrant hazardous waste listing
or to warrant additional controls than those provided under RCRA because of their hazardous
characteristics. After considering public comments, including additional data, received after
proposal, the Agency has conducted additional analyses and has determined that only three wastes
from the two production processes should be listed as hazardous wastes. From the antimony oxide
sector two wastes will be listed. The first is baghouse filters (K176). The second, K177, is slag
from the production of antimony oxide that is speculatively accumulated or disposed of, including
slag from the production of intermediates (e.g., antimony metal or crude antimony oxide). This
waste, K177, is hereafter referred to as "antimony oxide production slag." One waste will be listed
from the titanium dioxide sector. This waste, residues from manufacturing of ferric chloride from
acids formed during the production of titanium dioxide using the chloride ilmenite process (K178),
is hereafter referred to as "ferric chloride filter residues."
EPA studied the production processes, waste management practices, and market and
financial conditions in each affected industry sector. The Agency analyzed the costs that each
affected industry sector would incur as a result of listing the waste. These costs include new capital
expenditures and the incremental treatment, transportation, and disposal costs that firms would
incur because of the listing. Because adequate nonconfidential data are available for affected
facilities, this analysis uses actual facility data on production and waste generation and actual
company data on sales and employment in evaluating economic impacts of the final rule. EPA
estimated the costs of compliance for each affected facility according to the amount of waste
produced by its production processes. EPA estimated the revenues earned from the sale of
titanium dioxide and antimony oxide, based on the estimated quantity of salable product and market
prices for the products. Finally, the Agency calculated total costs and estimated the economic
impacts on the affected sectors of the inorganic chemicals industry. Economic impacts were
measured by comparing the costs of compliance to baseline sales of affected inorganic chemicals
and the baseline sales and profits for the companies owning affected facilities.
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Based on the economic impact analysis, the Agency believes that this listing will not have
any significant economic impact on firms in the inorganic chemicals industry. Affected facilities
generally face costs that will result in very small impacts on them and their owner companies, as
defined by cost-to-sales or cost-to-profits ratios. Thus, the costs of these regulations are not
expected to be burdensome to most inorganic chemical producers.
Table 1-1 summarizes the expected costs of implementing this ruling. The table is broken
down by sector, the range of cost-to-sales ratios, and approximate total annualized costs. The
totals at the bottom of each table sum the expected national costs of implementing this ruling.
Table 1-1. National Costs of Implementing the Proposed Listing
Facility total annualized
Industry sector Cost-to-sales ratio (%) costs
Antimony oxide O.OOOOl to 0.063 $730 to $ 14,200
Titanium dioxide 0.0004 to 0.0005 $114,400 to $156,800
Total $115,200 to $ 171,000
Based on the ratio of costs of compliance to company sales, the impacts of the listing are
expected to be small. For all companies under all cost estimation scenarios, EPA estimates that the
costs of complying with the listing will represent less than 0.1 percent of the companies' baseline
sales. EPA's analysis was conducted under the assumption that the companies will be unable to
pass any share of the costs of compliance along to their customers. Thus, the ratios may overstate
actual impacts if the companies are able to charge increased prices for their products. Because
other producers of antimony oxide and titanium dioxide exist that are not expected to incur
compliance costs due to the listing, EPA believes the companies' ability to increase the prices they
charge for their affected chemicals may be limited.
EPA also conducted an analysis of possible impacts on small businesses. One of the
companies, Amspec (APOA), in the antimony oxide sector, is a small business. While the
company had substantial sales at baseline ($22 million), it was unprofitable in 2000.
Notwithstanding that it is currently unprofitable, the very modest costs ($415) of complying with
the listing under the lower-cost scenario (recycling) should not be problematic to Amspec. The
costs projected under the recycling management scenario represent an estimated 0.003% of
baseline sales revenues from antimony oxide sales, and approximately 0.002% of baseline company
revenues. Another small business in the antimony oxide industry, U.S. Antimony, is currently
recycling its antimony oxide production slag and is thus not projected to incur costs to comply with
the listing. Because only one small business is projected to incur costs, and the costs represent at
most 0.06 percent of baseline sales (under the higher cost treatment and disposal scenario), the
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Agency does not believe the listing will impose significant economic impacts on a substantial number
of small entities.
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CHAPTER!
INDUSTRY PROFILE
A variety of waste materials are generated in the manufacturing of inorganic chemicals. The
original lawsuit resulting in the consent decree identified 14 specific production processes in the
inorganic chemicals industry for which EPA was required to do risk assessments on the wastes
generated. Of those 14, the antimony oxide and titanium dioxide production processes generate
wastes that EPA, based on its risk assessment, found reason to model and thus consider listing as
hazardous wastes. This section profiles these two sectors of the industry and includes extensive
information on each industry's supply, production processes, demand, market structure, and
product markets.
2.1 Industry Profile for Antimony Oxide
Characterizing the antimony oxide industry involves describing the supply of antimony
oxide, including production processes, production facilities, and the firms that own them. Demand
for antimony oxide, the market structure of the industry, and markets for the product are also a part
of the profile.
2.1.1 The Supply of Antimony Oxide
In the United States, six facilities engage in antimony oxide production. This section
examines the raw materials used, production processes employed, and the costs of production.
Antimony oxide can be produced commercially from either antimony sulfide ore or antimony metal.2
Antimony oxide can be produced using four different processes:
• direct process (roasting),
• indirect process,
• recovery from lead smelting, and
• hydrolysis of antimony trichloride (only demonstrated on a laboratory scale to date).
These processes are described in detail below.
Direct Method. The direct method involves roasting antimony oxide or sulfide ore in the
presence of air (or oxygen). The chemical reaction is as follows:
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
Protection Agency. Reston, VA: SAIC. Pg. 59.
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2Sb2S3 + 9O2 • 2Sb2O3 + 6SO2
The antimony oxide is formed as a fume, cools, and is condensed in a baghouse or similar dry
collection device. At this stage, the antimony oxide is usually too impure and must undergo further
roasting steps.
Indirect Method. The indirect method of antimony oxide production reduces the raw ore
to antimony metal prior to the recovery of antimony oxide. In the blast furnace, oxide-based
antimony ore, coke, iron oxide, limestone, and silica are combined, and the antimony present in the
ore is converted to its metallic state. Next, the extracted molten antimony is refined using
proprietary fluxes. The refined antimony metal is then volatilized and reacted with oxygen in the
vapor phase to produce the product. The antimony oxide cools, condenses, and is collected in a
dry collection device. The chemical reaction is as follows:
4Sb + 3O2« 2Sb2O3.
Recovery. The final commercial means of antimony oxide production is through recovery
as a by-product of secondary lead refining. Most of the antimony oxide is recovered from lead
scrap, particularly batteries.
Hydrolysis. Antimony oxide can also be produced by a wet chemical process that entails
the hydrolysis of antimony trichloride solutions under alkaline solutions. Although this method
produces a pure product in the laboratory, it is not an economical method for the commercial
production of antimony oxide.3
All three of the facilities currently producing antimony oxide in the United States employ the
indirect process, and both Amspec and Laurel also use the direct process.
In addition to other standard variable input costs, firms incur costs associated with waste
disposal. At baseline, the production of antimony oxide generates two nonhazardous wastes,
baghouse filters and antimony oxide production slag, that are subject to this rulemaking under
RCRA. Typically, the nonhazardous waste is disposed of without treatment or it is recycled.
2.1.2 The Demand for Antimony Oxide
Characterizing the consumption of antimony oxide involves describing antimony oxide's
uses and consumers and possible substitutes in consumption. Antimony oxide's primary use is as a
flame retardant in plastics and textiles. It is also used as a smoke suppressant; as a stabilizer for
plastics; in chromate pigment manufacture; as an opacifier in glass, ceramics, and vitreous enamels;
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
Protection Agency. Reston, VA: SAIC. Pg. 59-60.
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and as a coating for titanium dioxide pigments4. Substitutes exist for its use as a flame retardant.
Hydrated aluminum oxide and certain organic compounds are considered acceptable substitutes.5
2.1.3 Industry Organization
The organization of the antimony oxide industry is an important component of the industry
profile because the organization provides insights into how the industry will respond to increased
costs.
Three companies produce antimony oxide: Amspec Chemical Corp., Laurel Industries,
and U.S. Antimony. Each company operates one facility. One of the facilities has had recent
changes in ownership, but overall production capacity has not been affected. Table 2-1 shows the
company, the facility location, and production at each facility. Capacity information was
unavailable, so the table lists production as provided by RCRA 3007 surveys.
Table 2-1. Characteristics of Major Antimony Oxide Producers
Company Facility location 1998 Production (MT/yr)
Amspec Chemical Corp. Gloucester City, NJ 6,621
Laurel Industries LaPorte, TX 9,133
U.S. Antimony Thompson Falls, MT 2,300
Source: Company surveys
Note: In 1998, the industry included a facility in Laredo, TX, owned by the Great Lakes Chemical Company
(GLCC). This facility produced 10,890 MT of antimony oxide in 1998. The company has since closed this
facility and moved its operations to Mexico.
The ownership of several antimony oxide producers has changed in recent years.
GLCC-Laredo was formerly Anzon, Inc. GLCC reached a deal to buy the Laredo facility from
Cookson in 1997 that produced 10,980 MT in 1998. GLCC has since closed this plant and
moved its production to Mexico. While no longer a domestic producer of antimony oxide, GLCC
may nevertheless be subject to the rule, depending on its selected management of a historic slag pile
at its Texas facility. For additional discussion of the regulatory status of the GLCC plant, see
Section 2.3.
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
Protection Agency. Reston, VA: SAIC. Pg. 58.
U.S. Geological Survey. "Antimony." Mineral Commodity Summaries. January 1999.
. As accessed September 1999.
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In addition, Laurel Industries, which produces approximately one-third of the antimony for
the U.S. market,6 recently acquired Elf-Atochem's facility, marginally increasing its production
capabilities. Finally, U.S. Antimony recently dissolved its partnership with Pressure Vessel
Services and now realizes 100 percent of the profits and reports 100 percent of sales.7
Table 2-2 provides financial information at the company level for antimony oxide. Of the
three companies for which data are available, two companies have fewer than 1,000 employees
and therefore meet the Small Business Administration's (SBA's) definition of a small business for
this industry.
Table 2-2. Company-Level Financial Information: Antimony Oxide
Profits
(Losses) Sales
Companies Facilities ($2000 106) ($2000 106) Employees
APOA
(Amspec)a
Occidental
(Laurel)"
U.S. Antimony0
Gloucester City, NJ
LaPorte, TX
Thompson Falls, MT
($0.191)
$1,570
($0.0677)
$22.0
$13,574
$5.0
65
8,791
25
NA = Not available
a Amspec Chemical Corp. Phone Conversation with Karen Bradshaw, May 11,2001.
b Hoover's Online, . Company Capsule. As accessed May, 2001.
0 U.S. Securities and Exchange Commission. May 2001. EDGAR database, .
2.1.4 Markets
Conditions in the markets for antimony oxide help determine the effect the regulation will
have on antimony oxide producers. As previously stated, antimony oxide is used primarily as a
flame retardant; in 1990, 20,000 metric tons were used for this purpose8. Overall, domestic
Scheraga, Dan. "OxyChem's Laurel Buys Elf Line in Flame Retardant Consolidation."
Chemical Market Reporter, New York; December 22, 1997.
www.chemexpo.com/schnell/cmr.html. Accessed June 11, 1999.
U.S. Antimony, . As accessed April 2000.
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
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production met consumer demand in 1980 and was expected to continue to meet demand as
production increased with economic growth9. Production and consumption trends for 1995
through 1999 are shown in Table 2-3. All figures are metric tons (MT) of antimony content in
antimony oxide. Antimony oxide weighs approximately 1.2 times the weight of its antimony
content. Accordingly, production of antimony oxide can be estimated in this way to have been
28,800 MT in 1998 and 28,560 MT in 1999.
Table 2-3. Production, Consumption, Imports and Exports of Antimony Oxide (MT)
Year
1995
1996
1997
1998
1999
Production
23,500
25,600
26,400
24,000
23,800
Imports
15,400
18,300
23,200
19,100
19,100
Exports Apparent Consumption
6,590
3,990
3,230
3,270
3,190
32,310
39,910
46,370
39,830
39,710
All figures in metric tons of antimony content.
Source: U.S. Geological Survey. Mineral Industry Surveys for Antimony, fourth quarter 1999 and fourth
quarter 2000. Accessedwww.usgs.gov. Accessed May 15, 2001.
Between 1985 and 1990, domestic production doubled. To accommodate production, the
United States imports a large amount of antimony and metal ore. Domestic sources are considered
inferior to imports because U.S. sources contain high arsenic levels. In 1988, 33,106 tons of ore
were imported into the United States, while only 1,353 tons were exported.10 The quantity of
antimony oxide imports and exports is shown in Table 2-3 for the years 1995 through 1999. Since
1996, consumption of antimony oxide has been relatively flat and production has been generally
declining. Imports increased until 1997 but have fallen sharply since then. Supply of antimony
metal has declined and its price has risen. Meanwhile, the price of antimony oxide fell by nearly 50
percent between 1996 and 2000 (see Table 2-4). These market trends have been difficult for
domestic antimony producers, and two companies that specialize in antimony oxide production,
Protection Agency. Reston, VA: SAIC. Pg. 58-59.
Ibid.
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
Protection Agency. Reston, VA: SAIC. Pg. 58-59.
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U.S. Antimony and Amspec, were unprofitable in 2000. U.S. Antimony in particular is threatened
with bankruptcy.
Table 2-4. Antimony Oxide Prices ($/lb)
Year
1996
1997
1998
1999
2000
High
4.5
5.75
5.57
5.52
5.88
Low
1.53
0.98
0.83
0.65
0.65
Average
1.86
1.41
1.13
0.85
0.99
Source: U.S. Securities and Exchange Commission. 10KSB for U.S. Antimony.
With only three domestic firms, producers (especially the larger ones) may have the power
to influence price, although substantial imports limit this effect. Antimony oxide producers may be
able to shift some of the costs associated with new regulations on to their customers. However,
because substitutes do exist, they will not be able to shift all of the costs on to consumers.
2.2 Industry Profile for Titanium Dioxide
This profile of the titanium dioxide segment of the inorganic chemicals industry describes the
supply of titanium dioxide, including production processes, production facilities, and the firms that
own them. Demand for titanium dioxide, the market structure of the industry, and markets for the
product are also a part of the profile.
2.2.1 The Supply of Titanium Dioxide
This section provides an overview of titanium dioxide production in the United States and
examines the raw materials used, production processes employed, and the costs of production.
The titanium dioxide industry comprises 64 percent of products produced under SIC code 2816.
Currently, five companies with 11 facilities produce titanium dioxide. These facilities use three
different processes to produce titanium dioxide. These are known and described as the sulfate
process, the chloride process, and the chloride-ilmenite process. These three processes are
described sequentially.
Sulfate Process. The sulfate process is complex and includes numerous stages and
intermediate steps. Producing titanium dioxide via the sulfate process requires sulfuric acid and
naturally occurring ilmenite ore (FeTiO3) or manufactured titanium-bearing slag as the major
material inputs. Titanium-bearing slag is an ilmenite/hematite mixture. This mixture of ores is
smelted, leaving iron and a slag that is rich in titanium.n For the sulfate process, sulfuric acid is
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
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used to dissolve the titanium dioxide out of this pulverized slag. Additional refinement is required to
produce different grades of the finished product.12
Chloride Process. In the chloride process, rutile or high grade ilmenite ore is reacted with
chlorine gas at high temperatures to produce titanium tetrachloride. The titanium tetrachloride is
then oxidized at high temperature, forming titanium dioxide and recyclable chlorine13. In the
discussion that follows, this process is referred to as the "chloride-only" process to distinguish it
from the chloride-ilmenite process. In reality, both processes are chloride processes, but they differ
in important ways, as discussed below.
Chloride-ilmenite Process. The chloride-ilmenite process is very similar to the chloride
process but uses low-grade ilmenite ore as an input. This low-grade ore has a much higher iron
content than the grade of ore used in the chloride process. The pulverized ore is reacted with
chlorine gas at high temperature with coke added as a reducing agent. In the first step of this two-
step reaction, the iron oxides in the ore react with the chlorine, forming iron chlorides that are
condensed and then sold or disposed of in the waste stream. What remains is enriched ilmenite
ore. In the second step, this ore is converted, as in the chloride process, to titanium tetrachloride.
The titanium tetrachloride is then oxidized to form titanium dioxide and recyclable chlorine.
Refinement steps within the process remove contaminants and improve the purity of the finished
product.14
Of these three methods of production, the chloride processes are newer and more widely
used. A comparison of the sulfate and chloride-only processes reveals that the sulfate process
creates large amounts of dilute acid effluent, whereas the chloride-only methods
produce a more toxic waste, but in lower volumes. A key difference is that chloride process
facilities can recover and recycle chlorine when either of the chloride methods is used.15 For
instance, producing 1 ton of titanium dioxide results in 12 tons of waste material from the sulfate
process and only 4 tons from the chloride-only process. However, iron chloride makes up a large
amount of the chloride-only process waste. Iron chloride is both acidic and hazardous; thus,
facilities using the chloride-only process minimize the amount of iron chloride waste by using higher
Protection Agency. Reston, VA: SAIC. Pg. 98.
12 Heil, Scott, and Terrance W. Peck, eds. 1998. Encyclopedia of American Industries, Second
Edition. Vol. 1: Manufacturing Industries. Detroit: Gale Research, Inc. Pg. 510.
13 Ibid.
14 Letter from C. Goldstein, Covington & Burling, Washington, B.C., to Randolph L. Hill, U.S.
Environmental Protection Agency, Office of General Counsel, November 16, 1990, p.2.
15 Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
Protection Agency. Reston, VA: SAIC. Pg. 97.
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grade, higher cost rutile or other purified titanium-containing materials in production.16 The
chloride-ilmenite process uses lower grade ores with higher iron content, producing higher
quantities of wastewater treatment solids than the chloride-only process.
The costs of producing titanium dioxide include the costs of obtaining variable inputs, such
as the raw materials, labor, transportation, and energy and fixed capital expenditures. Most of
these costs are assumed, under the current methodology, to be unaffected by the regulation. The
incremental costs of the rulemaking result from changes in waste management practices. Baseline
waste management practices and costs are discussed in Section 4.2.
2.2.2 The Demand for Titanium Dioxide
This section characterizes the consumption of titanium dioxide by describing the
characteristics of titanium dioxide, its uses and consumers, as well as possible substitutes in
consumption. The three titanium dioxide production processes result in titanium dioxide having
slightly different characteristics. Titanium dioxide produced using the sulfate process uses more
common raw materials and produces a less abrasive pigment product, while the chloride processes
result in a pigment with a better dry brightness.17 The chloride processes can produce higher
grades of titanium dioxide without additional handling. Furthermore, titanium dioxide produced
using the chloride processes uses less labor and equipment and is produced continuously, as
opposed to by the batch.18 These differences in the finished product affect the commercial
applications in which it is used.
Over 50 percent of the titanium dioxide produced is used in paints, varnishes, and lacquers.
In paints, titanium dioxide is used primarily to whiten and opacity polymeric binder systems. Even
mid to deep shades of paint usually contain some titanium dioxide. It is also used in coatings where
exterior durability is needed.
Approximately one-third of the titanium dioxide produced is used in the paper and plastics
industries. The paper industry uses titanium dioxide in two different applications: as a direct
addition to whiten and opacity the paper stock and in the manufacture of coatings that are applied
to the paper product. Titanium dioxide is used in plastics to impart whiteness and opacity. It is
used by the ink printing industry to control the optical properties and abrasivity of the inks. It is
used in a wide range of synthetic fibers (such as rayon, crepe, and taffeta) for delustering. Titanium
16 Heil, Scott, and Terrance W. Peck, eds. 1998. Encyclopedia of American Industries, Second
Edition. Vol. 1: Manufacturing Industries. Detroit: Gale Research, Inc. Pg. 510.
17 Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
Inorganic Chemicals Listing Determination DRAFT." Prepared for the U.S. Environmental
Protection Agency. Reston, VA: SAIC. Pg. 100.
18 Ibid.
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dioxide is also used in significant quantities by the rubber industry in the manufacture of whitewall
tires.
Finally, titanium dioxide is used in the manufacture of numerous other products including
enamel and glaze for ceramics, pharmaceuticals, thermoplastic roadline compounds, putties,
mastics, fillers, white shoe cleaners, leather coatings, roofing granules, correction fluids, bitument
and bituminous mastic, concrete-curing membranes, wire-drawing lubricants, lens polishes, lapidary
polishes, welding rod coatings, titanium chemicals, and catalysis.19
According to the U.S. Geological Survey, there are no cost-effective substitutes for titanium
pigment.20 However, in paper production, calcium carbonate can be used as a filler that is both less
expensive and that protects against cellulose degradation by acids in the air.21
2.2.3 Industry Organization
Titanium dioxide producers are categorized under SIC code 2816, inorganic pigments.
The SIC code represents numerous types of inorganic pigment producers, but titanium dioxide
producers overwhelmingly comprise the majority of the SIC code, making up 64 percent of the
products produced in SIC 2816.
Although the Herfindahl index is only available at a four-digit SIC code level, it may provide
a meaningful picture of the titanium dioxide industry in the United States. The index indicates a
highly concentrated industry with a value of 1,910 and only 73 producers in the entire SIC code.
Eleven facilities produce titanium dioxide in the United States, representing only
five companies. In addition, two facilities in Canada produce a total of 63,636 tons of titanium
dioxide, 18,185 tons of which are produced using the sulfate method. DuPont operates a chloride
facility in Mexico that produces 100,000 tons. Of the ten U.S. facilities, only two
companies—Kemira Oyj and Millennium Inorganics—produce titanium dioxide using the sulfate
method.
Table 2-5 presents characteristics of titanium dioxide producers. The table is organized
into three sections: facilities that use the chloride process and low-grade ilmenite ore (chloride-
ilmenite), facilities that use the sulfate process, and facilities that use the chloride process and high
grade ores (chloride-only). This organization facilitates the discussion of the regulations in the
following sections. It should be noted that the two facilities that use the sulfate process are paired
with adjacent chloride-only process facilities. The paired facilities, currently owned by the same
Ibid.
U.S. Geological Survey, . Mineral Commodity Summaries, January 1999.
Accessed July 1999.
Swaddle, T.W. 1997. Inorganic Chemistry: An Industrial and Environmental Perspective.
San Diego: Academic Press. Pg. 199.
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firm but analyzed based on 1999 ownership, mix some of their waste streams. In the analysis and
discussion, when these processes and waste streams are combined, they are referred to as
"chloride/sulfate."
Overall, titanium dioxide facilities are generally in the mid-90 percent capacity utilization
range, regardless of method.22 The industry is facing some changes in its structure. On April 1,
2000, Kemira transferred ownership of its Savannah plants to Kerr-McGee.23 This change will
affect Kerr-McGee's sales, income, and employment information. The change will also result in
Kemira dropping out of scope and in Kerr-McGee incurring all the costs associated with
compliance at the Savannah facilities as well as at its Mississippi plant. However, the only data
available to characterize the industry pre-date this sale. Thus, Kemira remains in the analysis and
Kerr-McGee's data are pre-transfer.
Table 2-6 provides company-level financial information. None of the five firms meets the
SBA's criterion as a small business.
22 ChemExpo. "Chemical Profile for Titanium Dioxide." Accessed
May 8,2000.
23 Kemira Oyj. "Kemira and Kerr-McGee Finalised Sale Contract on Kemira Pigments Titanium
Dioxide Pigment Plant in the U.S." . Accessed April 2000.
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Table 2-5. Characteristics of Titanium Dioxide Producers
Company
Chloride-Ilmenite Facilities
DuPont (C)
DuPont (C)
DuPont (C)
Chloride/Sulfate Facilities
Kemira (S)
Kemira (C)
Millenium Inorganics (C)
Millenium Inorganics (S)
Chloride-only Facilities
Kerr-McGee (C)
Louisiana Pigment (C)
Millenium Inorganics (C)
Millenium Inorganics (C)
Total
Facility location
DeLisle, MS
Edge Moor, DE
New Johnsonville,
TN
Savannah, GA
Savannah, GA
Baltimore, MD
Baltimore, MD
Hamilton, MS
Lake Charles, LA
Ashtabula, OH
Ashtabula, OH
Capacity in 2000
(Mt)
280,000
130,000
320,000
60,000
100,000
51,000
44,000
190,000
110,000
104,000
86,000
1,475,000
Production
(Mt)
266,000a
123,500a
304,000a
57,000a
95,000a
48,450a
41,800a
180,500a
121,956a
98,800a
81,700a
1,401,250"
Estimated
Revenues from
Ti02b($106)
604.0
280.4
690.3
129.4
215.7
110.0
94.9
409.9
276.9
224.3
185.5
3,181.9
a Plant production data were either CBI or not available. Production was estimated for these facilities, using a
95% industry-wide capacity utilization rate. Source: ChemExpo. "Chemical Profile for Titanium Dioxide."
Accessed June 16,2000.
b Estimate using production estimate times a price of $1.03 per pound. Source: ChemExpo. "Chemical Profile
for Titanium Dioxide." . Accessed June 16, 2000.
C = chloride method
S = sulfate method
2.2.4 Markets
This section summarizes conditions in the market for titanium dioxide. Between 1994 and
1996, production of titanium dioxide fell 36,000 tons to 1,217,800 tons, before rising again in
1997. Total shipments, including interplant transfers, fell by 40,909 tons to 1,229,818 tons from
1994 to 1996. However, the total value of shipments increased $14.6 million to $2.3 billion.24 In
1997, estimated capacity was 1,474,545 tons; capacity recently
U.S. Department of Commerce. 199 6 Manufacturing Prof ties, .
Accessed June 1999.
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Table 2-6. Company-Level Financial Information: Titanium Dioxide
Companies
DuPont
Kemirab
Kerr-McGee
Millennium
Inorganics
Valhi, Inc.
(Louisiana Pigment)
Facilities
DeLisle, MS
Edge Moor, DE
New Johnsonville, TN
Savannah, GA (2)
Hamilton, MS
Ashtabula, OH (2)
Baltimore, MD (2)
Lake Charles, LA
Profits3
($2000 106)
$2,314.0
$28.6
$842.0
$122.0
$76.6
Sales3
($2000 106)
$29,202.0
$2,416.0
$4,121.01
$1,793.0
$1,191.9
Employees3
(2000)
94,000
10,743
4,426
4,370
7,110
a Hoover's Online Company Data. . Accessed June 16,2000.
b 1999 Data. 2000 Data Not Available. Converted from Eurodollars based on 1 EUR$ = 1.045 US$. Universal
Currency Converter, . Accessed June 16,2000.
decreased for the sulfate process, while increases are expected for chloride-produced titanium
dioxide.25 In 1997, titanium dioxide production reached 1,342,952 tons.26 As shown in Table 2-5,
2000 production is estimated at 1,401,250 tons.
Meanwhile, 1997 domestic demand was 1,068,000 tons.27 In 1996, with titanium dioxide
production at 1,217,800 tons, the United States exported 332,200 tons and imported 167,100
metric tons. Thus, U.S. apparent consumption was 1,052,700 tons of titanium dioxide.28 Demand
was 1.13 million MT in 1997, 1.162 million MT in 1998, and is projected to be 1.283 million MT
in 2002.29
Demand was strong enough for the industry to raise prices at least twice in 1997. The price
improvement represents a partial recovery from 1995-1996 when global prices fell 15 percent. In
September 1997, the price for titanium dioxide ranged between $0.92 and $0.94 per pound.
ChemExpo. "Chemical Profiles." . Accessed June 1999.
U.S. Department of Commerce. 1997 Current Industrial Reports, .
Accessed June 1999.
ChemExpo. "Chemical Profiles." . Accessed June 1999.
U.S. Department of Commerce. 199 6 Manufacturing Prof ties, .
Accessed June 1999.
ChemExpo. "Chemical Profiles." . Accessed May 2001.
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Between 1981 and 1996, the market high was $1.04 per pound, and the market low was
$0.69 per pound.30 The price of titanium dioxide in 2000 was $1.03 per pound.31
Growth is projected in this industry in the range of 2 to 4 percent per year through the year
2001. Prices should continue to rise to their 1995 levels. Several capacity expansions put on hold
in 1997 are likely to be put into place as the market continues to look positive.
Given the recent increases in price, the limited availability of substitutes, and the positive
outlook for the industry, it seems likely that the titanium dioxide producers would be able to pass
some share of the costs of new regulations onto consumers. On the other hand, only one of the
producers is expected to incur compliance costs due to the listing. This may limit this producer's
ability to raise his prices.
2.3 Wastes from the Production of Inorganic Chemicals
The Agency collected data from producers of antimony oxide and titanium dioxide under
Section 3007 of RCRA. Using these data on current production residuals and residual
management practices, EPA analyzed 16 specific residuals generated in the above two production
processes for possible listing as hazardous wastes. Of the 16 residuals analyzed, only three
residuals are being listed. The residuals being listed for antimony oxide production are baghouse
filters (K176) and antimony oxide production slag (K177). The residual being listed for titanium
dioxide is ferric chloride filter residues (K178).
Some manufacturers of a particular product produce none of the wastes being listed and
are thus exempt from the listing. Others produce only one of the wastes for any particular sector.
This means that the number of companies affected by the listing is only a subset of the total number
of producers of each product.
Currently, producers of these wastes typically treat them as nonhazardous. In practice, this
means that the wastes may not be treated prior to impoundment and/or disposal to a Subtitle D
landfill. If these wastes were to be listed, producers would have to both handle them as hazardous
wastes and treat them to mitigate their hazardous characteristics. Disposal in a Subtitle C landfill or
hazardous waste incinerator would be required. Residuals that are currently stored in open air,
unlined impoundments would need to be stored in tanks or treated before disposal. Additional
costs for transport as a hazardous waste would also be incurred.
30 ibid.
31
ChemExpo. "Chemical Profiles." . Accessed May 2001.
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2.3.1 Listings
EPA is developing a notice of final rulemaking that lists the following wastes generated in
the production of antimony oxide and titanium dioxide as hazardous:
• K176: baghouse filters (antimony oxide),
• K177: antimony oxide production slag (antimony oxide), and
• K178: ferric chloride filter solids (titanium dioxide).
Table 2-7 shows the facilities that would be affected. A facility that produces antimony oxide could
exempt itself from the antimony oxide listings if it chose to recycle rather than dispose of the waste.
Table 2-7. Wastes and Facilities Affected
Product
Wastes Analyzed
To be Companies affected and waste
Listed? volume (Mt/y)
Antimony Antimony oxide production slag
Oxide
Baghouse filters
Yes U.S. Antimony (20)
Amspec (20)a
Yes Laurel Industries (4)
Amspec (3)
Titanium
Dioxide
Sulfate process digestion sludge No
Combined chloride-sulfate wastewater No
treatment solids
Secondary gypsum No
Combined chloride/sulfate wastewater No
Commingled chloride-only No
wastewaters
Ferric chloride filter solids Yes
Combined ilmenite wastewater No
Kemira (34,000)
Millenium Baltimore (CBI)
Kemira (66,000)
Millenium Baltimore (CBI)
Millenium Baltimore (CBI)
Kemira (9,600,000)
Millenium Baltimore (CBI)
Millenium Ashtabula 1 & 2 (CBI)
Louisiana Pigments (70,670)
Kerr-McGee (477,000)
DuPont Edge Moor (45)
DuPont DeLisle, Edge Moor, and
New Johnsonville (NA)
a Cookson could be affected by the low-antimony slag listing, depending on their chosen management of a 60,000
ton slag pile at their closed Laredo facility. However, a number of management options, including capping the slag
in place on-site, using it as a road sub-base or asphalt aggregate, or disposing of it in a Subtitle D industrial landfill
before the effective date of the final rule, make incremental costs associated with the listing unlikely.
In a comment on the proposed rule, the Cookson Group (previous owners of the site)
notes that 60,000 tons of smelter slag are presently stored at their Laredo plant, and that recycling
is not a viable option for them because of the low antimony and lead content. If this slag pile were
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loaded, transported, and disposed of as a hazardous waste after the listing took effect, Cookson
estimates the incremental costs to be $4.0 to 40.5 million. EPA acknowledges that these costs
could be incurred under the circumstances described by Cookson. However, EPA also notes that
the site is already undergoing corrective action by the state of Texas. If the listing goes into effect
before the cleanup is complete, several options are available in the context of corrective action that
do not involve removing the entire 60,000 ton slag pile and disposing of it in a Subtitle C landfill.
The least expensive would be closing the pile in place as a landfill, which can be done without
actively managing the pile. This option would not result in any incremental costs that are attributable
to this listing. The company could also elect to place the entire volume in a Subtitle D landfill prior
to the effective date of the rulemaking, which would also result in no incremental costs attributable
to this listing. Finally, the company could also elect to recycle its slag through an alkaline sulfide
leaching process at an average annual cost of $3.3 million which is comparable to the company's
estimate of its cost of placing the material in roadbed.32 This cost is not incremental for this final
rule.
Cookson Antimony Process Slag Conceptual Treatment Plant Study, Center for Advanced
Mineral & Metallurgical Processing, Montana Tech of the University of Montana, Butte
Montana, September 10, 2001
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CHAPTERS
METHODOLOGY AND DATA LIMITATIONS
This report estimates the economic impacts of the listings on certain sectors of the inorganic
chemicals industry. EPA's approach to modeling uses all of the publicly available and
nonconfidential information available about the firms and the industry in constructing the model to
create estimates of industry costs for waste treatment and disposal under the rule.
Using only nonconfidential data sources, including data provided by the industry through
RCRA 3007 questionnaires or obtained from publicly available sources, EPA characterizes each
affected facility in terms of its production of the inorganic chemical, its revenues from that
production, and its generation of listed wastes. Baseline waste management practices are assumed
to be in compliance with current regulations. Resulting characterizations are examined to ensure
that the final results do not compromise any particular firm's Confidential Business Information
(CBI).
This chapter summarizes the methods used to characterize plants and the companies
expected to be affected by the listing, estimates the costs they will incur, and analyzes the impacts
of the costs on their plant and company profits. Limitations of the economic modeling methodology
are identified.
3.1 Description of Affected Facilities
EPA has identified four facilities that will be directly affected by the listing. Of these four,
three produce antimony oxide and one produces titanium dioxide. In addition, another antimony
oxide facility, now closed, has a slag pile that under some circumstances could become subject to
the listing. These facilities are described below.
3.1.1 Affected Facilities Producing Antimony Oxide
Two facilities producing antimony oxide are potentially affected by the final listing, and one
facility that previously produced antimony oxide may be affected depending on its chosen waste
management. In addition, one facility that produces antimony oxide but currently recycles its
antimony oxide production slag may be affected if it decides to change its practice of recycling the
waste. The two facilities that are expected to be affected by the listing are shown, together with the
wastes they produce, in Table 3-1. Two facilities, owned by Laurel Industries and Amspec,
produce small quantities of baghouse filters. Another facility, owned by U.S. Antimony, produces
20 MT/year of antimony oxide production slag. This facility currently recycles its antimony oxide
production slag, so it will not be affected by the listing unless it changes this practice and begins
disposing of waste in a landfill. The
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Table 3-1. Antimony Oxide Facilities
Type of waste generated
Facility3 Low-antimony slag (MT/yr) Baghouse filters (MT/ yr)
Laurel Industries 4
Amspec 20 3
a U.S. Antimony currently generates 20 MT/yr of antimony oxide production slag, which it recycles and is
therefore not subject to the rulemaking.
facility owned by Amspec also produces 20 Mr/year of antimony oxide production slag. This
waste has been historically recycled and disposed of as a nonhazardous waste. Amspec's slag is
considerably higher in antimony than other antimony oxide producers, it will be modeled for
recycling only in this analysis. Amspec's slag will also be modeled for land disposal for sensitivity
analysis. The fourth facility, currently owned by GLCC, has a slag pile generated when the facility
was owned by Cookson. The facility is no longer operating to produce antimony oxide and is
undergoing corrective action by the state of Texas. As described in detail in Chapter 4, the Agency
believes that this company has several management options for the slag pile that would not make it
subject to the listing, and thus would minimize their costs of management. EPA assumes that they
will take the least-cost means of management available.
Under the final listing, treatment, transportation, and disposal practices would need to be
upgraded to reflect the hazardous nature of the wastes. These costs are calculated in Chapter 4
and would include disposal in a Subtitle C landfill and transport via hazardous waste hauler. Firms
affected by this listing could avoid these additional costs by recycling their wastes, a practice
common to the other firms in this sector. Table 3-2 summarizes baseline practices and changes that
would be required as a result of the listing.
3.2.2 Affected Facilities Producing Titanium Dioxide
The final listing will only affect facilities using the chloride-ilmenite process. The wastes
listed for this process are ferric chloride filter residues. Only DuPont's Edge Moor, DE, plant
generates ferric chloride filter residues that will be subject to this listing. Presently, Edge Moor
generates approximately 120,000 to 140,000 short tons (109,000 MT to 127,000 MT) of "Iron-
Rich." Of this volume, EPA estimates that approximately 10 percent, or 13,000 tons (11,794
MT), are ferric chloride filter solids. Much of this volume will be Bevill-exempt, however, once
DuPont moves the chlorine addition to a later point in the production process. DuPont reports that
only 50 tons (45 MT) of ferric chloride filter residues will be generated by this facility after the
process change (see Table 3-3).
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Table 3-2. Summary of Baseline and Listing Compliance Waste Management Practices
for Antimony Oxide Facility
Baseline practice
Compliance management
practice (treatment and
disposal)(Laurel only)
Compliance management
practice (recycling) (Laurel
& Amspec)
Loading as nonhazardous
waste
Transportation to landfill as
nonhazardous waste
Off-site disposal as a
nonhazardous waste
Loading as hazardous waste
Transportation to landfill as
hazardous waste
Off-site stabilization
Off-site disposal in Subtitle C
landfill
RCRA recordkeeping
Incremental administrative costs
Loading as nonhazardous
waste
Transportation to smelter as
nonhazardous waste
Smelter charges
Recovery of antimony values
Table 3-3. Titanium Dioxide: Chloride-Ilmenite Process, DuPont Edge Moor, DE, Plant
Type of waste generated
Amount of waste generated (MT/yr)
Ferric chloride filter residues
45
EPA evaluated the costs and impacts of the K178 listing under two alternative baseline
scenarios: that the ferric chloride filter residues are characteristic hazardous wastes or that the ferric
chloride filter residues are nonhazardous wastes. If the ferric chloride filter residues are
characteristic hazardous wastes at baseline, the incremental costs of the listing will be lower than if
the ferric chloride filter residues are nonhazardous at baseline. If these residues are characteristic
hazardous wastes, incremental costs only include the difference in costs between Subtitle D
disposal and Subtitle C disposal. This scenario is the basis for the Agency's lower-bound estimate
for this facility's potential costs. If, on the other hand, they are nonhazardous wastes at baseline,
then incremental costs would include transportation, treatment, and disposal. EPA's analysis
presents a range of costs, based on these alternative baseline scenarios.
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3.3 Characteristics and Limitations of the Economic Impact Analysis Method
EPA measured the economic impact of the regulation by comparing the estimated costs of
complying with the regulation to facilities' and companies' baseline revenues and, where data are
available to estimate them, baseline profits. Facility revenues were estimated by multiplying the
facilities' estimated production times the market price for the commodity. If the estimated costs of
compliance are a significant share of the plant's revenues from producing the commodity, the
product line may become unprofitable and production stopped. EPA does not have sufficient data
about production costs to estimate the baseline profitability of the individual product lines, so this
analysis is only approximate.
The Agency also compared the estimated costs of compliance with revenues and, where
available, profits for the companies owning the regulated facilities. These measures assess whether
the companies owning the facilities are expected to have the financial resources to purchase the
capital equipment and undertake the annual costs associated with compliance. If the costs of
compliance represent a substantial share of baseline revenues or profits, it is possible that the
companies will become less profitable as a result of complying with the regulation.
In both of these analyses, the costs of compliance, product line revenues, company
revenues, and company profits were analyzed without accounting for market responses to the costs
of the regulation. In reality, EPA expects firms facing regulatory costs to reduce the quantity of the
regulated product they offer at a given price, thus reducing the market supply of the commodity.
Depending on market conditions, this may result in an increase in the market price and a decrease
in the production of the commodity. Facilities that produce the product but are not in-scope of the
regulation (and thus incur no costs of compliance) may experience higher revenues, market shares,
and profits, while facilities that are directly affected by the regulation may experience higher costs
and lower market shares and profits.
EPA's analysis abstracts from these responses and distributional impacts. By assuming that
the facilities continue to produce the same quantities of the products and that market prices are
unchanged, EPA's estimated impacts could be considered worst-case estimates of impacts on
company profits for companies owning directly affected facilities. However, EPA notes that even
though this assumption presents a worst-case scenario for the inorganic chemical producers
themselves, in reality a decline in production and an increase in the price of the commodity would
result in a loss of consumer surplus in the economy, and smaller losses in producer surplus as
producers pass some of the costs on to their customers. The Agency believes that this loss and the
decrease in supply would be relatively small because of the modest level of costs in relation to the
value of the chemicals being supplied.
EPA presents qualitative information in Chapter 2 about the ability of inorganic chemical
producers to pass costs through to consumers. Particularly in the titanium dioxide market, where
only one facility is affected and its costs are estimated to be relatively low, very little change in price
is anticipated and EPA's full-cost absorption analysis may be a fairly accurate representation of the
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distribution of impacts in the economy. In the market for antimony oxide, relatively stagnant
consumption and somewhat increased imports of antimony oxide, falling market prices for antimony
oxide, and increasing prices for antimony metal have reduced the profitability of antimony oxide
production. These conditions may also affect the ability of antimony oxide producers to increase
their prices in response to the listing. The actual ability of inorganic chemical producers to pass
costs through depends on the elasticities of supply and demand of the commodities themselves.
And while quantitative elasticities are more informative than qualitative discussion, EPA does not
have the data necessary to estimate this information.
Also, as mentioned in Chapter 2, under Executive Order 12866, economic analyses of
Agency rulemakings are to address both the costs and benefits of regulation and alternative
approaches. Because of data limitations, the Agency has been unable to quantify all benefits
associated with this regulatory proposal and alternatives. The reader is referred to the background
document Risk Assessment for Listing Determination of Inorganic Chemical Manufacturing
Wastes^ for a description of individual risks posed by wastes proposed for listing under this
proposal.
U.S. Environmental Protection Agency. August 2000. Risk Assessment for Listing
Determination of Inorganic Chemical Manufacturing Wastes.
3-5
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CHAPTER 4
COSTS OF THE PROPOSED LISTING
After sampling and analyzing the wastes generated by these inorganic chemical producers,
the Agency has chosen to list two wastes from the production of antimony oxide and one waste
from the production of titanium dioxide. The wastes listed for antimony oxide production are
antimony oxide production slag and baghouse filters. The waste listed for titanium dioxide
production is ferric chloride filter residues. The individual wastes are listed in Table 2-7. These
wastes for listing either present individual risks that warrant hazardous waste listing or warrant
additional controls than those provided under RCRA due to their hazardous characteristics. This
chapter describes the cost analysis of the proposed listing for each of those sectors separately and
in detail. It also sums up all of the estimated costs for each of the scenarios of the proposed listing
to estimate the national cost of implementing either scenario of this rulemaking.
The examination of the affected industry sectors is divided into three parts. The first part
gives a brief review of current baseline conditions in each industry sector, including waste
management practices and the changes that will be necessitated by the proposed listing. The
second section uses this information to analyze the costs of the proposed listing. Section 4.3 sums
costs across all of the affected firms in all of the affected sectors to show the national costs of this
rulemaking.
4.1 Antimony Oxide
The antimony oxide industry generates wastes that are candidates for listing. This section
reviews the baseline waste management practices in the antimony oxide industry, provides a cost
analysis for the listing, and assesses its economic impacts.
4.1.1 Review of Baseline and Compliance Waste Management Practices
This section reviews the baseline and post-rule compliance waste management practices
incorporated into the cost and economic impact analysis. In the antimony oxide sector, baghouse
filters and antimony oxide production slag are the only two wastes that the Agency has chosen to
list, based on its risk assessment screening. Not all of the affected firms produce both wastes. The
baseline assumes that all affected companies are handling their waste according to current
regulations. Both wastes are nonhazardous at baseline, and affected facilities dispose of the wastes
by sending them to an industrial Subtitle D landfill without treatment, incinerating them, or recycling
them.
Listing the wastes as hazardous means that they will now be considered hazardous "from
the cradle to the grave" and, if land disposed, must be disposed of, even after treatment, in a
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hazardous waste (Subtitle C) landfill. However, the listing description for K177 slag is limited to
slags that are land disposed or speculatively accumulated. So, if the slag is recycled (i.e. antimony
recovery), it is not within the scope of the listing. Similarly, all hazardous wastes and residuals from
the production process must be transported to the landfill under a hazardous waste manifest by a
licensed hazardous waste hauler, which is more expensive than industrial waste transportation. As
noted above, both wastes would be conditionally exempt from listing as hazardous wastes if they
are recycled. Potentially affected generators thus have two scenarios in responding to the listing:
recycle the wastes (Amspec and Laurel) or manage them as listed hazardous wastes (Laurel only,
Amspec disposal cost presented as sensitivity analysis).
In modeling antimony oxide facilities for the cost and economic impact analysis, it was
assumed that the plants manage their waste as nonhazardous and transport it via common carrier
for disposal at an off-site Subtitle D landfill. Plants that currently recycle their wastes and continue
to do so are conditionally exempt from the listing.
Two of the facilities producing antimony oxide are expected to be affected by this regulation
because they both generate at least one of the wastes and do not currently recycle them. If either
or both of these two plants choose to recycle their wastes post-rule, then they will also be exempt
from the ruling.
4.1.2 Cost Analysis
The Agency estimated incremental costs associated with listing wastes from antimony oxide
production. Costs were estimated for each compliance method (treatment and disposal or
recycling) for each waste type.
The listed wastes are baghouse filters and antimony oxide production slag. This analysis
made the following assumptions:
1. Waste volumes are 4 MT/y and 3 MT/y for the two plants with baghouse filters and 20
MT/y for the plant with antimony oxide production slag.
2. For compliance by treatment and disposal, wastes are accumulated for 90 days then
loaded and transported to an off-site treatment and disposal facility.
3. For compliance by recycling, wastes are shipped once a year to the recycling facility (a
smelter).
4. For compliance by treatment and disposal, stabilization of post-rule wastes to universal
treatment standards (UTS) standards is required.
5. Costs for stabilization and disposal are based on the quantity of waste generated.
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Table 4-1 lists the unit cost for each of the management practices. Footnotes to the table
provide the source for each cost. The cost estimates are made using the unit costs in Table 4-1 for
Management practice Unit cost
Loading as nonhazardous waste $62.35/loada
Loading as hazardous waste $103.92/loadb
Transportation as nonhazardous waste $49.51/MT°
Transportation to recovery facility $44.39/MTd
Transportation as hazardous waste $246.45/MTe
Off-site stabilization $93.94/MTf
Off-site disposal in Subtitle D landfill $63.82/MT,B $302.69 minimum charge per load11
Smelter charges for antimony waste S123.48/MT1
Value of recovered antimony $64.06/MTJ
Off-site disposal in Subtitle C landfill $256.36/MT,k $2,340 minimum charge per load including
stabilization1
RCRA recordkeeping $51.53 for environmental technician, $21.64 for clerk™
Incremental administrative costs $1,147 initial cost"
U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 22. Estimated by deleting 1 hour from administration time listed in first footnote on page
22 and using an annual generation rate of 30 t/y . Converted to metric tons and updated to 1 999.
U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 21. Estimated from Table 4-3. 30 t/y annual generation rate. Converted to metric tons
and updated to 1999.
U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the Cost and
Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous under RCRA Subtitle C."
Prepared by DPRA Incorporated, January 10, 1998. p. 3-61, trucks with drums. Updated to 1999.
Derived from Form 3007 for the antimony oxide industry. Assumes transport distance of 1,250 miles.
U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the Cost and
Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous under RCRA Subtitle C."
Prepared by DPRA Incorporated, January 10, 1998. p. 3-61, trucks with drums. Updated to 1999.
U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 18. Extracted from Landfill Costs. Minimum cost per load of $2,267. Converted to metric
tons and updated to 1999.
U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the Cost and
Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous under RCRA Subtitle C."
Prepared by DPRA Incorporated, January 10, 1998. p. 3-41, Off-site Municipal Subtitle D Landfill. Updated to
1999.
U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 18. Taken from Landfill Costs. Estimated as the ratio of Subtitle D landfill unit cost to
4-3
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Table 4-1. Baseline and Compliance Management Unit Costs ($2000) (continued)
1 Derived from average price charged to accept waste for metals recovery. US EPA. Office of
Water, Office of Science and Technology. Waste Treatment Industry Questionnaire, 1991.
J Derived from USGS Mineral Industry Surveys, Antimony in the Third Quarter 1999. Assumes 15
percent of dust on filter bags or in slag is recoverable at 30 percent of the market price for
antimony. Market price for antimony taken as $0.64/lb.
k U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the
Cost and Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous
under RCRA Subtitle C." Prepared by DPRA Incorporated, January 10, 1998. p. 3-41, Off-site
Subtitle C Landfill. Updated to 1999.
1 U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the
Final Rule for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared
by DPRA, Inc. St. Paul. January 14, 2000. p. 18. Taken from Landfill Costs. Converted to
metric tons and updated to 1999.
m U.S. Environmental Protection Agency, Office of Regulatory Enforcement. "Estimating Costs for
the Economic Benefits of RCRA Noncompliance." December 1997 Update, Appendix B.
Assumes 5 hours environmental coordinator and 3 hours clerical time annually. Updated to 1999.
n U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection
Request Number [ ], "Reporting and Recordkeeping Requirements for the Proposed Rule on Listing
Hazardous Wastes from Inorganic Chemical Production." August 2000.
the compliance management practice chosen.
Tables 4-2 and 4-3 present the incremental costs of the listing for the antimony oxide sector
for each compliance scenario. The costs for all affected facilities are much higher for a firm if it
chooses the disposal option, where wastes are stabilized and disposed of in a subtitle C landfill. If
this method of compliance is chosen, Laurel, which produces baghouse filters, will be required to
make a one-time investment of $1,147 for permitting and administrative requirements associated
with waste disposal. The total annual costs for this facility will be $13,774.
Amspec produces baghouse filters and antimony oxide production slag. If it chooses the
disposal scenario, Amspec will have a one-time cost of $1,147 for administrative and permitting
requirements associated with waste disposal. In addition, this facility is expected to incur annual
costs of $13,774 as a result of the listing if it complies by choosing the stabilization and disposal
scenario. However, due to the high antimony content of Amspec's slag, it is assumed that this
material with the company's baghouse filters will be recycled rather than disposed. Disposal costs
for Amspec are presented in this report as sensitivity analysis only. U.S. Antimony, which produces
antimony oxide production slag, currently recycles this waste and is assumed to have incremental
costs equal to zero as a result of the listing.
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Table 4-2. Antimony Oxide Costs: Disposal Option3
Waste volume
Company _ (MT/yr) _ Cost ($/yr)
Am spec (Sensitivity Analysis Only)
Baseline
Waste
Baghouse filters 3
Antimony oxide production slag 20
Total volume 23
With-regulation
Waste
Baseline volume x 1.46, for cement stabilization 33.58
Cost
Minimum incremental charge for transportation, $13,666
offsite treatment and disposal at Subtitle C LFb
Annual incremental administrative cost $108
Total annual incremental cost $13,774
Laurel
Baseline
Waste
Baghouse filters 4
Antimony oxide production slag
Total volume 4
With-regulation
Waste
Baseline volume x 1.46, for cement stabilization 5.84
Cost
Minimum incremental charge for transportation, $13,666
offsite treatment and disposal at Subtitle C LFb
Annual incremental administrative cost $108
Total annual incremental cost $13,774
a Table includes costs for two antimony oxide production facilities. Only Laurel is being modeled to incur
disposal costs under the rulemaking. Disposal costs for Amspec are presented for sensitivity analysis only.
U.S. Antimony is currently recycling its antimony oxide production slag and is thus not expected to incur
costs.
b Both facilities incur the same cost, because their waste volume is low enough that they would incur the
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Table 4-3. Antimony Oxide Costs: Recycle Option"
Company
Waste volume
(MT/yr)
Cost ($/yr)
Amspec
Baseline
Waste
Baghouse filters
Antimony oxide production slag
Total volume
3
20
23
With-regulation
Waste
Baseline volume
Cost
Incremental loading and transportation
Smelter charges (123.48/MT) x volume
Recovery value (103.44/MT) x volumeb
Annual incremental administrative cost
Total annual incremental cost
23
-118
2,840
-2,379
108
415
Laurel
Baseline
Waste
Baghouse filters
Antimony Oxide production slag
Total volume
4
4
With-regulation
Waste
Baseline volume
Cost
Incremental loading and transportation
Smelter charges (123.48/MT) x volume
Recovery value (65.21/MT) x volumeb
Annual incremental administrative cost
Total annual incremental cost
-20
493
-261
108
321
Total national incremental cost
736
a Table includes costs for two antimony oxide production facilities currently expected to incur costs under the
rulemaking. U.S. Antimony is currently recycling its antimony oxide production slag and is thus not
expected to incur costs.
b Amspec is estimated to receive a higher recovery value because its waste is assumed to be 23 percent
antimony, while Laurel's waste is assumed to be 12 percent antimony.
4-6
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It is important to note that firms will not be likely to choose this compliance scenario. The
lowest cost compliance scenario is for firms to recycle wastes instead of stabilizing and disposing of
them. The Agency expects firms to choose the cost-minimizing strategy for compliance and recycle
their wastes. In so doing, Laurel will incur annual incremental costs of approximately $321.
Amspec will incur annual incremental costs of $415. Because the high antimony content (25
percent) of Amspec's slag, the facility is modeled for recycling only. Disposal costs for Amspec
are presented as sensitivity analysis only but are not attributed as incremental costs for the rule
making. The incremental costs for the recycling compliance scenario are shown in Table 4-3. The
total costs of the listing for the antimony oxide sector for both compliance scenarios are presented
in Table 4-4.
Table 4-4. Total Costs of the Listing for the Antimony Oxide Sector
Model facility type
Type of waste
Total quantity Total one- Total
of wastes time costs annual
treated (MT/y) ($) costs ($/y)
Stabilization and Subtitle C Disposal Compliance Scenario
Amspec (Sensitivity Analysis Baghouse filters/
Only) antimony oxide
production slag
Laurel
Total
Baghouse filters
Recycling Compliance Scenario
Amspec
Laurel
Total"
Baghouse filters/
antimony oxide
production slag
Baghouse filters
23
4
27
23
4
27
1,147 13,774
1,147
2,294
0
13,774
27,548
415
321
736
U.S. Antimony produces 20 MT/y of antimony oxide production slag. Because it already recycles this waste,
it will incur zero costs as a result of the listing. If it chooses to dispose of wastes instead of recycling, it could
incur costs and associated economic impacts.
4.1.3 National Costs
The estimated incremental annual costs to the antimony oxide sector of the inorganic
chemicals industry as a result of this listing were calculated by multiplying the total annual costs of
each of the facilities by the number of affected facilities. The results are shown in Table 4-5.
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Table 4-5. Total Annualized Costs of the Proposed Listing: Antimony Oxide
Total annualized
Total capital costs costs
Disposal as hazardous waste $2,294 $13,774
Recycle $0 $736
The analysis shows that costs for plants and firms in the antimony oxide industry will be
minimal as a result of this listing. The recycling scenario is significantly less expensive, so it is
assumed that all firms affected by the ruling will choose this scenario to comply with the proposed
listing. The total annualized costs for the recycling scenario are carried forward to Section 4.3 of
this chapter, where they are summed with the costs and economic impacts on other affected
industry sectors to arrive at the total costs of the proposed listing.
4.2 Titanium Dioxide
This section reviews the titanium dioxide industry and provides cost analysis of the
proposed listing.
4.2.1 Review of Baseline and Compliance Waste Management Practices
This section reviews the baseline and post-rule compliance waste management practices
that are incorporated into the cost and economic analysis of the titanium dioxide industry. After
completing its risk assessment screening, EPA identified one waste by-product resulting from
titanium dioxide manufacturing using the chloride ilmenite process for listing: residues from
manufacturing of ferric chloride from acids formed during the production of titanium dioxide using
the chloride-ilmenite process (hereafter ferric chloride filter residues). The wastes are considered
nonhazardous at baseline, and affected facilities currently dispose of the wastes in Subtitle D
landfills or treat the wastes in impoundments.
One of these wastes, ferric chloride filter residues, is considered for listing. Because there
are three distinct processes for producing titanium dioxide, not all of the facilities produce all of the
wastes. Table 2-7 lists which facilities produce which waste, including the single facility that is
affected.
In analyzing the titanium dioxide facility for cost and economic impacts, EPA estimated
costs under two alternative assumptions: that the plant manages the waste as non-hazardous and the
plant manages the waste as hazardous. These assumptions affect costs estimated for loading,
transportation, and type of landfull (Subtitle C or D) used for disposal. Any waste managed on-site
would be stored in piles or treated in an impoundment. Only one of the facilities producing titanium
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dioxide is expected to be affected by this regulation because it generates one of the wastes
considered for listing.
4.2.2 Cost A nalysis
Incremental costs for the listing of a waste were calculated based on the amount of a
particular waste generated by a plant multiplied by the extra costs associated with treating and
disposing of the waste as hazardous post-rule. Waste stream quantities for each plant were
obtained from Form 3007 information (non-CBI) and a May 4, 2001, letter submitted to EPA by
DuPont (non-CBI).
The following assumptions were used for estimating costs (input quantities are based on
typical plants):
1. Ferric chloride filter residues that are not Bevill-exempt are 45.4 MT/yr.34
2. For compliance with Subtitle C solids disposal, wastes are accumulated for 90 days
and then loaded and transported to an offsite disposal facility.
3. Costs for disposal are based on the quantity of waste generated.
4. Post-rule management requires administrative costs that include permit revisions,
recordkeeping, and hazardous waste manifest preparation.
Table 4-6 lists the unit cost or cost function for each of the management practices.
Footnotes to Table 4-6 give the source for each cost or cost function. Costs were estimated using
the unit costs or functions in Table 4-6 for aggregated solids accumulated over a 90-day period.
Table 4-7 shows a detailed breakdown of the incremental costs for two scenarios: a high
incremental cost scenario and a low incremental cost scenario. Under the high incremental cost
scenario, DuPont is assumed to manage its wastes as non-hazardous at baseline. The low
incremental costs scenario assumes that the facility is managing its wastes as characteristic
hazardous wastes at baseline. In other words, they are treating them as hazardous until the
hazardous characteristic is no longer present and then disposing of the wastes in a subtitle D landfill.
In the low-cost scenario, the chloride-ilmenite facility is estimated to incur annualized costs of
approximately $114,000 for the disposal of its wastes. Under the new listing, the firm will be
required to treat wastes as hazardous "from cradle to
E-mail from Paul Borst, U.S. EPA, to James Turner, Research Triangle Institute. This quantity
is based on information provided to EPA by the facility.
4-9
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grave" and dispose of them in a subtitle C landfill. If the facility is not treating the listed wastes as a
RCRA waste at baseline, than its compliance costs are estimated to be approximately $157,000,
Table 4-6. Baseline and Compliance Management Unit Costs ($2000)
Management practice
Unit cost or cost function
Loading as nonhazardous waste
Loading as hazardous waste
Transportation as nonhazardous waste
Transportation as hazardous waste
Offsite disposal in Subtitle D landfill
Offsite disposal in Subtitle C landfill
Incineration
Administrative costs
$62.35/loada
$103.92/loadb
$49.51/MTC
$246.39/MTd
$63.82/MT,e $302.69 minimum charge per loadf
$256.36/MT,B $1,497 minimum charge per load11
$734.03'
$1,147J
a U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 22. Estimated by deleting 1 hour from administration time listed in first footnote on page
22 and using an annual generation rate of 30 t/y. Converted to metric tons and updated to 1999.
b U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wasterwater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 21. Estimated from Table 4-3. 30 t/y annual generation rate. Converted to metric tons
and updated to 1999.
c U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the Cost and
Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous under RCRA Subtitle C."
Prepared by DPRA Incorporated, January 10, 1998. p. 3-61, trucks with drums. Updated to 1999.
d U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the Cost and
Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous under RCRA Subtitle C."
Prepared by DPRA Incorporated, January 10, 1998. p. 3-61, trucks with drums. Updated to 1999.
e U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the Cost and
Economic Impact Analysis of Listing Four Petroleum Refining Wastes as Hazardous under RCRA Subtitle C."
Prepared by DPRA Incorporated, January 10, 1998.
h U.S. Environmental Protection Agency, Office of Solid Waste. "Regulatory Impact Analysis of the Final Rule
for 180-Day Accumulation Time for F006 Wastewater Treatment Sludges." Prepared by DPRA, Inc. St. Paul.
January 14, 2000. p. 18. Taken from Landfill Costs. Converted to metric tons and updated to 1999.
1 Environmental Technology Center, http://www.etc.org/costsurvey2.cfm. Accessed April 2001.
j Supporting Statement for EPA Information Collection Request Number [ ], "Reporting and Recordkeeping
Requirements for the Proposed Rule on Listing Hazardous Wastes from Inorganic Chemical Production."
August 2000.
including higher costs for handling and transportation, incremental treatment, and incremental
disposal costs.
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4-11
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Table 4-7. Titanium Dioxide Costs: Ferric Chloride Filter Solids Generated by DuPont
Edge Moor
High Incremental Cost Scenario: Waste is
nonhazardous at baseline Waste volume (MT/yr) Cost (S/yr)
Baseline
Waste
Ferric chloride filter solids 45
Cost
Transportation, handling, and Subtitle D LF disposal $2,895
With-regulation
Cost
One-time costs
Capital cost for moving chlorine line $1,125,000
Permit modification $1,147
Total $1,126,147
Annual costs
Incremental transportation and handling $9,097
Incineration $33,296
Offsite ash disposal in Subtitle C LF $11,047
Annualized capital costs $106,189
Annual incremental administrative cost $108
Total $159.737
Incremental cost of high-cost scenario $156,842
Low Incremental Cost Scenario: Waste is characteristic hazardous waste at baseline
Baseline
Waste
Ferric chloride filter solids 45
Cost
Transportation, handling, incineration, and $2,750
Subtitle D LF disposal of ash
With-regulation
Cost
One-time costs
Capital cost for moving chlorine line $1,125,000
Permit modification $41,147
Total $1,126,147
Annual costs
Offsite ash disposal in Subtitle C LF $11,047
Annualized capital costs $106,189
Annual incremental administrative cost $108
Total $117.199
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Table 4-8 gives an overview of the capital and annual incremental costs associated with the
listing for both scenarios. DuPont is expected to have approximately $1.1 million in capital costs
and total annualized costs of between $114,000 and $157,000, depending on their baseline waste
treatment practices.
Table 4-8. Incremental Treatment and Disposal Costs for TiO2 Facilities Changing to
Listed Wastes ($2000)
Total quantity of Overall Total
wastes treated, Capital cost unit cost, annual cost,
Facility baseline condition MT/y for residues, $ $/MT $/y
DuPont Edge Moor treating as non- 45.36 1,125,000.00 2,809.57 156,842
RCRA
DuPont Edge Moor treating as RCRA 45.36 1,125,000.00 2,367.26 114,449
4.2.3 National Costs
Because only one facility is going to be affected by the listing, the national costs of the listing
of titanium dioxide are equal to the costs shown above for the DuPont Edge Moor facility.
4.3 Total Annualized National Costs
Table 4-9 summarizes the total national costs for each of the affected sectors of the
inorganic chemicals industry for the listing chosen by the Agency. The table shows the total
annualized national costs for the listing and the lump sum capital investments the listing will require.
Capital costs for the titanium dioxide industry are significant and estimated at approximately $1.1
million. In the antimony oxide industry, one-time investments required are expected to be
approximately $1,147 for a firm choosing to stabilize and dispose of wastes and $0 for a firm
choosing to recycle its wastes. The annualized costs include capital costs, annualized over the
expected lifetime of the equipment, and additional administrative and operating expenses that may
be incurred as a result of the listing. Annualized costs depend on the method of compliance chosen
by the firms in the antimony oxide sector and the baseline treatment of wastes in the titanium dioxide
facility. If firms in the antimony oxide industry choose the cost-minimizing strategy and recycle their
wastes and if the affected DuPont facility treats its wastes as RCRA wastes at baseline, then the
total annualized national cost of the listing is estimated at approximately $115,000. If firms in the
antimony oxide industry choose to stabilize and dispose of wastes and if the affected DuPont facility
treats its wastes as non-RCRA wastes at baseline, then the total annualized national cost of the
listing is estimated at approximately $184,000.
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Table 4-9. National Costs of Listing
Industry
Titanium dioxide
Titanium dioxide
Antimony oxide
Antimony oxide
Total costs: minimum
Total costs: maximum
Compliance scenario
Treating wastes at baseline as Non-
RCRA
Treating wastes at baseline as RCRA
Stabilization and Subtititle C disposal
Recycling
Capital cost
$1,125,000
$1,125,000
$2,294
$0
$1,125,000
$1,127,294
Total annual
cost
$156,842
$114,449
$13,774
$736
$115,185
$170,616
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CHAPTER 5
ECONOMIC IMPACTS
The economic impact analysis uses information on industry structure and firm-level sales
and profits from Chapter 2, along with the cost estimates developed in Section 4.3, to examine the
impacts of the proposed listing in the context of the affected companies' baseline financial condition.
This chapter also estimates the economic impacts of the proposed listing compared to its revenues
from production of the affected chemicals. EPA estimates that the companies will not be severely
affected by this regulation, even under the higher-cost assumptions made for each sector.
5.1 Economic Impact Analysis—Antimony Oxide Sector
When the hazardous waste listing goes into effect, the cost of producing antimony oxide will
increase for the affected facilities. Because only two of the five domestic producers are expected
to incur incremental costs due to this listing and the market for antimony oxide has recently been
characterized by falling prices, EPA estimates that the affected producers will be unable to pass the
costs they incur along to their customers. Thus, EPA's economic impact analysis assumes that
producers will fully absorb the costs of responding to the rulemaking. This will reduce their profits.
However, the conditional nature of the listing enables them to select the cost-minimizing response.
In this case, the cost-minimizing response for all companies affected is to recycle their wastes. If
they choose the cost-minimizing recycling option, EPA estimates that the costs to any of the
affected firms will increase only slightly.
5.1.1 Estimated Economic Impacts on Affected Antimony Oxide Facilities and Firms
As described in Chapter 4 the market supply of antimony oxide is unlikely to be significantly
affected as a result of the costs attributed to the rulemaking. Because the costs associated with this
rulemaking are relatively small compared to the baseline cost of antimony oxide production, and
especially small compared to baseline company costs and revenues, the decrease in supply is
expected to be quite small.
The impacts of the regulation on affected companies were measured by comparing the
costs of compliance to the company's baseline revenues from antimony oxide production to the
company's baseline total revenues and to their baseline profits. The impacts were estimated
assuming that the companies are unable to change the price of antimony oxide, so that they are
absorbing all of the compliance costs for either Subtitle C landfill disposal or recycling. Tables 5-1
and 5-2 show that the costs associated with compliance comprise a
5-1
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Table 5-1. Economic Impacts for Companies Choosing Nonrecycling Compliance
Scenario: Facility Impacts
Company
APOA (Amspec)
Laurel
Quantity
(MT)
23
4
Total annual
costs (S)
$13,774
$13,774
1998 Antimony
Oxide Production
(MT)
6,621
9,133
Estimated
Antimony Oxide
Revenues (S)
14,450,690
19,933,266
Cost/ Antimony
Oxide Sales (%)
0.095%
0.069%
Note: U.S. Antimony currently recycles its 20 MT/year of antimony oxide production slag, and is thus not
expected to incur incremental compliance costs due to rulemaking. If it chooses to dispose of its slag
instead of recycling it, it could incur costs and impacts. Amspec's cost is for sensitivity analysis only.
Table 5-2. Economic Impacts for Companies Choosing a Recycling Compliance Scenario:
Facility Impacts
Company
APOA
(Amspec)
Laurel
Quantity
(MT)
23
4
1998 Antimony
Total annual Oxide Production Estimated Antimony Cost/Antimony Oxide
costs (S)
$451
$321
(MT)
6,621
9,133
Oxide Revenues (S)
14,450,690
19,933,266
Sales (%)
0.003%
0.002%
small share of estimated revenues from the sale of antimony oxide. Tables 5-3 and 5-4 show that
the costs of complying with the rulemaking represent a small share of baseline company sales
revenues.
For both affected producers, costs of complying with the listing are projected to be at most
0.1 percent of their baseline revenues from the sale of antimony oxide. If they choose the cost-
minimizing recycling option, the costs are projected to be less than 0.01 percent of baseline
antimony oxide revenues. The costs of compliance are an even smaller share of baseline company
revenues.
While EPA's costs appear insignificant compared to the revenues of antimony oxide
producers, it should be noted that two of the producers, U.S. Antimony and Amspec, are
unprofitable at baseline, due to recent market trends. Although U.S. Antimony is not expected to
incur compliance costs due to the regulation, Amspec is projected to experience modest increased
costs to manage their baghouse filters and antimony oxide production slag. The price of antimony
metal has increased, in part because China has reduced the amount it
5-2
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Table 5-3. Economic Impacts for Companies Choosing Nonrecycling Compliance Scenario
Quantity Total annual Cost/sale Cost/
Company Type of waste (MT) costs (S) Sales (S) s Profits (S) profits
APOA Baghouse filters/
(Amspec) antimony oxide
(sensitivity production slag
only)
Laurel Baghouse filters
23
$13,774
$22,000,000 0.0626%
-$191,000 -7.2%
$13,774 $13,574,000,000 0.0001% $1,570,000,000 0.001%
Table 5-4. Economic Impacts for Companies Choosing a Recycling Compliance Scenario
Company
APOA
(Amspec)
Laurel
Type of waste
Baghouse
filters/
antimony oxide
production slag
Baghouse
filters
Quantity
(MT)
23
4
Total annual
costs (S)
$451
$321
Sales (S)
$22,000,000
$13,574,000,000
Cost/sale
s
0.002%
<0.001%
Profits (S)
-$191,000
$3,616,000,000
Cost/
profits
-0.24%
<0.001%
exports, and in part because at least one mine has ceased mining for antimony. Energy prices have
also risen. At the same time, antimony oxide prices have fallen by nearly 50 percent between 1996
and 2000. For these reasons, antimony oxide production is less profitable than it was several years
ago. For these two companies, antimony oxide production is a large share of their business. Thus,
these market trends have made them unprofitable. In response to these conditions, U.S. Antimony
has begun development of a large zeolite deposit in an effort to become more profitable35. Amspec
is owned by a small business, APOA, which was unprofitable in 2000. Because Amspec's slag
and filters average over 20 percent antimony when combined, this material is expected to be
recycled post-rule. Disposal costs for these materials are presented for sensitivity analysis only. .
5.2 Economic Impact Analysis—Titanium Oxide Sector
This section examines the costs of the proposed regulation in the context of the companies'
baseline financial conditions. Using facility and firm information, EPA estimates that the company
affected by the listing will not experience any significant economic impacts.
5.2.1 Estimated Economic Impacts on Affected Facilities and Firms
http://biz.yahoo.com/bw/010604/2492.html. Accessed July 3, 2001.
5-3
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EPA measured the impacts of the regulation on companies' titanium dioxide operations by
comparing the costs of compliance to the company's baseline sales of titanium dioxide. Impacts on
the companies owning titanium dioxide facilities were measured by comparing compliance costs to
total revenues and total profits for the affected company in the titanium dioxide industry. The
estimated impacts of the regulation were calculated keeping the price and quantity sold of titanium
dioxide unchanged so that companies absorb all of the compliance costs and experience no
increase in revenues. Because only one titanium dioxide producer is projected to incur incremental
costs to comply with the listing, it is unlikely that it will be able to pass much of the costs along to
their customers in the form of higher prices. To the extent that this is an unrealistic model of
producer behavior, this analysis overestimates impacts on firms.
EPA estimated costs of compliance, as discussed in Chapter 4, under two alternative
scenarios. Based on information contained in a letter from DuPont's Edge Moor plant to EPA,
there is reason to believe that DuPont may manage the waste, in the absence of the listing, as
characteristic hazardous waste. If so, the only incremental costs of the listing will be some
administrative costs and the additional cost of disposing of the treated waste (EPA's analysis
assumes incinerator ash) in a Subtitle C landfill rather than a Subtitle D landfill. If, on the other
hand, the waste is managed as nonhazardous waste at baseline, the incremental costs would include
higher transportation and handling costs, treatment costs, plus higher disposal costs and
administrative costs. EPA analyzed the impacts of the listing on DuPont under both scenarios,
providing a range of possible impacts.
Table 5-5 shows the total annualized costs for the titanium dioxide facility. Compliance
costs comprise less than 1 percent of the revenues earned by titanium dioxide facilities from the sale
of titanium dioxide.
Table 5-6 shows estimated impacts of the rulemaking on the affected company owning
titanium dioxide facilities. The table shows that the total annual cost represents a small share of total
sales and profits. The cost as a share of sales and profits represents less than 0.1 percent for the
affected company.
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Table 5-5. Company Impacts—DuPont
Baseline waste
management
Non-RCRA
RCRA
Total annual
costs
$156,842
$114,449
Sales
$29,202,000,000
$29,202,000,000
Cost/sales
(%)
<0.001%
<0.001%
Profits
$2,314,000,000
$2,314,000,000
Costs/
profits
0.007%
0.005%
Overall, EPA expects the rulemaking to have only a moderate financial impact on the
affected company owning titanium dioxide production facilities. Because the company is
Table 5-6. Facility Impacts—DuPont Edge Moor
Baseline
waste
treatment
Non-RCRA
RCRA
Total annual
costs
$156,842
$114,449
Capacity (MT)
$130,000
$130,000
Production
(MT)
123,500
123,500
Estimated sales
($1.03/lb)
$280,436,143
$280,436,143
Costs/
sales
0.056%
0.041%
relatively large, it is estimated that it has the resources to comply with the rulemaking without
incurring adverse financial impacts.
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CHAPTER 6
FEDERALISM ANALYSIS
Under Section 6 of Executive Order 13132 (August 4, 1999)36 on Federalism, agencies
are required to consult with state and local officials when developing regulatory policies that have
federalism implications. Policies that have federalism implications are defined in Section 1 of the
Executive Order as including regulations that have "substantial direct effects" on the states. The
purpose of this analysis is to determine whether this notice of proposed rulemaking has substantial
direct effects on states affected by the proposal. Because the purpose of the Executive Order
13132 is to "further the policies of the Unfunded Mandates Reform Act" (UMRA)37, EPA has
applied the $100 million threshold specified in §202 of UMRA to quantify "substantial direct
effects" for purposes of determining whether this rulemaking has federalism implications. For the
reasons stated below, the rulemaking for listing of wastes from inorganic chemical production does
not have substantial direct effects or federalism implications associated with this rationale on state or
local governments.
State and local governments who either implement or who are subject to the provisions of
this rulemaking could incur four types of potential costs: 1) administrative costs (reading and
understanding the regulation, processing notifications and other reporting requirements, record
management, other), 2) state program authorization revision costs (amending their state
authorizations to include newly listed wastes), 3) enforcement costs (inspection, settlement, litigation
costs), and 4) direct compliance costs (e.g., a municipally owned landfill required to manage it's
leachate as hazardous waste). Taking all of these costs together, if the total expenditure in any one
year resulting from this rule does not exceed $100 million, then the rule would not have "substantial
direct effects" on state and local government and therefore not have federalism implications for this
reason (other rationales for federalism implications are addressed in the preamble to this
rulemaking).
36 64 FR 43255 (Tuesday, August 10, 1999)
E.O. 13132, Introduction
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Four states have jurisdiction over wastes listed in this rulemaking produced by four
potentially affected facilities. These states and facilities are New Jersey (Amspec), Montana (U.S.
Antimony), Texas (Laurel Industries), and Delaware (DuPont Edge Moor).38
Regarding administrative costs, all the potentially affected facilities are previously regulated
under RCRA. Therefore, affected states would not incur additional facility reports from this
proposal (including 3010 notification, Biennial Reporting System reports, etc.). There may be
some administrative cost from reading and familiarization with the rule. This cost is likely to be
nominal, less than $3,000.39
Regarding state authorization, all of the states affected by this proposal are authorized for
the base RCRA program. This means that, for these states to be authorized for the new hazardous
waste listings, they would need to revise their program. State program authorization revision
applications are estimated to cost approximately $6,500 per respondent (state).40 Thus, the total
state authorization cost associated with this rulemaking would be approximately $26,000 ($6,500
per revision application x 4 states).
Because only four facilities potentially are affected by this proposal, this represents the
upper bound number of inspections, settlements, and enforcement actions potentially incurred by
state and local government. EPA has used a model inspection, settlement, and litigation approach
for this analysis. Because not all inspections costs may be fully enumerated, the Agency has
adjusted the estimate upward by 15 percent to account for any unenumerated costs. EPA has
estimated the upper-bound enforcement cost incurred by state and local governments from this
rulemaking to be less than $550,000.
Inspection costs are modeled with one state inspector having an annual case load of four
cases at 520 hours per case (0.25 FTE x 2,080 hours = 520 hours). Using an loaded labor rate of
Of the four potentially affected facilities, only three (Amspec, Laurel Industries, and DuPont
Edge Moor) are projected to incur incremental costs due to the listing. U.S. Antimony
currently recycles its antimony oxide production slag and is thus not projected to incur costs.
However, if U.S. Antimony chose to treat and dispose of its slag instead of recycling it, it
would be subject to the listing.
For example, in estimating respondent burden for Information Collection Requests, the time
and cost of reading regulations have been between 0.1 and 8 hours and between $25 and $680
per respondent. Supporting Statement for EPA Information Collection Request Number
1189.05 Identification Listing and Rulemaking Petitions, 1/16/98, Supporting Statement for
EPA Information Collection Request Number 0820.06, Hazardous Waste Generator Standards,
7/15/97. Thus, upperbound rule familiarization costs for this rulemaking would be
approximately $5,000 total (4 states x $700 per state).
U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection
Request Number 969 Final Authorization For Hazardous Waste Management Programs,
December 1998. Exhibits.
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$47.5241 for state inspectors, this amounts to roughly $25,000 labor cost per inspection per year.
Sampling costs from the inspection are expected to average $15,000.42 Unenumerated costs are
estimated at 15 percent of labor and sampling cost resulting in $6,000 ($40,000 labor plus sampling
x 0.15). The average state inspection cost associated with this rulemaking is $46,000 per
inspection.
If the inspection results in either an administrative or judicial action being filed, then either
settlement costs or litigation costs would need to be added to the inspection costs to determine the
aggregate enforcement cost. Based on conversations with EPA enforcement personnel, an average
Agency RCRA enforcement attorney has a caseload of two to three cases per year that take up 50
percent of his time.43 This translates to a maximum of 0.25 FTE per case (two cases times 50
percent). EPA enforcement personnel indicated that the actual time spent on a case would depend
on how long it took the case to settle. Cases that might settle quickly would take 3 to 4 months.
Longer cases could take over 1 year. Thus, the range of hours per year that an attorney might
devote to a case could vary from 200 to 80044 hours (assuming a higher percentage of time in the
event of a trial). Using an average loaded labor rates for state attorneys of $62.85 per hour,45 the
total labor cost settling or litigating a case could range from $12,500 for a quick 4-month settlement
to $50,000 per case per year. Because cases are more likely to settle than go to trial, this analysis
assumes a value of $15,000 per case filed. In the event of a trial, expert witness costs are
estimated at $10,000 per case.
With a total of four facilities potentially affected by this proposal, even if all facilities were
inspected and cases were filed (an unlikely event), the total expenditure of states for these
enforcement activities would not exceed $245,000 (four facilities x $61,000 per inspection/case)
Ibid., p.18.
Assumes an average of 10 samples per inspection at a cost of $1,500 per sample TLCP
analysis for a range of metal analytes. TCLP cost for metal analytes, best professional
judgment, Oliver Fordham, Inorganic Chemical Program, U.S.EPA Office of Solid Waste, June
16,2000.
Personal communication between Paul A. Borst, EPA Office of Solid Waste and Lewis
Maldonado, EPA Region 9, Office of Regional Counsel, June 19, 2000.
This analysis assumes one attorney FTE equal to approximately 2,500 hours per year. 2,500
per year * 0.25 FTE = 625 hours per year. A case that settles in 4 months is assumed to take
approximately 200 hours. A case that exceeds 1 year, 600 to 800 hours (if a higher percentage
of time is involved).
U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection
Request Number 969 Final Authorization For Hazardous Waste Management Programs,
December 1998. p. 18.
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No state or local government entities would incur direct compliance costs as a result of this
Table 6-1. Summary of Upperbound State and Local Expenditures Associated with the
Inorganics Proposed Listing of Hazardous Waste
Cost estimate $103
Administrative <5
State authorization 26
Enforcement 245
Direct compliance 0
proposal. Therefore, as broken out in Table 6-1, the estimated expenditure for state and local
governments in any one year from this rulemaking would be less than $600,000 per year.
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CHAPTER 7
CONCLUSIONS
After sampling and analyzing the wastes generated by these inorganic chemical producers,
the Agency has decided to list as hazardous wastes specified wastes from the antimony oxide
sector and the titanium dioxide sector. Based on the data and analysis available, the Agency
determined that three wastes from two production processes in the inorganic chemicals industry
either present individual risks that warrant hazardous waste listing or warrant additional controls
than those provided under RCRA because of their hazardous characteristics. As a result, the
Agency has decided to list baghouse filters (K176) and antimony oxide production slag (K177)
from the antimony oxide industry and ferric chloride filter residues (K178) from the titanium dioxide
industry as hazardous wastes.
This report provides an economic impact assessment of the listing. The report characterizes
baseline conditions in affected sectors, describes the methods used to estimate costs and impacts,
reports estimated incremental costs by facility for each sector, and estimates the economic impacts
of the regulation on the companies' antimony oxide and titanium dioxide operations, as well as the
companies' financial conditions.
Three companies are projected to incur increased costs to comply with the listing, two in
the antimony oxide sector and one in the titanium dioxide sector. In the antimony oxide industry,
two companies, Amspec and Laurel, owning one facility each, are expected to incur costs to
comply with the listing of baghouse filters and antimony oxide production slag as hazardous wastes.
EPA assessed the impacts on antimony oxide producers under two compliance scenarios:
recycling the waste or treatment and disposal as a hazardous waste. Under the recycling option,
costs are projected to be less than $500 per facility (less than 0.01 percent of baseline company
sales). Despite the fact that the costs are small when compared to company revenues, it is
important to consider that one of these companies, Amspec, is a small business and has become
unprofitable as a result of market trends. Nevertheless, the estimated impact of this listing on this
company is small when compared to the effects of market conditions such as pricing trends and
energy prices. Because the costs of compliance are so low and only one small business is expected
to incur modest incremental costs, EPA does not believe that the listing will have a significant
economic impact on a substantial number of small businesses.
In the titanium dioxide industry, only one company and one facility will be affected as a
result of the listing. DuPont's Edge Moor, DE, facility will incur additional costs as a result of the
listing of ferric chloride filter residues as a hazardous waste. Depending on its baseline waste
management practices, the company is expected to incur incremental annualized costs of between
7-1
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$114,400 and $156,800. These costs are insignificant when compared with estimated company
titanium dioxide revenues and company-level revenue and profits.
After conducting this analysis, the Agency concludes that the economic impacts of the listing
on firms within the antimony oxide and titanium dioxide industries are not significant. When viewed
in the context of company financial characteristics and external market factors that have affected the
antimony oxide industry, the listing will not substantially impact the condition of firms in either
industry.
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CHAPTER 8
REFERENCES
64 FR 43255. August 10, 1999.
Amspec Chemical Corp. Section 3007 questionnaire for Gloucester City, NJ, facility.
Amspec Chemical Corp. . Accessed June 1999 and 2000.
Amspec Chemical Corporation. Phone conversation between Karen Bradshaw, Amspec
Chemical Corporation and Charles Pringle, Research Triangle Institute, May 11, 2001.
ChemExpo. "Chemical Profiles." . Accessed June 1999, May and June
2000, and May 2001.
Executive Order 13132. Introduction. August 4, 1999.
E-mail from Paul Borst, U.S. EPA, to James Turner, Research Triangle Institute.
Fordham, Oliver, EPA, Inorganic Chemical Program, June 16, 2000.
Heil, Scott, and Terrance W. Peck, eds. 1998. Encyclopedia of American Industries, Second
Edition. Vol. 1: Manufacturing Industries. Detroit: Gale Research, Inc. Pg. 510.
Hoover's Online, . Company Capsule. Accessed June 1999, June and July
2000, and May 2001.
Kemira Oyj. "Kemira and Kerr-McGee Finalised Sale Contract on Kemira Pigments Titanium
Dioxide Pigment Plant in the U.S." . Accessed April 2000.
Laurel Industries. Section 3007 questionnaire for LaPorte, TX, facility.
Letter from C. Goldstein, Covington & Burling, Washington, D.C., to Randolph L. Hill, U.S.
Environmental Protection Agency, Office of General Counsel, November 16, 1990, p.2.
Personal Communication between Paul A. Borst, EPA Office of Solid Waste and Lewis
Maldonado, EPA Region 9, Office of Regional Counsel, June 19, 2000.
Scheraga, Dan. "OxyChem's Laurel Buys Elf Line in Flame Retardant Consolidation." Chemical
Market Reporter, New York; December 22, 1997. As accessed June 11, 1999.
Science Applications International Corporation (SAIC). 1997. "Industry Overview for the
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Protection Agency. Reston, VA: SAIC.
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Swaddle, T.W. 1997. Inorganic Chemistry: An Industrial and Environmental Perspective.
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Universal Currency Converter. . Accessed April 25, 2000.
U.S. Department of Commerce. 1996Manufacturing Profiles, . Accessed
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U.S. Department of Commerce. 1997 Current Industrial Reports, .
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U.S. Environmental Protection Agency, Office of Regulatory Enforcement. "Estimating Costs for
the Economic Benefits of RCRA Noncompliance." December 1997 Update, Appendix B.
U.S. Environmental Protection Agency, Office of Solid Waste. "Background Documents for the
Cost and Economic Impact Analysis of Listing Four Petroleum Refining Wastes as
Hazardous under RCRA Subtitle C." Prepared by DPRA Incorporated, January 10,
1998.
U.S. Environmental Protection Agency, Office of Solid Waste. Regulatory Impact Analysis:
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Processing Wastes. Appendices E and F. April 30, 1998.
U.S. Environmental Protection Agency. Detailed Costing Document for the Centralized Waste
Treatment Industry. EPA 821/R-98-016. December 1998. P. 2-60.
U.S. Environmental Protection Agency, Office of Solid Waste. Regulatory Impact Analysis of
the Final Rule for 180-Day Accumulation Time for F006 Wasterwater Treatment
Sludges. Prepared by DPRA, Inc. St. Paul. January 14, 2000.
U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection
Request Number [ ], "Reporting and Recordkeeping Requirements for the Proposed Rule
on Listing Hazardous Wastes from Inorganic Chemical Production." August 2000.
U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection
Request Number 969 Final Authorization for Hazardous Waste Management Programs,
December 1998. Exhibits.
U.S. Environmental Protection Agency. August 2000. Risk Assessment for Listing
Determination of Inorganic Chemical Manufacturing Wastes.
U.S. Geological Survey. "Antimony." Mineral Commodity Summaries. January 1999.
. As accessed September 1999.
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U.S. Geological Survey. Mineral Commodity Summaries, January 1999. .
Accessed July 1999.
U.S. Geological Survey. Mineral Industry Surveys for Antimony, fourth quarter 1999 and fourth
quarter 2000. Accessedwww.usgs.gov. Accessed May 15, 2001.
U.S. Securities and Exchange Commission. May 2001. EDGAR database.
.
U.S. Securities and Exchange Commission. 10KSB for U.S. Antimony.SECTION #
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