ECONOMIC ANALYSIS OF CATHODE RAY TUBE
MANAGEMENT, NOTICE OF PROPOSED
RULEMAKING
U.S. Environmental Protection Agency
Office of Solid Waste
February 15,2002
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Table of Contents
1.0 Introduction 1
2.0 Overview of the Entities Involved in Generating and Recycling CRTs 2
2.1 Original Users 3
2.2 Establishments that Reuse Monitors 4
2.3 Collectors 4
2.4 Reclaimers 6
2.5 Glass Processors 7
2.6 Transporters 7
2.7 CSI Handlers 8
3.0 Methodology and Data 8
3.1 Estimate the Number of Original Users Discarding Computer Monitors 9
3.2 Estimate the Total Number of Color Computer Monitors Discarded Annually 9
3.2.1 Total Number of Computers in All Business Establishments 9
3.2.2 Discarded Computer Monitors from All Original Users 10
3.2.3 Color Monitors Discarded from All Original Users 10
3.3 Estimate the Number of Regulated Original Users and Collectors and the Number of
CRTs They Discard 11
3.3.1 Computers Discarded per Original User 11
3.3.2 Monitor Weight 13
3.3.3 Number of Original Users and Collectors that are Regulated Generators in the
Subtitle C Baseline Based Only on the Generation of CRTs 13
3.3.4 Number of Original Users that are Regulated Generators in the Subtitle C
Baseline Due to a Combination of CRTs and Non-CRT Hazardous Waste
15
3.3.5 Number of Original Users and Collectors that are Regulated Generators Under
the Primary Alternative 16
3.3.6 Number of Original Users and Collectors that are Regulated Generators Under
the CSI Alternative 18
3.4 Flow of CRTs from Generators to Disposal Sites - Subtitle C Baseline 19
3.4.1 Disposal Option Assumptions 24
3.5 Estimate Administrative Compliance Costs 28
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3.5.1 Baseline Unit Costs for Original Users (Generating No Non-CRT Hazardous
Waste) 28
3.5.2 Baseline Unit Costs for Original Users Also Generating Non-CRT Hazardous
Waste 28
3.5.3 Primary Alternative 28
3.5.4 CSIAlternative 29
3.6 Estimate Disposal Costs 31
3.7 Estimate Transportation Costs 32
3.8 Estimate Storage Costs 35
3.9 Estimate Costs for Glass Processors and Transporters 37
3.9.1 Costs to Glass Processors 37
3.9.2 Costs to CRT Glass Transporters 37
3.10 Estimate the Impact of Compliance Costs on Affected Entities 38
3.11 Methodology for Subtitle D Management Baseline 39
3.12 Limitations of the Methodology and Data 43
3.12.1 Assumptions 43
3.12.2 Limitations 46
3.12.3 Other Factors 47
4.0 Cost Results and Sensitivity Analysis for Subtitle C Management Baseline 49
4.1 Costs Under the Subtitle C Baseline 49
4.2 Primary Alternative 50
4.2.1 Costs Under the Primary Alternative 50
4.2.2 Incremental Cost Difference Between the Subtitle C Baseline and the Primary
Alternative 51
4.2.3 Sensitivity Analysis for the Primary Alternative 52
4.2.4 Incremental Cost Between the Subtitle C Baseline and the Primary Alternative,
Including Currently Unregulated Monitors and Televisions 54
4.3 CSI Alternative 55
4.3.1 Costs Under the CSI Alternative 55
4.3.2 Incremental Cost Difference Between the Subtitle C Baseline and the CSI
Alternative 56
4.3.3 Sensitivity Analysis for the CSI Alternative 57
4.3.4 Incremental Cost Between the Subtitle C Baseline and the CSI Alternative,
Including Currently Unregulated Monitors and Televisions 59
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5.0 Cost Results and Sensitivity Analysis for Subtitle D Management Baseline 60
5.1 Costs Under the Subtitle D Baseline 60
5.2 Primary Alternative 61
5.2.1 Costs Under the Primary Alternative 61
5.2.2 Incremental Cost Difference Between the Subtitle D Baseline and the Primary
Alternative 62
5.2.3 Sensitivity Analysis for the Primary Alternative 63
5.2.4 Incremental Cost Between the Subtitle D Baseline and the Primary Alternative,
Including Currently Unregulated Monitors and Televisions 65
5.3 CSI Alternative 66
5.3.1 Costs Under the CSI Alternative 66
5.3.2 Incremental Cost Difference Between the Subtitle D Baseline and the CSI
Alternative 67
5.3.3 Sensitivity Analysis for the CSI Alternative 68
5.3.4 Incremental Cost Between the Subtitle D Baseline and the CSI Alternative,
Including Currently Unregulated Monitors and Televisions 70
6.0 Economic Impacts 71
7.0 Qualitative Environmental Benefits 79
8.0 Other Administrative Requirements 81
8.1 Environmental Justice 81
8.2 Unfunded Mandates Reform Act 81
8.3 Protection of Children from Environmental Health Risks and Safety Risks 82
8.4 Regulatory Flexibility 82
9.0 Discussion of Findings and Summary 82
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Appendix A: Number of Establishments and the Number of Employees for all Two-Digit SIC Codsesl
Appendix B: Ratios of Computers per Employee Calculated for Each SIC Code B-l
Appendix C: Disposal Cost Source Details C-l
Appendix D: Flow of CRTs in Both Number and Tons D-l
Appendix E: Average Shipment Sizes for Each Type of Establishment Distributing CRTs to Each
CRT Management Option E-l
Appendix F: Revenues per Establishment for All Two-Digit SIC Codes F-l
Appendix G: List of Parameters to Which the Analysis Results are Relatively Insensitive G-l
Appendix H: Telephone Contacts H-1
Appendix I: Bibliography I-1
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1.0 Introduction
Computers and televisions are in almost every household and business in the United States.
Several hundred million computers and televisions are in use and many more millions are believed to be
in storage. Both computer monitors and televisions typically contain a cathode ray tube (CRT), which
creates the images seen on the television or computer monitor. The glass in CRTs from color computer
monitors and color televisions can contain enough lead to qualify these devices as hazardous waste
(D008, characteristically hazardous for lead) when they are discarded. Under current Resource
Conservation and Recovery Act (RCRA) regulation, post-consumer CRTs from many commercial and
industrial generators are hazardous waste whether disposed, or sent for reclamation, such as
disassembly and glass recycling (40 CFR §261.2(C)(3)). CRTs that are sent for refurbishment or
reuse are not considered a solid waste under RCRA.
Businesses that discard (i.e., "generate") post-consumer CRTs must comply with RCRA
regulations and dispose of computer monitors and televisions by treating them for lead and sending
them to a Subtitle C or D landfill or sending them to recyclers or smelters. Households are excluded
from RCRA Subtitle C hazardous waste regulation and many smaller businesses do not generate
enough CRTs to trigger RCRA generator requirements; these entities tend either to store old electronic
equipment or to send it to Subtitle D landfills. Most of the current disposal methods (Subtitle C and D
landfilling and lead smelting) do not take advantage of the full intrinsic value contained in CRT glass or
in other CRT components that can be recycled back into high value products, such as new CRT glass
or recovered gold and copper. While there is already a demand for the CRT glass contained in
computer monitors and televisions, RCRA regulations that can apply for applicable hazardous waste
generators can be burdensome and may discourage this type of recycling. The requirements under the
current RCRA regulations include: storage limits, manifesting, recordkeeping, safety training, and
biennial reporting by large generators. The administrative, transportation, treatment, disposal, and
storage costs associated with the current regulations add to the cost of recycling old CRT glass back
into new CRT glass, and also tend to discourage glass-to-glass recycling.
To remedy this situation the Common Sense Initiative (CSI) Council tasked the Computers and
Electronics Sector Subcommittee with recommending regulations that encourage environmentally sound
recovery of CRTs and that eliminate unnecessary regulatory burden for recycling post-consumer CRTs
back into new CRT glass. In June 1998, the CSI Computers and Electronics Sector Subcommittee
recommended changes to the current regulations specifically for CRTs that encourage recycling CRT
glass back into new CRT glass. The recommendations included extended storage limits, no
manifesting, reduced recordkeeping requirements, and no biennial reporting. EPA's proposed
regulation builds on the CSI recommendation by further streamlining the requirements and by also
reducing the regulatory requirements for CRTs sent to lead smelters. EPA believes that the additional
capacity at lead smelters may be necessary to recycle all of the CRTs generated and, therefore, to
achieve the greatest reduction in CRTs requiring disposal. The proposed regulation is expected to
encourage glass-to-glass and other types of recycling, reduce the costs on the regulated community,
and maintain or increase the degree of protection provided to human health and the environment.
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The purpose of this analysis is to analyze the costs and economic impacts of EPA's proposed
rule (primary alternative) and the CSI alternative related to encouraging environmentally sound recycling
of CRTs. To achieve this purpose the analysis estimates the incremental cost of the alternatives over
current regulations (the "baseline"). The analysis uses two different baselines: one that models full
compliance with RCRA Subtitle C requirements (referred to as the Subtitle C management baseline),
and one that reflects what is possibly current CRT disposal practice (referred to as the Subtitle D
management baseline). The remainder of this report is organized as follows: Section 2 provides an
overview of the types of entities involved in generating and recycling CRTs. Section 3 describes the
methodology used to estimate the costs of the proposed rule and to calculate the first order economic
impacts associated with the costs. Sections 4 and 5 present, respectively, the results of the cost
analysis for each of the two baselines. Section 6 presents impact analysis results. Section 7 discusses
environmental benefits associated with the proposed regulatory changes. Other administrative
requirements are addressed in Section 8. Finally, Section 9 concludes with a summary of the analytical
results.
2.0 Overview of the Entities Involved in Generating and Recycling CRTs
This section describes the entities involved in generating, collecting, transporting, reclaiming, and
recycling CRTs from televisions and computer monitors. CRTs from televisions and computer monitors
are treated the same when discarded, so the same entities typically handle both types of CRTs.
However, this analysis models the management of CRTs only from color computer monitors because
these CRTs comprise the vast majority of CRTs discarded by regulated entities. CRTs from televisions
only are included in a sensitivity analysis that includes televisions from unregulated entities (see Sections
4.2.4 and 4.3.4).
The seven economic based entities involved in generating and managing CRTs are: original
users, reusers, collectors (including exporters), hazardous waste disposal facilities, reclaimers, glass
processors, and CRT glass manufacturers. Exhibit 2-1 is a simplified diagram of how CRTs flow
between these entities. In this analysis, original users are businesses that first use monitors and
televisions for their intended purpose. They may be regulated generators or they may be unregulated
under RCRA, as discussed in Section 2.1. Establishments that reuse computers are similar to original
users, but are typically not regulated (see Section 2.2). In this analysis, collectors are intermediaries
that accept discarded CRTs from original users or reusers prior to sending the CRTs or CRT glass to
other entities. Like original users, collectors may be regulated generators or they may be unregulated.
Collectors are described in more detail in Section 2.3. Reclaimers considered in this study consist of
lead smelters, and are described in more detail in Section 2.4. Glass processors prepare CRT glass
for introduction into a CRT glass manufacturer's glass furnace, and are the subject of Section 2.5.
Hazardous waste facilities and CRT glass manufacturers are included in Exhibit 2-1 for completeness
but, because these types of entities are not affected by the proposed alternatives, they are not discussed
further in this overview. Section 2.6 briefly discusses the transporters of CRTs that move CRTs from
one entity to the next. Finally, under the CSI alternative a category of entities is defined, CSI handlers,
that can be either original users or certain collectors. CSI handlers are described in more detail in
Section 2.7.
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Exhibit 2-1: CRT Life-Cycle Flow Diagram
2.1 Original Users
Original users are establishments that first use and discard CRTs. Original users include entities
that use computers and televisions in the normal course of their business operations and that periodically
discard them. For example, original users range from large multinational corporations down to small
local real estate offices. Original users send CRTs for reuse, recycling, reclamation, disposal, or to
collectors. As considered in this analysis, original users do not include entities that are explicitly
excluded from hazardous waste requirements (e.g., households).
Current RCRA Regulatory Requirements
Because color CRTs contain leaded glass that typically qualifies as hazardous waste when
disposed, any entity that uses computers or televisions may be a regulated generator. However, under
current EPA policy, used CRTs with the potential for reuse are assumed to be products and not wastes
if there is the possibility that the CRTs will be refurbished or reused. Therefore, original users that
discard intact CRTs are only regulated generators if they send the CRTs for intended disposal (e.g., a
landfill), to a lead smelter, or to a glass processor that does not refurbish any of the CRTs it receives.
Original users that discard broken CRT glass are regulated generators regardless of where they are
sent. This analysis assumes that original users only discard intact CRTs.
Original users are regulated if they produce hazardous wastes in quantities above a threshold of
100 kilograms (kg) per month. Original users that produce less than 100 kg per month of hazardous
waste are conditionally exempt from RCRA requirements and are not included in this analysis (40 CFR
§261.5). Original users that produce between 100 and 1,000 kg per month of hazardous waste are
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small quantity generators (SQGs) and must comply with storage limits, manifesting, recordkeeping, and
safety training requirements (40 CFR Part 262 generally). Original users that generate more than 1,000
kg per month of hazardous waste are large quantity generators (LQGs) and must comply with the same
or more stringent requirements as SQGs and must also comply with biennial reporting requirements.
Due to the 100 kg per month threshold (equivalent to approximately seven CRTs), only relatively large
original users are likely to qualify as regulated generators based solely on their generation of post-
consumer CRTs. However, facilities that generate hazardous waste other than CRTs may qualify as a
regulated generator with less than 100 kg per month of CRTs. The treatment of these generators in this
analysis is discussed in Section 3.3.4.
Primary and CSI Alternatives
Under the primary alternative, CRTs that are sent to reclaimers and glass processors (see
Sections 2.4 and 2.5) are excluded from the definition of solid waste. Thus the original users that send
CRTs to these CRT management options will no longer be considered generators of CRTs. Original
users that send their CRTs for disposal continue to be regulated generators under the primary
alternative.
Under the CSI alternative, CRTs that are sent to glass processors (see Section 2.5) are
excluded from the definition of hazardous waste. Therefore, the original users that send CRTs to glass
processors are no longer considered generators of CRTs. Original users that send their CRTs for
disposal or to reclaimers continue to be generators under the CSI alternative. Thus the CSI alternative
also reduces the number of original users subject to the rule, but not by as many as does the primary
alternative.
2.2 Establishments that Reuse Monitors
Establishments that reuse CRTs include schools, foundations, and other not-for-profit entities.
Although reusers of CRTs can face the same regulatory conditions as original users of CRTs (i.e.,
because RCRA regulations do not define/distinguish between them), the analysis assumes that
establishments that reuse monitors do not discard enough CRTs to trigger the RCRA requirements or
they are exempted entities. This category of establishments is included in the analysis for completeness
of the CRT life cycle flow.
2.3 Collectors
The analysis recognizes a category of entities called CRT "collectors," which includes
intermediary entities that collect intact televisions or computer monitors, and then send the CRTs or
CRT glass for reuse, recycling, reclamation, or disposal. Because collectors often make a decision to
either refurbish/reuse CRTs or to dispose of them, they frequently trigger the hazardous waste
regulations, becoming potentially regulated generators when opting to send CRTs for disposal,
reclamation, or recycling. Like original users, collectors are unregulated if they send CRTs to entities
(e.g., other collectors) that might refurbish/reuse them.
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The category of collectors covers a wide variety of entities. For example, this category
includes establishments that primarily refurbish CRTs for reuse and also establishments that primarily
dismantle CRTs for recycling. Collectors that primarily refurbish CRTs for reuse tend to be smaller
organizations, including non-profit entities. Collectors that primarily recycle CRTs are typically small to
medium for profit businesses. Since not all CRTs can be refurbished for reuse, the collectors that
refurbish CRTs typically send unusable CRTs to collectors that primarily recycle CRTs. Some
collectors that primarily recycle CRTs break and grind the CRTs to separate out the metal from the
glass. Separating the metal from the glass also reduces the CRT management costs of the glass if it is
sent to glass processors. The grinding process increases the density of the CRTs, thus reducing
shipping costs, and also results in a better price from the glass processor. The collector category also
includes brokers that arrange for large quantities of electronic equipment, including CRTs, to be sent to
electronics recycling facilities or for export. This analysis assumes that collectors that are SQGs discard
bare CRTs and collectors that are LQGs discard broken or crushed CRT glass.1 Collectors are
assumed not to generate hazardous waste other than CRTs.
Current RCRA Regulatory Requirements
Under current EPA policy, CRTs that are discarded are assumed to be products and not
wastes if there is the possibility that the CRTs will be refurbished or reused. Therefore, under current
requirements, collectors that discard intact CRTs are only regulated generators if they send the CRTs
for intended disposal (e.g., a landfill), to a lead smelter, or to a glass processor that does not refurbish
any of the CRTs it receives. Collectors that discard bare CRTs or broken CRT glass are regulated
generators regardless of where they are sent because it is assumed they cannot be reused at this point.2
Collectors are regulated if they produce hazardous wastes in quantities above a threshold of
100 kilograms (kg) per month. Collectors that produce less than 100 kg per month of hazardous waste
are conditionally exempt from RCRA requirements and are not included in this analysis (40 CFR
§261.5). Collectors that produce between 100 and 1,000 kg per month of hazardous waste are small
quantity generators (SQGs) and must comply with storage limits, manifesting, recordkeeping, and safety
training requirements (40 CFR Part 262 generally). Collectors that generate more than 1,000 kg per
month of hazardous waste are large quantity generators (LQGs) and must comply with the same or
more stringent requirements as SQGs and must also comply with biennial reporting requirements.
1 Collectors that are SQGs are assumed to not crush the CRTs because the large capital costs
of the crushing equipment and the relatively low volumes of CRTs that they handle does not
make crushing economically viable. Collectors that are LQGs are assumed to crush the CRTs
because the larger volumes of CRTs they handle combined with the disposal cost savings for
crushed versus whole bare CRTs makes the purchase and operation of the crushing equipment
economically feasible.
2 Bare CRTs are televisions or monitors that have had the casing, electronics, and electron gun
removed from them, leaving only the panel and funnel glass that are still fused together.
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Primary and CSI Alternatives
Under the primary alternative, bare intact CRTs that are sent to lead smelters and glass
processors (see Sections 2.4 and 2.5) are unconditionally excluded from the definition of solid waste.
Used broken CRTs are conditionally excluded when stored in containers or buildings. Therefore, the
collectors that send CRTs to these disposal options are no longer considered generators of CRTs.
Collectors that send their CRTs for disposal continue to be generators under the primary alternative.
Under the CSI alternative, CRTs that are sent to glass processors (see Section 2.5) are
excluded from the definition of solid waste. Consequently, the collectors that send CRTs to glass
processors are no longer considered generators of CRTs. Collectors that send their CRTs for disposal
or to lead smelters continue to be generators under the CSI alternative. Thus, the CSI alternative
reduces the number of collectors subject to the rule, but not by as many as does the primary alternative.
2.4 Reclaimers
Current RCRA Regulatory Requirements
Current requirements do not recognize or specifically define any category of CRT reclaimers.
Under current RCRA Subtitle C regulations, entities that disassemble televisions or computer
monitors and break CRT glass for land disposal or smelting are "treating" the CRT glass (40 CFR §
260.10). Treatment of hazardous waste is often subject to administrative and technical standards and
requires a permit (40 CFR Parts 264, 265, and 270). However, some forms of treatment, such as
reclamation, are not subject to regulation (e.g., CRT disassembly for smelting) (40 CFR §
261.6(C)(1)) or, treatment may be conditionally exempt if the treater generated the waste (40 CFR §§
262.34, 264.1(g)(3), and 265.1(c)(7)).
Primary and CSI Alternatives
Reclaimers include entities that use CRT glass as a substitute for raw materials. Under the
primary alternative only lead smelters are recognized as reclaimers. Other types of reclaimers that are
not recognized under the primary alternative include establishments that turn the CRT glass into a usable
product, such as glass construction blocks. Another example is a reclaimer that has a value added
process that turns the CRT glass into a marketable product called LeadX, which can be used as a
sand-blasting abrasive suitable for the abatement of leaded paint.3 The primary alternative only changes
the RCRA regulatory requirements for lead smelters, but not for other types of reclaimers. The CSI
alternative does not change the RCRA regulatory requirements for any reclaimers.
3 Cutter Information Corp.'s, Product Stewardship Advisor, "The Long-Term Future of CRT
Glass Recycling: How NEC Is Planning Ahead." Volume I, No. 6, November 1997.
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2.5 Glass Processors
Current RCRA Regulatory Requirements
Current requirements do not define any category of CRT glass processors. CRT glass
processors are currently captured under the regulations as treatment, storage, and disposal facilities
unless thev also conduct refurbishment.
jjiu^caauia cue ^uncimy ^apiuicu uiiuc
unless they also conduct refurbishment
Primary and CSI Alternatives
Glass processors disassemble the televisions and computer monitors, intentionally break the
CRT glass and prepare the CRT glass, by cleaning and sorting it, for shipment to CRT glass
manufacturers. Glass processors receive discarded post-consumer televisions and computer monitors
from both original users and collectors, and off-specification pre-consumer CRTs from manufacturers
of televisions and computer monitors.4 Although a subset of collectors perform some of the same
processing steps as glass processors, the primary difference between glass processors and collectors is
that glass processors prepare the glass for input directly into a CRT glass manufacturers furnace, while
CRT glass from collectors requires further processing before it can be sent to a CRT glass
manufacturer.
2.6 Transporters
Current RCRA Requirements
Under current requirements, transporters of any hazardous waste, including discarded CRTs,
are required to be certified as hazardous waste handlers. (40 CFR Part 263)
Primary and CSI Alternatives
Under both regulatory alternatives, any non-hazardous material carrier may transport whole
televisions and computer monitors between original users and collectors and between generators and
glass processors without being certified hazardous waste handlers. Under the primary alternative, any
non-hazardous material carrier may transport intact or broken CRTs between generators and
reclaimers and between glass processors and reclaimers.
2.7 CRT Handlers
Current RCRA Regulatory Requirements
Current requirements do not recognize or define any category of CRT handlers.
Pre-consumer CRTs are not addressed in this analysis.
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Primary Alternative
The primary alternative does not recognize or define a category of CRT handlers.
CSI Alternative
The CSI alternative defines handlers as including entities that collect and/or store whole
televisions or computer monitors, including those generated by the entity itself, and then send them to
glass-to-glass recycling facilities (also called "glass processors") or to other handlers. Handlers also
include any entity that disassembles televisions and computer monitors and sends the whole CRTs to a
processor or another handler. Note that, under the CSI alternative, entities that are generators under
current requirements become handlers for CRTs if they send their CRTs to glass-to-glass recycling
facilities or to other handlers. Under the CSI alternative, handlers are exempt from RCRA generator
requirements. Large quantity handlers (LQH) include handlers that collect and store more than 40
tons of CRTs for more than seven consecutive days. Small quantity handlers (SQH) include handlers
that collect or store more than 100 kg per month. Handlers are believed to send CRTs to processors,
smelters, or other handlers.
3.0 Methodology and Data
This section describes the methodology used to quantitatively estimate (1) the type and number
of entities impacted by the proposed rule; (2) the cost savings expected to result from the proposed
rule; and (3) the impact on the regulated entities. To obtain these results the analysis models the flow of
discarded CRTs from generation to final disposal. The following ten steps broadly outline the analytical
methodology:
(1) Estimate the number of original users discarding computer monitors;
(2) Estimate the total number of color computer monitors discarded annually;
(3) Estimate the number of regulated original users and collectors;
(4) Estimate the flow of discarded CRTs to each disposal alternative;
(5) Estimate the administrative compliance costs for the regulated establishments;
(6) Estimate the CRT management costs (i.e., costs for disposal, recycling, reuse);
(7) Estimate the transportation costs for shipping CRTs;
(8) Estimate the storage costs for storing CRTs;
(9) Estimate the costs for glass-to-glass processors and transporters; and
(10) Estimate the impact of the compliance costs on the regulated establishments.
These steps, along with the applicable data and assumptions used, are described below in
Sections 3.1 through 3.10. Section 3.11 describes the methodology, data, and assumptions used to
analyze the Subtitle D management baseline where a large percentage of CRTs are disposed in Subtitle
D landfills without treatment. This baseline may more closely represent current CRT disposal practices.
Section 3.12 identifies key assumptions and limitations of the methodology and data. It is worth noting
at this time that the CRTs from televisions are addressed only in a sensitivity analysis presented in
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Sections 4.2.4 and 4.3.4. For reasons discussed in Section 3.12, this is not believed to have a
significant bearing on the results.
While not a limitation to the analysis, note also that the analysis reflects generators of non-CRT
hazardous wastes only to the extent that these entities generate more than 30 CRTs per year. For
reasons discussed in Section 3.12, this is consistent with least cost behavior on the part of these entities.
3.1 Estimate the Number of Original Users Discarding Computer Monitors
Computers are used in all industries; it is rare to find a business establishment without at least
one computer. However, businesses utilize computers at different rates. For example, financial
institutions are far more likely to have high ratios of computers per employee than are farms. Given that
computers are used, and therefore discarded, by virtually all establishments, the total number of
establishments in all two-digit SIC codes provides an estimate of the number of business original users
discarding computer monitors. These data are currently available for 1995 from the U.S. Bureau of the
Census. The total number of establishments in all SIC codes in 1995 is 6,613,188. In addition to
obtaining the total number of establishments in each two-digit SIC code, the distribution of
establishments by size, as measured by the number of employees per establishment, was obtained for
use in subsequent steps in the modeling process. Appendix A contains a table of the number of
establishments and the total number of employees for all two-digit SIC codes.
3.2 Estimate the Total Number of Color Computer Monitors Discarded Annually
The second step in the modeling process estimates the number of color computer monitors
discarded by the original users identified in the first step. To do this, the analysis estimates, in turn, the
total number of computers in use, the number discarded each year and, finally, the number of these
discarded monitors that are color monitors.
3.2.1 Total Number of Computers in All Business Establishments
To determine the total number of computers in use by all original users, an estimate of the ratio
of computers per employee is developed for each two-digit SIC code based on two surveys taken by
the U.S. Bureau of the Census.5 The first survey, completed in 1993, contained a detailed listing of
computer use at work by two-digit SIC classification. The second survey, completed in 1997, only
contained a summary of computer use at work by fifteen major SIC classifications. This analysis uses
the less detailed 1997 survey to extrapolate the more detailed 1993 survey results to 2001 by assuming
the same percentage increase occurred between 1997 and 2001 as occurred from 1993 to 1997. This
assumes a linear growth in computer use. The average increase in the percent of employees using
5 U.S. Bureau of the Census, "Computer Use in the United States: October 1993."
www.census.gov/population/socdemo/computer/compwork.txt and "Computer Use in the
United States: October 1997." September 1999.
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computers is six percent. The range of percentage increases in the percent of employees using
computers at work is from one to 14 percent. Appendix B lists the ratios of computers per employee
calculated for each SIC code. The ratios are multiplied by the total number of employees in each two
digit SIC code. The resulting products are summed to obtain an estimate of the total number of
computers in use by all original users. The model estimates there are 55,555,000 computers used by
all original users.
3.2.2 Discarded Computer Monitors from All Original Users
To determine the total number of computers discarded by all original users, the estimated
number of computers in use by all original users is divided by an estimate of the average computer
monitor life. The analysis assumes that computer monitors last an average of 3.5 years in businesses.
A literature search yielded a wide range of estimates for monitor lifetimes. For example, a 1997 study
by Carnegie Mellon suggested lifetimes of four to five years,6 while a 1999 report by the National
Safety Council estimates that monitor lifetimes would be 2.8 years in the year 2000.7 The model results
are sensitive to monitor lifetime. The estimated total number of computers discarded per year by all
original users is 15,873,000. This value includes monitors that are sent by original users to
organizations that will reuse the monitors.
An implicit assumption in this calculation is that businesses discard computers continuously, or
in small batches annually, rather than replacing all computers once every 3.5 years. This is a reasonable
assumption as most businesses purchase new computers on an as needed basis, and the computer
stock in any one company is not all of the same age.
3.2.3 Color Monitors Discarded from AII Original Users
To determine the total number of color monitors discarded, the model subtracts out laptop
computers (which do not use CRTs) and monochrome monitors (which do not use glass with high lead
concentrations) from the total number of computers discarded.8 After these subtractions, described
6 Matthews, Scott H., McMichael, Francis Co., Hendrickson, Chris T., Hart, Deanna, J.,
Disposition and End-of-Life Options for Personal Computers., Carnegie Mellon University:
Green Design Initiative Technical Report #97-10, July 7, 1997.
7 National Safety Council, Electronic Product Recovery and Recycling Baseline Report,
Recycling of Selected Electronic Products in the United States. May 1999. page 29.
8 Monochrome computer monitors are assumed not to contain enough lead to qualify them as
hazardous waste when discarded and thus are excluded from the analysis. Source: Overview
of Cathode Ray Tube Recycling, February 27, 1997, page 8. The original source in the
referenced report is a letter from Robert Dodds, Sony, to Nancy Helm, EPA Region X, dated
July 8, 1996.
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below, the resulting number of color monitors discarded per year by all original users is estimated at
11,714,000.
Percent of Discarded Computers that are Laptops. The model assumes that 18 percent of all
discarded computers are laptops. Laptops have become an important segment of the computer
market over the last five to eight years. Computer sales estimates from 1998 indicate that 18
percent of computer sales are laptops.9 The model results are only slightly sensitive to the
percent of laptops discarded.
Percent of Discarded Monitors that are Color. The Census survey from 1993 reported that 61
percent of households with computers have color monitors.10 This analysis considers that
figure to be a lower-bound estimate for businesses, based on the assumption that businesses are
more likely to have color monitors than households. Since color monitors have become much
more common over the last eight years, the model uses an estimate of 90 percent for the
percent of color monitors discarded from businesses. The model results are sensitive to the
percent of color monitors assumed as a percentage of all monitors discarded.
3.3 Estimate the Number of Regulated Original Users and Collectors and the Number of
CRTs They Discard
The next step in the methodology is to determine the number of original users and collectors
that are subject to RCRA requirements for generators and that would be affected by the regulatory
alternatives. This section also estimates the number of CRTs that are discarded by original users and
collectors. To complete these calculations, the number of computers discarded per establishment and
an estimate of monitor weight is required. The report then explains the methodologies used to estimate
the number of establishments for three types of entities: original users that are currently generators solely
due to CRTs; original users that are generators due to a combination of CRTs and non-CRT hazardous
waste; and collectors that are currently generators.
3.3.1 Computers Discarded per Original User
To estimate the average number of computers discarded annually per original user in each of
the two digit SIC codes, the analysis estimates the average number of employees per establishment,
9 National Safety Council, Electronic Product Recovery and Recycling Baseline Report,
Recycling of Selected Electronic Products in the United States. May 1999. page 31.
10 U.S. Bureau of the Census, "Computer Use in the United States: October 1993."
www.census.gov/population/socdemo/computer/compwork.txt.
Page 11
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multiplies this estimate by the number of computers per employee (as discussed in Section 3.2.1), and
then adjusts for the number of color computer monitors discarded. Exhibit 3-1 contains the summary
statistics generated by this analysis for the number of color CRTs discarded per original user for all
two-digit SIC codes.
The Census reports the number of establishments by two-digit SIC code for six size ranges of
employees (250 to 499; 500 to 999; 1,000 to 1,499; 1,500 to 2,499; 2,500 to 4,999; and 5,000 or
more employees). The midpoint of each range is used as the estimate of the number of employees in
each establishment within each defined size range. For the largest category (5,000 or more
employees), a value of 10,000 employees per establishment is used.
Exhibit 3-1: Number of Color CRTs Discarded per Original User
for All Two-Digit SIC Codes
Statistic
Minimum
25th Percentile
Median
Average
75th Percentile
Maximum
Number of Color CRTs Discarded by Establishment Size As Determined
by the Number of Employees
250 - 499
13
32
35
43
56
79
500 - 999
25
34
70
85
111
157
1000 - 1,499
42
107
117
141
184
261
1,500 - 2,499
66
172
187
225
294
417
2,500 - 4,999
124
321
350
422
552
781
> 5,000
330
854
931
1,123
1,470
2,082
Page 12
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3.3.2 Monitor Weight
Throughout the analysis, the model assumes an average monitor weight of 35 pounds, based on
the percentage and weight of each size of monitor sold 3.5 years prior to the modeled year.11 The
analysis uses a weighted average of the monitors sold in 1997 and 1998 to determine the average
weight of monitors discarded in the model year. In the future, the average monitor weight is expected
to increase with the use of larger screens, which would tend to push more original users into the
regulated universe. For example, by 2004 the average weight of discarded monitors is expected to be
38 pounds.
3.3.3 Number of Original Users and Collectors that are Regulated Generators in the
Subtitle C Baseline Based Only on the Generation of CRTs
Original Users
To estimate the number of original users that are regulated solely due to their generation of
CRTs, assumptions must be made regarding the behavior that establishments will exhibit in discarding
computer monitors. The analysis assumes that businesses will exhibit least cost behavior to the extent
possible by discarding monitors each month just below the 100 kilogram per month limit for SQGs. An
original user becomes an SQG if in any one month it exceeds the 100 kilogram per month threshold.
11 The table below presents the number and percent of monitors sold in 1997 and 1998 by size
of monitor. The source of the sales data is the Electronic Industries Alliance report, Spring
2001. The 15-inch monitor weight was obtained from the user manuals for a Sony Trinitron
Color Computer Display (manufactured in 1998), and for an Apple Multiple Scan 15 Display
(manufactured in 1994). The 17-inch monitor weight was obtained from the user manual for a
Sony Trinitron Color Computer Display (manufactured in 1998). The 14-inch and 19- to 21-
inch monitor weights are estimated based on the weight of glass in each monitor size, which is
20 pounds and 28 pounds respectively
Monitor Size
(inches)
<= 14
15
17
19-21
Monitor Weight
(Ibs)
26
31
41
48
Totals
1997
Number Sold
4,100
12,800
10,300
1,200
28,400
Percent Sold
14%
45%
36%
4%
100%
1998
Number Sold
2,600
12,900
13,700
2,400
31,600
Percent Sold
8%
41%
43%
8%
100%
Page 13
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Based on the current SQG threshold (100 kg/month) and LQG threshold (1,000 kg/month)
under the Subtitle C baseline, and the assumptions made regarding monitor lifetime and weight, and the
assumed least cost behavior, original users who discard 73 - 744 monitors annually are SQGs and
those who discard 745 or more monitors annually are LQGs.12 Based on the assumed monitor lifetime
of 3.5 years, the smallest SQG possesses 256 operating color computer monitors and the smallest
LQG possesses 2,608 operating color computer monitors. Under these assumptions and the estimated
number of computers discarded per establishment, there are an estimated 12,151 potential SQGs and
356 potential LQGs in the Subtitle C baseline due solely to the generation of CRTs. These entities
discard an estimated total of 2,490,000 CRTs per year. Some of these potential SQGs and LQGs
only send CRTs to collectors, for reuse, or to glass processors who refurbish and resell some of the
monitors they receive. Thus not all of the potential SQGs and LQGs are actually regulated generators.
The analysis estimates that there are 2,066 actual SQGs and 61 actual LQGs. The analysis models the
flow of all of the CRTs generated by all the potential original user generators, because although the
establishments generating these CRTs are not regulated, the CRTs themselves may still become subject
to regulation with subsequent handlers.
Collectors
To estimate the number of collectors the analysis started with a database of establishments
involved in the electronics recycling industry.13 By comparing this database with the names of
electronics recyclers mentioned in the literature review, a rough estimate of the number of collectors
was obtained. The analysis estimates there are 100 potential SQGs and 500 potential LQGs that are
collectors. Collectors are assumed to only be hazardous waste generators due to their discarding of
CRTs. The 600 potentially regulated collectors are estimated to process approximately 2.0 million
CRTs per year. Some of these potential collectors only send CRTs for reuse or for export, neither of
which are regulated activities if the CRTs have the possibility of being reused. Thus, the collectors who
send CRTs for reuse or export are not considered regulated generators in this analysis. The analysis
assumes that there are 50 SQGs and 250 LQGs.
12 This calculation assumes that, in any one month, an establishment will be subject to RCRA
regulation if it discards seven or more color monitors (7 monitors * 15.9 kg/monitor = 111 kg;
100 kg per month is the threshold for SQGs). Assuming least-cost behavior, the smallest
number of color monitors an establishment could discard annually and trigger the RCRA
requirements for SQGs is [(11 months * (7-1 CRTs)) + (1 month * 7 CRTs) =] 73 CRTs per
year. Given the assumed monitor lifetime (3.5 years, for a turnover rate of 0.29), SQGs must
possess a minimum of 73/0.29, or 256 operating color monitors. The numbers for LQGs are
calculated using the same method, with the threshold for discard starting at 63 color monitors
per month, or 745 in a year, for a total number of computers of 2,608 in each LQG
establishment.
13 The database is the International Association of Electronics Recyclers (IAER) industry
directory that is located on LAER's web site, www.iaer.org.
Page 14
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3.3.4 Number of Original Users that are Regulated Generators in the Subtitle C
Baseline Due to a Combination of CRTs and Non-CRT Hazardous Waste
The number of generators due in part to non-CRT hazardous waste is estimated from the
number of original users discarding between 30 and 72 CRTs per year and the total number of SQGs
and LQGs in each two-digit SIC code. The lower bound of 30 CRTs discarded per year is based on
the assumption that generators discarding fewer than 30 CRTs per year do not send their CRTs to
glass-to-glass processors due to the high transportation costs and low volume of CRTs discarded. The
upper bound of 72 CRTs discarded per year is used because original users generating more than 72
CRTs per year are captured as SQGs or LQGs in the analysis above.
The total number of all original users discarding between 30 and 72 CRTs per year in each
two-digit SIC code is estimated using the same methodology as described in Sections 3.3.1 to 3.3.3.
The total number of original users generating between 30 and 72 CRTs per year is estimated at 21,842.
This number underestimates the total number of these generators because for some SIC codes the
number of employees that generate 30 CRTs per year is less than 250, while the analysis uses the total
number of establishments with 250 to 499 employees to estimate the number of generators. The
analysis uses this larger size category because the Census data source does not have a category for
below 250 employees except for 1 - 249 employees. Because about 97 percent of all establishments
have less than 250 employees, it is likely that the estimated number of establishments discarding 30 to
72 CRTs is low. To estimate the number of hazardous waste generators in each two-digit SIC code
from the number of all establishments discarding 30 to 72 CRTs per year, the ratio of all hazardous
waste generators to all establishments in each two-digit SIC code is multiplied by the total number of
establishments discarding between 30 and 72 CRTs per year.14 To account for the fact that SQGs and
LQGs are more likely to be larger organizations, the ratio for SQGs is multiplied by a factor of 1.5 and
the ratio for LQGs is multiplied by a factor of 2. Under these assumptions there are 2,136 potential
SQGs and 891 potential LQGs because they generate a combination of CRTs and non-CRT
hazardous waste. These generators discard an estimated total of 151,000 CRTs per year. Some of
these potential SQGs and LQGs only send CRTs to collectors, so not all of the potential SQGs and
LQGs are actually regulated generators. The analysis estimates that there are 534 actual SQGs and
223 actual LQGs. The total number of original user generators under the baseline is estimated at 2,600
SQGs and 284 LQGs.
A list of the number of SQG and LQG original users by two-digit SIC code under the Subtitle
C baseline and the proposed rule is shown in Exhibit 3-2. Under the baseline there are generators in
66 different two-digit SIC codes.
14 The ratio of all hazardous waste generators to all establishments was calculated from data
obtained from the biennial reporting system database (number of LQGs) and the Resource
Conservation and Recovery Information System (RCRIS) database (number of SQGs in each
SIC code) and 1995 U.S. Census data.
Page 15
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3.3.5 Number of Original Users and Collectors that are Regulated Generators
Under the Primary Alternative
Under the proposed rule, the generators under the baseline that send their monitors to glass
processors or reclaimers are no longer regulated as generators of hazardous waste. However, the
baseline generators, whether original users or collectors, that continue to send monitors for hazardous
waste disposal will be subject to full RCRA Subtitle C regulation and will qualify as SQGs or LQGs at
the RCRA thresholds of 100 and 1,000 kilograms of CRTs generated per month, respectively.
The analysis assumes that two percent of original users (both SQGs and LQGs) will send their
monitors for disposal under the primary alternative. This assumption is based on the high costs
associated with disposal of intact CRTs and anecdotal evidence regarding the current disposal
practices. For original users under this assumption, there are 286 SQGs, 25 LQGs, and 2,573 former
generators under the primary alternative. For collectors, the analysis assumes that 80 percent of
collectors will continue to send at least one shipment per year for disposal. Thus the analysis estimates
there are two SQG collectors, ten LQG collectors, and 288 former generators that are collectors under
the primary alternative.
Exhibit 3-2: Original User Generators Under the Baseline by 2-digit SIC Code
Industry
SIC
Code
Potential SQG Establishments
Due to
CRTs Only
Due to Other
Haz. Waste
Total
Potential LQG Establishments
Due to
CRTs Only
Due to Other
Haz. Waste
Total
AGRICULTURE
Agriculture service
Forestry
7
8
1
2
0
0
1
2
0
0
0
0
0
0
MINING
Metal mining
Coal mining
Oil & gas extraction
STon-metallic minerals, except fuels
Administrative & auxiliary
10
12
13
14
-
24
21
52
5
37
7
6
6
1
7
31
27
58
6
44
0
0
0
0
0
1
1
1
0
1
1
1
1
0
1
CONSTRUCTION
General contractors
Heavy construction
Special trade contractors
Administrative & auxiliary
15
16
17
-
8
24
5
0
0
1
0
1
8
25
5
1
0
0
0
0
0
1
0
0
0
1
0
0
MANUFACTURING
Food & kindred products
Tobacco products
Textile mill products
20
21
22
178
10
56
139
9
44
317
19
100
3
1
0
13
2
5
16
3
5
Page 16
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Industry
Apparel & other textile products
Lumber & wood products
Furniture & Fixtures
Paper & allied products
Printing & publishing
Chemicals & allied products
Petroleum and coal products
Rubber & misc. plastics products
Leather & leather products
Stone, Clay, and glass products
Primary metal industries
Fabricated metal products
Industrial machinery & equipment
Electronic & other electronic
equipment
Transportation equipment
Instrument & related products
Miscellaneous manufacturing
Administrative & Auxiliary
SIC
Code
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
-
Potential SQG Establishments
Due to
CRTs Only
9
3
30
208
328
297
44
225
5
22
72
62
483
578
459
121
19
212
Due to Other
Haz. Waste
2
1
18
119
56
192
23
122
2
8
221
251
123
309
202
28
7
4
Total
11
4
48
327
384
489
67
347
7
30
293
313
606
887
661
149
26
216
Potential LQG Establishments
Due to
CRTs Only
0
0
0
0
0
4
0
0
0
0
5
0
7
12
51
0
0
0
Due to Other
Haz. Waste
0
0
6
32
9
159
12
38
1
2
150
112
19
133
100
11
2
1
Total
0
0
6
32
9
163
12
38
1
2
155
112
26
145
151
11
2
1
TRANSPORTATION
Local & Interurban passenger
transit
Trucking & Warehousing
Water transportation
Transportation by Air
Pipelines, except natural gas
Communication
Electronic, gas, & sanitary
services
Administrative & Auxiliary
41
42
44
45
46
48
49
-
7
98
16
78
1
303
255
43
5
12
4
15
1
0
81
3
12
110
20
93
2
303
336
46
1
12
0
20
0
11
4
5
1
2
0
5
1
0
55
1
2
14
0
25
1
11
59
6
WHOLESALE
Wholesale trade-durable goods
Wholesale trade-nondurable
goods
Building materials & garden
supplies
Administrative & Auxiliary
50
51
52
-
168
213
1
98
6
7
0
5
174
220
1
103
0
0
0
1
0
3
0
1
0
3
0
2
RETAIL TRADE
Page 17
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Industry
General merchandise store
Food stores
Auto dealers & service station
Apparel & accessory stores
Furniture & home furnishing
stores
Eating & drinking places
Miscellaneous retail
Administrative & Auxiliary
SIC
Code
53
54
55
56
57
58
59
-
Potential SQG Establishments
Due to
CRTs Only
28
2
1
4
2
6
31
96
Due to Other
Haz. Waste
23
1
6
0
0
0
0
7
Total
51
3
7
4
2
6
31
103
Potential LQG Establishments
Due to
CRTs Only
0
1
0
0
0
0
0
1
Due to Other
Haz. Waste
1
0
0
0
0
0
0
1
Total
1
1
0
0
0
0
0
2
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
STondepository Institution
Security & commodity brokers
Insurance carriers
Insurance agents, brokers, &
servicers
Real Estate
Holding & other investment
offices
Administrative & Auxiliary
60
61
62
63
64
65
67
-
339
87
86
482
27
74
37
23
0
0
0
0
0
0
0
6
339
87
86
482
27
74
37
29
18
5
5
14
0
0
3
0
0
0
0
0
0
0
0
1
18
5
5
14
0
0
3
1
SERVICES
Personal services
Business services
Auto repair services & parking
Miscellaneous repair services
Motion picture
Amusement & recreation services
Health services
Legal services
Educational services
Social Services
Museums, botanical, zoological
gardens
Membership organization
Engineering & management
service
Services, n.e.c
Administrative & Auxiliary
72
73
75
76
78
79
80
81
82
83
84
86
87
89
-
6
1,432
1
2
15
69
3,177
52
580
18
3
83
365
8
134
1
20
2
0
0
1
20
0
0
0
1
0
0
0
0
7
1,452
3
2
15
70
3,197
52
580
18
4
83
365
8
134
0
22
0
0
5
3
65
0
33
0
0
6
31
0
7
0
5
0
0
0
0
2
0
0
0
0
0
0
0
0
0
27
0
0
5
3
67
0
33
0
0
6
31
0
7
Page 18
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Industry
SIC
Code
Total Original Users Under the Baseline
Total Number of Actual Original User
Generators Under the Baseline
Total Number of Actual Original User
Generators Under the Primary Alternative
Total Number of Actual Original User
Generators Under the CSI Alternative
Potential SQG Establishments
Due to
CRTs Only
12,151
2,066
Due to Other
Haz. Waste
2,136
534
Total
14,287
2,600
286 SQGs
2,3 14 Not Regulated
390 SQGs
2,452 SQHs
Potential LQG Establishments
Due to
CRTs Only
356
61
Due to Other
Haz. Waste
891
223
Total
1,247
284
25LQGs
259 Not Regulated
42LQGs
OLQHs
3.3.6 Number of Original Users and Collectors that are Regulated Generators
Under the CSI Alternative
Under the CSI alternative, the original user generators under the baseline who send their
monitors to glass processors become handlers. However, the baseline original user generators that
continue to send monitors for disposal or to lead smelters will be subject to full RCRA Subtitle C
regulation and will qualify as SQGs or LQGs at the RCRA thresholds of 100 and 1,000 kilograms of
CRTs generated per month respectively.
The threshold for SQGs under the baseline is the same as for small quantity handlers (SQH)
under the CSI alternative. However, the threshold for large quantity handler (LQH) status is much
higher. For a handler to be regulated as an LQH under the proposed rule, the handler must store
36,287 kilograms of computer monitors (40 tons) for more than seven days. This is equivalent to
2,281 monitors, or an approximate total of 7,984 operating monitors on site.
The analysis assumes that a total of 17 percent of generators (both SQGs and LQGs) will send
their monitors only to glass processors under the CSI alternative. This assumption is based on the fact
that there are currently only several processors and thus transportation costs may be prohibitive in some
areas of the country. Also smelters are likely to compete on price to obtain discarded monitors.15
Lead smelters, in particular, value tipping fees from monitors as a secondary revenue source. The
primary revenue source for lead smelters is the sale of refined lead. These factors will contribute to
limiting the percentage of monitors that are sent for glass-to-glass recycling. Under the CSI alternative,
all of the LQGs sending their discarded CRTs to processors are reclassified as SQHs because they do
not exceed the higher threshold for LQHs. Under these assumptions, there are 390 SQGs, 42 LQGs,
2,452 SQHs, and no LQHs under the CSI alternative.
3.4 Flow of CRTs from Generators to Disposal Sites Under the Subtitle C Baseline
15
See telephone interviews with Noranda and Doe Run in Appendix H.
Page 19
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The analysis considers the flow of CRTs from original users, through collectors, reusers, and
glass processors, and on to treatment and disposal destinations. Exhibit 3-3 presents a simplified
diagram of this flow under the Subtitle C baseline, which shows how CRTs flow from original users to
the final CRT management options. The exhibit shows that the CRT management options for original
users include collectors, establishments that reuse CRTs, hazardous waste treatment and disposal
facilities, reclaimers, and glass processors. The CRT management options for collectors include
establishments that reuse CRTs, hazardous waste treatment and disposal facilities, reclaimers, and glass
processors. The CRT management options for glass processors include reclaimers and CRT glass
manufacturers. The actual flows modeled for this baseline are presented in Exhibit 3-4.
The analysis recognizes that either of the two regulatory alternatives will provide incentives for
behavioral changes and will result in altered flows. Exhibit 3-5 shows the flows assumed to occur
under the primary alternative. It reflects all CRTs that are regulated in the baseline, even though many
of them will be unregulated post-rule. Similarly, Exhibit 3-6 shows the flows assumed to occur under
the CSI alternative, including flows to and from the "handlers" that will be unregulated under that
alternative. These three exhibits show the estimated percentages for the flow of CRTs from each type
of entity to each of the various CRT management options, and the total tons of CRTs sent from each
type of entity. Thus, the total tons of CRTs generated multiplied by each percentage yields the tons of
CRTs sent from each type of generator to each CRT management option. These three exhibits also
show, for reference purposes, representative disposal costs for each CRT management option to
provide an indication of the comparative economic advantage of sending CRTs to each CRT
management option.
Collectors and glass processors are only intermediaries in the flow of CRTs towards their
ultimate disposal endpoint. Thus all of the CRTs that collectors and glass processors receive are
expected to be sent to other entities. Although reuse is not the ultimate disposal endpoint for CRTs,
within the one year time frame of this analysis, CRTs that are sent for reuse are not expected to be
discarded again, since the expected lifetime of a reused CRT is two to four years.16
Exhibit 3-3: CRT Life-Cycle Flow Diagram
16 National Safety Council, Electronic Product Recovery and Recycling Baseline Report,
Recycling of Selected Electronic Products in the United States. May 1999.
Page 20
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Page 21
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Exhibit 3-4: Assumed Distribution of Discarded Monitors and CRT Glass Under the Subtitle C Management Baseline
Entity Distributing
CRTs
Disposal Cost*
Original User SQGs and
Due to CRTs Only
Due to CRTs and
Non-CRT
Hazardous Waste
Collectors
SQGs
LQGs
Glass Processors
Total Tons
Reuse
$0/ton (I)
LQGs
2% (I)
0% (I)
20% (I)
20% (I)
0%
7,892
Export
$100/ton(I)
0%
0%
30% (I)
30% (I)
0%
10,531
Intermediate Processors
Collector
$271/ton (I)
76% (I)
75% (I)
NA
NA
NA
35,104
Glass
Processor
$333/ton(I)
$0/ton (C)
5% (I)
0%
25% (B)
30% (C)
NA
7,538
Disposal Options
Hazardous
Waste Facility
$l,500/ton(I)
$160/ton(C)
2% (I)
25% (I)
2% (B)
10% (C)
0%
3,499
Reclaimer
$207/ton (I)
$152/ton(C)
15% (I)
0%
23% (B)
10%(C)
2% (C)
9,022
CRT Glass
Manufacturer
-$175/ton(C)
NA
NA
NA
NA
98% (C)
7,387
Total
Percent
100%
100%
100%
100%
100%
Total Tons
Disposed
43,577
2,647
2,925
32,178
7,358
' Disposal costs shown are representative simplifications of the actual costs used in the analysis. See Exhibit 3-10 for further details.
(I) = Intact whole monitors.
(B) = Bare CRTs without the casing.
(C) = Crushed CRT glass.
NA = Not Applicable.
August 24, 2001 - DRAFT
Page 22
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Exhibit 3-5: Assumed Distribution of Discarded Monitors Under the Primary Alternative
Entity Distributing CRTs
Disposal Cost*
Original Users
SQGs and LQGs
Former SQGs and
LQGs
Reuse
$0/ton (I)
NA
2% (I)
Export
$100/ton(I)
NA
0%
Intermediate Processors
Collector
$271/ton (I)
NA
76% (I)
Glass
Processor
$333/ton(I)
$0/ton (C)
NA
5% (I)
Disposal Options
Hazardous
Waste Facility
$l,500/ton(I)
$160/ton(C)
2% (I)
NA
Reclaimer
$207/ton (I)
$152/ton(C)
NA
15% (I)
CRT Glass
Manufacturer
-$175/ton(C)
NA
NA
Total
Percent
100%
Total Tons
Disposed
46,224
Collectors
Regulated Post-Rule
SQGs
LQGs
20% (I)
20% (I)
30% (I)
18% (I)
NA
NA
25% (B)
45% (C)
2% (B)
2% (C)
23% (B)
15%(C)
NA
NA
100%
100%
59
648
Unregulated Post-Rule
Former SQGs
Former LQGs
Glass Processors
Total Tons
20% (I)
20% (I)
0%
7,973
30% (I)
18% (I)
0%
6,714
NA
NA
NA
35,335
25% (B)
45% (C)
NA
10,546
NA
NA
0%
931
25% (B)
17%(C)
2% (C)
10,743
NA
NA
98% (C)
10,335
100%
100%
100%
2,886
31,743
10,546
' Disposal costs shown are representative simplifications of the actual costs used in the analysis. See Exhibit 3-10 for further details.
(I) = Intact whole monitors.
(B) = Bare CRTs without the casing.
(C) = Crushed CRT glass.
NA = Not Applicable.
August 24, 2001 - DRAFT
Page 23
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Exhibit 3-6: Assumed Distribution of Discarded Monitors Under the CSI Alternative
Entity Distributing CRTs
Disposal Cost*
Original Users
SQGs and LQGs
Former SQGs and
LQGs (SQHs and
LQHs)
Collectors
SQGs
LQGs
Glass Processors
Total Tons
Reuse
$0/ton (I)
NA
2% (I)
20% (I)
20% (I)
0%
7,702
Export
$100/ton(I)
NA
0%
30% (I)
20% (I)
0%
7,205
Intermediate Processors
Collector
$271/ton (I)
NA
88% (I)
NA
NA
NA
34,582
Glass
Processor
$333/ton(I)
$0/ton (C)
NA
10% (I)
25% (B)
45% (C)
NA
11,349
Disposal Options
Hazardous
Waste Facility
$l,500/ton(I)
$160/ton(C)
15% (I)
NA
2% (B)
2% (C)
0%
1,454
Reclaimer
$207/ton (I)
$152/ton(C)
85% (I)
NA
23% (B)
13% (C)
2% (C)
8,984
CRT Glass
Manufacturer
-$175/ton(C)
NA
NA
NA
NA
98% (C)
11,122
Total
Percent
100%
100%
100%
100%
100%
Total Tons
Disposed
6,926
39,298
2,882
31,701
11,349
' Disposal costs shown are representative simplifications of the actual costs used in the analysis. See Exhibit 3-10 for further details.
(I) = Intact whole monitors.
(B) = Bare CRTs without the casing.
(C) = Crushed CRT glass.
NA = Not Applicable.
August 24, 2001 - DRAFT
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Under the primary alternative, 3,008 additional tons of CRTs are sent to glass processors
relative to the Subtitle C baseline. These CRTs are re-directed primarily from hazardous waste
facilities (decrease of 2,568 tons) and from export (decrease of 3,817 tons) under the baseline. The
2,568 tons of CRTs diverted from landfills translates to a volume of 456,000 cubic feet. The tons of
CRTs recycled under the primary alternative increases by 4,669 tons over the baseline.
Under the CSI alternative, 3,811 additional tons of CRTs are sent to glass processors relative
to the Subtitle C baseline. These CRTs would go to hazardous waste facilities (decrease of 2,045 tons)
and for export (decrease of 3,326 tons) under the baseline. The 2,045 tons of CRTs diverted from
landfills translates to a volume of 351,000 cubic feet. The tons of CRTs recycled under the CSI
alternative increases by 3,697 tons over the baseline.
Under the Subtitle C baseline, generators will send the minimum number of shipments to stay in
compliance with hazardous waste accumulation limits. For small quantity generators, the storage limit is
180 days; these establishments will make two shipments per year. Large quantity generators have a
storage limit of 90 days; they will make four shipments per year. Collectors are assumed to handle
relatively larger volumes of CRTs and thus are assumed to ship CRTs when they have full loads or at
least four times per year for LQGs and two times a year for SQGs. On average, collectors ship CRTs
two and four times per year, respectively for SQGs and LQGs. Glass processors are also assumed to
handle relatively larger volumes of CRTs and thus are assumed to ship CRTs when they have full loads
or at least four times per year. On average glass processors ship CRT funnel and panel glass 67 and
96 times per year under the baseline and alternatives, respectively. Under the primary and CSI
alternatives, each former generator is assumed to send discarded CRTs off-site once a year or more
frequently if the volume of CRTs warrants increased shipment frequency.
3.4.1 Disposal Option Assumptions
The following assumptions are used to develop the estimates of the volume of discarded
monitors being sent to each of the disposal alternatives (collectors, reuse, hazardous waste facilities,
reclaimers, and glass processors):
Reuse. The analysis assumes that two percent of discarded CRTs from original users are sent
for reuse in the Subtitle C baseline, and that this percentage remains constant under the primary
and CSI alternatives. The percentage of CRTs sent for reuse by original users is assumed to be
low for several reasons.
• Local organizations that can use donated computers are limited in number and
need for computers. Most donated computers are used locally, although there
is at least one foundation that sends donated computers worldwide for reuse.
• Businesses donating computers are concerned about proprietary information
that may be left on hard drives. This concern reduces the number of computers
that businesses donate.
August 24, 2001 - DRAFT Page 25
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The analysis assumes that 20 percent of discarded CRTs from collectors are sent for
reuse under the Subtitle C baseline, and that this percentage remains constant under the primary
and CSI alternative. Collectors obtain a higher return on reused monitors than they do on
disassembled monitors whose parts are recycled. Thus collectors have a strong economic
incentive to resell monitors for reuse.
Exports. The analysis assumes that only collectors arrange for the export of CRTs and that
only intact CRTs are exported. Under the baseline, collectors are assumed to export 30
percent of CRTs they receive. The literature search indicated that a large, but unknown,
percentage of CRTs are exported.17 Under the primary alternative collectors who are SQGs
are assumed to continue to export 30 percent of the CRTs they receive, while LQGs are
assumed to export 18 percent of the CRTs they receive. Collectors who are LQGs are
assumed to export fewer CRTs under the primary alternative because LQGs have a greater
economic incentive to send CRTs to a glass processor than to export them. Under the CSI
alternative collectors who are SQGs are assumed to continue to export 30 percent of the CRTs
they receive, while LQGs are assumed to export 20 percent of the CRTs they receive.
Collectors. Under the baseline, the analysis assumes that 76 percent of CRTs from original
users are sent to collectors. CRTs going to collectors are consolidated, reused when possible,
demanufactured and recycled, or refurbished. Although collectors are not the least expensive
disposal option they become an economically attractive alternative when administrative and
transportation costs are considered. Thus, most discarded CRTs are assumed to be sent to
collectors. There are two factors that reduce the costs of sending CRTs to collectors. First,
collectors are typically located near businesses, and thus the transportation costs are
comparatively low. Second, CRTs sent to collectors are considered a product and not a waste
and thus do not fall under RCRA control.
The collectors typically will consolidate the CRTs from various establishments and send
them to reclaimers or glass processors. The collectors demanufacture the monitors and recycle
the components that have value. The analysis assumes that LQG collectors have high enough
volumes of CRTs to warrant purchasing glass crushing equipment. Thus all shipments of CRTs
from LQGs to glass processors, hazardous waste facilities, and reclaimers are assumed to be
crushed CRT glass, which has economic benefit. The baseline assumes that 30 percent of the
CRTs the LQG collectors receive are crushed and sent to glass processors, 10 percent are
crushed and sent to reclaimers, and 10 percent are crushed and sent to hazardous waste
facilities. Crushing the CRTs significantly reduces the disposal costs charged by glass
processors, reclaimers, and hazardous waste facilities. More CRTs are assumed to be sent to
glass processors because the low disposal cost for crushed glass at glass processors often
17 National Safety Council, Electronic Product Recovery and Recycling Baseline Report,
Recycling of Selected Electronic Products in the United States. May 1999.
August 24, 2001 - DRAFT Page 26
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outweighs the higher transportation costs due to longer distances. As mentioned above, 20
percent of the regulated CRTs that collectors receive are refurbished and sold for reuse. Thirty
percent of the CRTs received by collectors are assumed to be exported for reuse or recycling.
Since SQG collectors do not crush the CRT glass they are assumed to send more CRTs to
reclaimers than to hazardous waste facilities, because of the lower tipping fees at reclaimers.
Under the regulatory alternatives the analysis assumes that more crushed CRTs are sent to glass
processors because of the low tipping fees and absence of administrative costs. Similarly, more
crushed CRTs are assumed to be sent to reclaimers and less are sent to hazardous waste
facilities because of the administrative burden on CRTs sent to hazardous waste facilities.
Glass Processors. The analysis assumes that a relatively small percentage of CRTs from
original users are sent directly to glass processors because of the higher disposal cost for intact
CRTs and the relatively longer shipping distances. The analysis assumes that only businesses
located near glass processors will send CRTs directly to them.
Hazardous Waste Facilities. The analysis assumes that original users, who are generators due
to CRTs only, will send two percent of discarded CRTs to hazardous waste facilities in the
Subtitle C baseline, and that this percentage remains at two percent under the primary
alternative. Under the CSI alternative, 15 percent of CRTs from original users are assumed to
be sent to hazardous waste facilities. Although the percent of CRTs sent to hazardous waste
facilities is higher under the CSI alternative than the baseline, there is still a 60 percent reduction
in the number of CRTs sent to hazardous waste facilities due to the smaller number of
generators in the CSI alternative. Several contacts at one of the largest Subtitle C facilities in
the United States, Chemical Waste Management, reported receiving no CRTs during 1998.
Contacts at other commercial hazardous waste disposal facilities also report receiving few
CRTs for disposal over the last couple of years.18 However, a Tufts University study reports
that 14 percent of CRTs are sent to landfills or municipal waste combustors. The Tufts data are
believed to include monitors from households. Households are more likely to send their CRTs
to landfills than are RCRA regulated establishments because households incur no direct costs to
send monitors to Subtitle D landfills, but it is expensive for regulated generators to send
monitors for treatment and disposal in Subtitle C or D landfills. Sending intact CRTs to a
hazardous waste facility is more expensive than sending the CRTs to lead smelters or glass
processors. Therefore, most CRTs ending up at hazardous waste facilities are probably
originating in areas of the country without nearby lead smelters, glass processors, or collectors.
Reclaimers. The analysis assumes that under the Subtitle C baseline, 15 percent of CRTs from
original users are sent directly to reclaimers and that this percentage remains constant under the
18 Envirosafe Services of Ohio reported receiving no CRTs last year and approximately 20 to
30 tons the previous year. Clean Harbours in Massachusetts reported that they do receive
CRTs, however, all of the CRTs they receive are processed in Clean Harbours Bristol
Connecticut recycling facility and none are disposed.
August 24, 2001 - DRAFT Page 27
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primary alternative. Lead smelters receive monitors from original users, collectors, and glass
processors. Most reclaimed CRTs are sent to lead smelters; however, copper smelters also
accept CRT glass. The glass is used as a fluxing agent in the smelting furnaces. Two
references indicated that lead smelters take whole monitors, crush them, and then add the
crushed monitor to the smelting furnace.19 However, Noranda indicated that the monitor's
plastic casing tends to foul their sulfuric acid plant, so they only accept the glass. Copper
smelters put crushed or whole monitors into the smelting furnace to recover the copper from the
electronics and use the glass as a fluxing agent. Glass processors send approximately two
percent of the glass they receive to reclaimers.20 This CRT glass is in the form of fines that
cannot be sent to CRT glass manufacturers.
CRT Glass Manufacturers. Only glass processors are assumed to send recycled post
consumer CRT glass to CRT glass manufacturers. Ninety-eight percent of the CRT glass that
glass processors receive is sent to CRT glass manufacturers because of the quality requirements
and technical specificaitons.
Monitor Shipping Size. A typical 15 inch monitor has a volume of 1.5 cubic feet.21 Based on
the assumption that discarded CRT monitors will be shipped carefully to avoid breakage of the
CRT glass, the model includes the assumption that the monitors will, on average, occupy 3.0
cubic feet during shipment.22 This includes approximately 0.3 cubic feet per monitor for the
actual packing material, such as a pallet or box. Whole monitors or whole CRTs are placed on
a pallet and wrapped in plastic, or are placed in one cubic yard boxes (Gaylord containers) to
minimize breakage and to contain any broken glass during transport.
Truck Capacity. The maximum number of monitors that can be shipped in a truck by volume
and weight is calculated to determine if the largest individual shipment from a generator or
handler could be sent in one truck or would require two trucks. A truck volume of 4,280 cubic
feet represents the volume of a semi-trailer measuring 9.5 by 53 by 8.5 feet, which is the largest
standard for trailers. A truck of this size carries up to 1,426 monitors (based on the assumption
that the shipping size of a monitor is 3.0 cubic feet). The maximum payload for standard trucks
is about 23 tons, which is equivalent to 1,314 thirty-five pound monitors. Thus the truck weight
limit is the limiting factor. The maximum number of CRTs that the largest establishments are
19 Doe Run indicated that they accept whole monitors. The article by Aanstoos, T., Mizuki,
C., Nichols, S., and Pitts, G. CRT Disposition: An Assessment of Limitations and
Opportunities in Reuses, Refurbishment, and Recycling in the U.S. (page 75) states that
lead smelters accept whole monitors.
20 Conversation with Greg Vorhees of Envirocycle, April 25, 2001.
21 Sony Trinitron Color Computer Display (manufactured in 1998) owners manual.
22 Based on a conversation with Chris Beyus of Clean Harbor.
August 24, 2001 - DRAFT Page 28
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estimated to generate in one year is 2,082 (see Exhibit 3-1). Thus under the alternatives, where
generators can accumulate CRTs up to one year, shipments from the largest generators would
require two truckloads per year. Under the baseline it is assumed that all SQGs ship twice a
year and that all LQGs ship four times per year. Under the primary alternative, for the
generators that now send CRTs to glass processors or reclaimers and are thus eligible for
regulatory relief, the model assumes that all former SQGs and former LQGs make the number
of shipments per year that minimizes the total of their administrative, storage, and transportation
costs. The analysis estimates that under the primary alternative former SQGS make one
shipments and former LQGs make two shipments per year.
3.5 Estimate Administrative Compliance Costs
This section describes the administrative requirements and costs applicable to two groups of
generators (i.e., generators due solely to CRTs and generators due to non-CRT hazardous wastes)
under the baseline and the primary and CSI alternatives. Disposal costs, transportation costs, and
storage costs in the baseline and under each alternative are addressed in Sections 3.6, 3.7, and 3.8,
respectively.
3.5.1 Baseline Unit Costs for Original Users (Generating No Non-CRT Hazardous
Waste)
The analysis models the current management of discarded CRTs assuming 100 percent
compliance with RCRA Subtitle C requirements under the Subtitle C baseline. Administrative activities
required under Subtitle C and the associated unit costs are summarized in Exhibit 3-7.
3.5.2 Baseline Unit Costs for Original Users Also Generating Non-CRT Hazardous
Waste
The analysis models the current management of discarded CRTs assuming 100 percent
compliance with RCRA Subtitle C requirements under the Subtitle C baseline. However, most of the
administrative costs (all but manifests for shipments of CRTs to smelters and glass processors that do
not refurbish CRTs) are assumed to be due to non-CRT hazardous waste and thus are not included in
the analysis. The manifest costs that are assumed to be due to CRTs are only for shipments to smelters
and glass processors that do not refurbish CRTs and have the same cost as contained in Exhibit 3-7.
3.5.3 Primary A her native
The full Subtitle C administrative requirements are eliminated under the primary alternative for
entities shipping CRTs to collectors, glass processors, and lead smelters. The activities required for
these entities are only packaging and labeling requirements for CRTs that are broken. Generators
sending CRT waste for disposal are still subject to full RCRA requirements.
August 24, 2001 - DRAFT Page 29
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Administrative activities required under the primary alternative and the associated unit costs are
summarized in Exhibit 3-8.
3.5.4 CSI Alternative
Subtitle C administrative requirements are significantly reduced under the CSI alternative for
entities shipping CRTs to glass processors. The activities required for these handlers are the same
types of activities that a facility incurs under the Universal Waste Rule. Generators sending CRT waste
to smelters or for disposal are still subject to full RCRA requirements.
Administrative activities required under the CSI alternative and the associated unit costs are
summarized in Exhibit 3-9.
Exhibit 3-7: Generator Administrative Requirements and Unit Costs Under the
Subtitle C Baseline
Required Activity
One-Time Costs*
Notification of Hazardous Waste Activity
Rule Familiarization
Emergency Planning
Total One-Time Costs per Facility
Annual Costs
Annual Review of Regulations
Recordkeeping
Personnel Safety Training (annualized cost)
Manifest Training
Biennial Reporting (annualized cost)
Total Annual Costs per Facility
Variable Costs**
Manifest and Land Disposal Restriction Notification (per
shipment)
Exception Reporting (per report)***
Storage Costs (per square foot of storage area)
Unit Costs
SQG
$218
$477
$533
$1,228
$91
$47
$384
$37
$0
$560
$44
$44
$8
LQG
$218
$1,373
$787
$2,378
$91
$47
$482
$180
$194
$994
$54
$97
$8
* Each year one percent of the generators are assumed to be new facilities and thus they incur additional costs as startup facilities.
The entry rate is used to determine the number of establishments expected to incur initial costs in any year (one percent of the
generator universe).
** Variable costs depend on the number of shipments made by a generator. The number of shipments per year is calculated and used
to estimate the administrative costs.
*** Tjjg analysis USgs an estimate of one half of one percent of manifests require an exception report.
Sources of Cost Data: Supporting Statement for EPA ICR # 261 "Reporting and Recordkeeping Requirements for Generators of
Mercury-Containing Lamps" June 29, 1994; Supporting Statement for ICR #801 "Requirements for Generators, Transporters, &
August 24, 2001 - DRAFT
Page 30
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Waste Management Facilities Under the RCRA Hazardous Waste Manifest System." 2/13/97; Technical Background Document,
Economic Impact Analysis for the Proposes Rule for the Management of Spent Mercury-Containing Lamps. 1994; and Supporting
Statement for EPA ICR # 0976, Amendment to OMB ICR # 2050-0024 "Analysis of Costs Under Draft Modifications to The
Manifest System, Final Report," August 1, 1997.
Exhibit 3-8: Generator Administrative Requirements and Unit Costs Under the
Primary Alternative
Required Activity
One-Time Costs *
Rule Familiarization
Total One-Time Costs per Facility
Annual Costs
Total Annual Costs per Facility
Variable Costs**
Labeling and Packaging Requirements for Shipments of
Broken CRTs
Storage Costs (per square foot of storage area)
Unit Costs
SQG
$477
$477
$0
$19
$8
LQG
$477
$477
$0
$37
$8
* Each year one percent of the generators are assumed to be new facilities and thus they incur additional costs as startup facilities.
The entry rate is used to determine the number of establishments expected to incur initial costs in any year (one percent of the
generator universe).
** Variable costs depend on the number of shipments made by a generator. The number of shipments per year is calculated and used
to estimate the administrative costs.
Sources of Cost Data: Supporting Statement for EPA ICR # 261 "Reporting and Recordkeeping Requirements for Generators of
Mercury-Containing Lamps" June 29, 1994; Supporting Statement for ICR #801 "Requirements for Generators, Transporters, &
Waste Management Facilities Under the RCRA Hazardous Waste Manifest System." 2/13/97; Technical Background Document,
Economic Impact Analysis for the Proposes Rule for the Management of Spent Mercury-Containing Lamps. 1994; and Supporting
Statement for EPA ICR i 0976, Amendment to OMB ICR i 2050-0024 "Analysis of Costs Under Draft Modifications to The
Manifest System, Final Report," August 1, 1997. Supporting Statement for EPA Information Collection Request Numberf]
"Reporting and Recordkeeping Requirements for the Proposed Rule on Cathode Ray Tube (CRT) Glass Reuse." Working Draft,
October 9, 1998.
August 24, 2001 - DRAFT
Page 31
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Exhibit 3-9: Handler Administrative Requirements and Unit Costs Under the CSI
Alternative
Required Activity
One-Time Costs*
Notification of Hazardous Waste Activity
Rule Familiarization
Total One-Time Costs per Facility
Annual Costs
Annual Review of Regulations
Mark CRT Materials or Storage Area
Mark Time/Date on CRT Material
Total Annual Costs per Facility
Variable Costs**
Recordkeeping of Outbound Shipments (per shipment)
Unit Costs
SQH
$0
$477
$477
$47
$27
$27
$100
$0
LQH
$185
$477
$662
$47
$53
$53
$154
$4
* Each year one percent of the handlers are assumed to be new facilities and thus they incur additional costs as startup facilities. The
entry rate is used to determine the number of establishments expected to incur initial costs in any year (one percent of the handler
universe).
** Variable costs depend on the number of shipments made by a handler. The number of shipments per year is calculated and used to
estimate the administrative costs.
Source of Cost Data: Supporting Statement for EPA Information Collection Request "Reporting and Recordkeeping Requirements
for the Proposed Rule on Cathode Ray Tube (CRT) Glass Reuse," October 1998.
3.6 Estimate Disposal Costs
The CRT management options currently being used by CRT generators include giving CRTs to
establishments that will reuse them, and sending CRTs to collectors, glass processors, smelters, or
treatment and disposal facilities that dispose of the treated CRTs in Subtitle C or D landfills. The per
ton cost for each disposal option is based on a literature search and on contacts at representative
facilities. The disposal costs obtained for each disposal option varied considerably. The maximum cost
typically is two to four times the minimum cost obtained for each disposal option. For each disposal
option the average of the costs obtained is used in the analysis. Exhibit 3-10 summarizes the cost per
ton for each disposal option.
August 24, 2001 - DRAFT
Page 32
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Exhibit 3-10: CRT Disposal Costs (per ton)
Disposal Option
Cost (Price Paid) per Ton
ollectors
ixport
leuse
Treatment and Subtitle C or D Landfill Disposal
Whole CRTs
Crushed CRTs
leclaimer
Whole CRTs
Whole bare CRTs
Crushed CRTs
Gflass Processor
Broken CRTs with no metal
Broken CRTs with metal
Whole bare CRTs
Broken mixed color and monochrome CRTs
Whole CRTs
RT Glass Manufacturer
$271
$ 107
$0
$ 1,500
$ 160
$295
$207
$ 152
$0
$ 100
$ 192
$325
$333
($ 175)
Details of the disposal costs by source are presented in Appendix C.
3.7 Estimate Transportation Costs
Under the baseline and each alternative, either hazardous or non-hazardous waste
transportation costs are used depending on the status of the CRTs being shipped. Different costs are
also used for shipments that are assumed to be partial truckloads and full truckloads. Shipments of
CRTs from collectors and glass processors are assumed to be full truckloads, except for collector
shipments sending CRTs for reuse. Shipment of CRTs for reuse are assumed to be partial truckloads
for three reasons:
• the collectors get the highest benefit from returning the CRTs to the market place as
quickly as possible, and thus are less likely to wait until they have a full truckload.
August 24, 2001 - DRAFT
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• the shipping distances for reuse are likely to be relatively short, because most CRTs are
reused locally, thus the expense of sending partial loads is roughly equivalent to sending
full shipments.
• collectors who primarily refurbish CRTs for reuse tend to be smaller and handle smaller
volumes and thus may take a long time to generate a full truckload of CRTs for reuse.
Exhibit 3-12 provides a summary of the two factors (i.e., hazardous or non-hazardous transport
and partial or full truckload) that drive the transportation costs for each of the disposal options. The
analysis assumes that shipments of less than one truckload are consolidated by the shipping company
prior to trucking the waste CRTs to a disposal facility, and that consolidated rates are passed on to
generators. The analysis assumes consolidated shipments because of the low volumes of waste (0.5 to
6 tons for original users and 9 to 16 tons for collectors under the baseline) and because generators are
clustered around urban and suburban areas. As discussed in Section 3.4, regulated generators are
found in 66 different two-digit SIC codes. For any individual generator the assumption made in this
analysis will not be accurate. However, in the aggregate the assumptions used in the analysis
reasonably estimate the actual transportation costs incurred.
Exhibit 3-12: Transportation Cost Driver Assumptions
CRT Management Options
Collectors
Reuse
Treatment &
Disposal
Reclaimer
Glass
Processor
CRT Glass
Manufacturer
Baseline
Original Users
Collectors
Glass Processors
NH - LIT
NA
NA
NH - LIT
NH - LIT
NA
H-LTT
H-TL
NA
H-LTT
H-TL
H-TL
NH - LTT
H-TL
NA
NA
NA
H-TL
Primary Alternative
Original Users
Collectors
Glass Processors
NH - LIT
NA
NA
NH - LIT
NH - LIT
NA
H-LTT
H-TL
NA
NH - LTT
NH-TL
NH-TL
NH - LTT
NH-TL
NA
NA
NA
NH-TL
CSI Alternative
Original Users
Collectors
Glass Processors
NH - LIT
NA
NA
NH - LIT
NH - LIT
NA
H-LTT
H-TL
NA
H-LTT
H-TL
H-TL
NH - LTT
NH-TL
NA
NA
NA
NH-TL
NH = Non-hazardous transport.
H = Hazardous material transport.
LTT = Less than truck load shipments.
TL = Full truck load shipments.
August 24, 2001 - DRAFT
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NA = Not applicable.
The transportation costs for less than truck load shipments consist of two parts, a fixed fee and
a variable fee based on tons shipped and miles driven. The variable portion of the per shipment
transportation cost is based on an average shipment size and the assumed miles that the CRTs are
shipped to each disposal option. For SQGs the average shipment size is calculated by dividing the total
tons of CRTs shipped by the total number of shipments. The total number of shipments is calculated by
assuming that each SQG ships twice a year and multiplying by the number of SQGs. The same
methodology is used for calculating the average shipment size for LQGs, except LQGs ship CRTs four
times per year. Under the regulatory alternatives, unregulated establishments are assumed to ship
CRTs once per year, unless they generate enough CRTs to need two shipments. Only formerly
regulated collectors generate enough CRTs to need two shipments per year. Glass processors are
estimated to make 23 shipments of funnel glass under the baseline, 32 shipments under the primary
alternative, and 34 shipments under the CSI alternative. The glass processor shipments only include
shipments of funnel glass, because panel glass does not contain enough lead to render it hazardous
waste when discarded. The transportation costs for full truck load shipments consists of a variable fee
based on the miles the load must be shipped. Appendix E contains the average shipment sizes for each
type of entity distributing CRTs to each of the management options. Exhibit 3-13 presents the cost
functions for hazardous waste and non-hazardous materials for both less than truckload and full truck
loads. These cost functions include the pre-shipment handling and administrative costs associated with
each shipment. Exhibit 3-14 presents the estimated or assumed mileage between each type of
establishment distributing CRTs and the CRT management options.
The transportation costs to collectors and disposal facilities for generators due to non-CRT
hazardous waste are zero because the CRTs are assumed to be shipped with the generator's other
hazardous waste. The actual cost is greater than zero but is not significant to the analysis.23
23 The cost to transport CRTs for generators due to non-CRT waste is estimated to be less
than $20 per shipment. This estimate is based on the per ton-mile rate of $0.16, 250 miles to a
treatment and disposal facility, and 0.5 tons of CRTs per shipment. The actual tons shipped by
these generators is typically less than 0.5 tons. There are approximately 800 establishments in
this category. Thus the total shipping cost is approximately $16,000, or less than one half of
one percent of the savings under the primary alternative.
August 24, 2001 - DRAFT Page 3 5
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Exhibit 3-13: Transportation Cost Functions
Full Truck
Loads
Less Than
Truck Load
< 50 miles
Hazardous Non-Hazardous
NA $3.41/mile
NA $108 + $0.18/ton-mile
50 to 400 miles
Hazardous
$2.98/mile
$162 + $0.16/ton-mile
Non-Hazardous
$2.25/mile
$108 + $0.12/ton-mile
Source: ICF Memorandum to Allen Maples, EPA, August 31, 1998.
NA = Not applicable.
Exhibit 3-14: Transportation Distances for Each CRT Management Option (Miles)
Original Users
Collectors
Glass Processors
CRT Management Options
Collectors
20
NA
NA
Reuse
20
20
NA
Treatment
& Disposal
250
250
NA
Reclaimer
300
300
350
Glass
Processor
200
200
NA
CRT Glass
Manufacturer
NA
NA
100
NA = Not applicable.
3.8 Estimate Storage Costs
Storage costs may increase for former generators under the regulatory alternatives because the
frequency of shipments decreases relative to shipments by generators. This section contains the storage
costs applicable to generators and former generators.
Storage costs depend on several assumptions about the type of storage facility that is used by
the generator. Some generators may use offsite commercial warehouse space which generally cost
three to four dollars per square foot for an annual rental, plus handling fees for each shipment in or out
of the warehouse.24 Other generators may store materials in self storage facilities that generally cost
$12 to $15 per square foot per year.25 Finally other generators may have on site storage that they use.
The on site storage cost can be considered to be zero if space is available and the building space is
considered a sunk cost. However, for some generators there will be an opportunity cost of storing the
24 Conversation with Hagerstown Transload Services on February 9, 1999.
25 Conversation with American Moving and Storage on February 9, 1999.
August 24, 2001 - DRAFT Page 36
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CRTs. In this case the storage cost is the cost of the lease or rent per square foot. The analysis
assumes an average cost of eight dollars per square foot per year for storage.26
The model assumes that each CRT will occupy three cubic feet and that the CRTs will be
stacked up to eight feet high. Exhibit 3-15 summarizes the number of CRTs stored and the annual
storage costs for each type of generator.
26 The storage cost of eight dollars per square foot is an assumed average cost based on the
information from the two storage companies contacted, Hagerstown Transload Services and
American Moving and Storage.
August 24, 2001 - DRAFT Page 3 7
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Exhibit 3-15: Storage Costs for Monitors
Number of CRTs Storage Area Cost per Square
Stored Required (ft2) Foot
Generators Due to CRTs Alone
Baseline
SQG
LQG
84
319
Primary Alternative
SQG
LQG
Former SQG
Former LQG
84
319
168
637
CSI Alternative
SQG
LQG
SQH
LQH
84
319
170
NA NA
Generators Due to CRTs and Non-CRT Hazardous
Baseline
SQG
LQG
25
13
Primary Alternative
SQG
LQG
Former SQG
Former LQG
25
13
50
51
CSI Alternative
SQG
LQG
SQH
LQH
25
13
NA NA
NA NA
31
119
31
119
63
239
31
119
64
Waste
9
5
9
5
19
19
9
5
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
NA
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
$8.30
NA
NA
Annual Storage
Cost
$261
$991
$261
$991
$522
$1,983
$261
$991
$529
NA
$78
$40
$78
$40
$154
$159
$78
$40
NA
NA
NA = Not Applicable
August 24, 2001 - DRAFT
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3.9 Estimate Costs for Glass Processors and Transporters
3.9.1 Costs to Glass Processors
Only a small number of dedicated processors exists at present. The analysis estimates there are
five glass processors. The glass reclamation process is exempt from RCRA Subtitle C regulation (40
CFR 261.6(c)(l)). However, under the baseline the storage of CRTs prior to reclamation requires a
RCRA Part B Permit. The estimated cost for obtaining a storage permit is $13,300.27 If a glass
processor refurbishes some of the CRTs, then any CRTs sent to the glass processor that possibly will
be refurbished are not a solid waste. Exhibit 3-16 shows the glass processor activities required under
the baseline and regulatory alternatives and the associated unit costs.
3.9.2 Costs to CRT Glass Transporters
Current CRT transporters are assumed to transport other hazardous wastes and other non-
hazardous materials and, consequently, do not incur savings under the proposed rule. To the extent
that new transporters enter the CRT market that do not transport other hazardous wastes, these new
transporters will incur minor compliance costs attributable to reviewing regulations. The analysis does
not attempt to quantify the costs associated with new transporters shipping CRTs due to the uncertainty
in the number of new transporters likely to enter this market and the estimated small impact on the
overall analytical results.
27 ICF Incorporated, Economic Impact Analysis for the Military Munitions Final Rule,
June 1996.
August 24, 2001 - DRAFT Page 39
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Exhibit 3-16: Glass Processor Compliance Requirements and Unit Costs
Required Activity
Initial Fixed Costs
Notification of Hazardous Waste Activity
Rule Familiarization
Emergency Planning
Environmental Justice Requirements
Total Initial Fixed Costs per Facility
Annual Costs
Annual Review of Regulations
Recordkeeping
Personnel Safety Training (annualized cost)
Manifest Training
Biennial Reporting
Total Annual Costs per Facility
Variable Costs
Manifest and Land Disposal Restriction Notification
(per shipment)
Recordkeeping of Incoming Shipments (per shipment)
Recordkeeping of Outbound Shipments (per shipment)
Unit Costs
Baseline
$218
$1,373
$787
$0
$2,378
$91
$47
$482
$180
$194
$994
$54
$0
$0
Primary
Alternative
$218
$1,373
$787
$0
$2,378
$91
$47
$482
$180
$194
$994
$0
$0
$0
CSI
Alternative
$218
$1,373
$787
$159
$2,537
$91
$47
$482
$180
$194
$994
$0
$4
$9
Source of Cost Data: Supporting Statement for EPA Information Collection Request Number [ ] "Reporting and Recordkeeping
Requirements for the Proposed Rule on Cathode Ray Tube (CRT) Glass Reuse," October 1998; and Supporting Statement for EPA ICR
# 261 "Reporting and Recordkeeping Requirements for Generators of Mercury-Containing Lamps" June 29, 1994.
3.10 Estimate the Impact of Compliance Costs on Affected Entities
The analysis estimates first-order economic impacts of incremental costs by calculating the
cost-to-sales ratio for each type of original user in each two-digit SIC code. Census data for the year
1994 served as the source of average sales data for establishments in each two-digit SIC code.
(Appendix F presents the average sales per establishment for all SIC codes used in the calculations for
this report.) Incremental compliance costs or cost savings for representative establishments are
developed by adding the costs as described previously. For purposes of this analysis, economic
impacts are considered significant if costs exceed three percent of sales.
The impacts analysis is likely to overstate economic impacts (whether costs or savings) because
the sales data used in the analysis represent average values for each SIC code as a whole, whereas the
estimated compliance costs arise only for the entities that are large enough to be considered an SQG or
August 24, 2001 - DRAFT
Page 40
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LQG in the baseline. Such entities are likely to have an average sales value higher than the average for
the industry as a whole.
3.11 Methodology for Subtitle D Management Baseline
This analysis includes a Subtitle D management baseline because it may more accurately
represent current CRT management practices. This baseline uses the same methodology and
assumptions as the RCRA Subtitle C baseline except for three changes in assumptions. The first
change is the percentage of facilities assumed to manage CRTs using Subtitle D landfills. The second
change is the assumed flow of CRTs to each of the disposal options, including Subtitle D landfills. The
third change is that estimated costs are different under this baseline. One similarity between the
baselines is the percent of CRTs recycled. Although the number of tons of CRTs sent for recycling
under the two baselines differs by about a factor of five, the percent of CRTs sent for recycling is
approximately the same at about 45 percent.
The Subtitle D management baseline assumes that 20 percent of facilities are managing their
CRTs as Subtitle C waste and 80 percent of facilities are managing their CRTs as Subtitle D waste.
The 20 percent of facilities that are managing their CRTs under Subtitle C incur all of the administrative,
disposal, transportation, and storage costs as discussed in Sections 3.5 through 3.8. Under these
assumptions in the baseline, there are 213 SQGs, 23 LQGs, and 2,648 establishments sending CRTs
to Subtitle D landfills without treatment. The primary alternative is assumed to induce some
establishments sending CRTs to Subtitle D landfills to send their CRTs to glass processors or
reclaimers. Thus under the primary alternative, there are 58 SQGs, 5 LQGs, 155 former SQGs, 18
former LQGs, and 2,648 establishments sending CRTs to Subtitle D landfills. The CSI alternative is
assumed to induce some establishments sending CRTs to Subtitle D landfills to send their CRTs to glass
processors. Thus under the CSI alternative, there are 32 SQGs, 4 LQGs, 200 small quantity handlers
(CSI SQHs), and 2,648 establishments sending CRTs to Subtitle D landfills. Exhibit 3-17 contains the
flow assumptions for CRTs under the Subtitle D management baseline. Exhibits 3-18 and 3-19 contain
the flow assumption for CRTs under the primary and CSI alternatives, respectively.
The cost for managing CRTs under the Subtitle D baseline are assumed to include only
disposal costs of $41 per ton. Thus, facilities managing CRTs under the Subtitle D baseline have no
administrative costs, no storage costs, and no transportation costs. There are no administrative costs
because these facilities will not prepare manifests, review regulations on an annual basis, or conduct any
of the other activities required under Subtitle C management. The storage costs are assumed to be zero
because facilities will not store the CRTs, but will place them with their other trash as soon as they
discard the CRTs. The transportation costs are approximately zero because facilities will place the
CRTs in with their other trash and not ship the CRTs separately. An incremental transportation cost
could be attributed to the CRTs based on the weight of the CRTs and the hauling charges companies
pay for their trash; however, the analysis assumes that any incremental transportation cost is immaterial
to the results.
August 24, 2001 - DRAFT Page 41
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Exhibit 3-17: Assumed Distribution of Discarded Monitors and CRT Glass Under the Subtitle D Management Baseline
Entity Distributing
CRTs
Disposal Cost
Original User SQGs and
Due to CRTs Only
Due to CRTs and
Non-CRT
Hazardous Waste
Collectors
SQGs
LQGs
Glass Processors
Total Tons
Reuse
$0/ton (I)
LQGs*
2% (I)
0% (I)
20% (I)
20% (I)
0%
1,447
Export
$100/ton(I)
0%
0%
20% (I)
20% (I)
0%
576
Intermediate Processors
Collector
$271 /ton (I)
6% (I)
10% (I)
NA
NA
NA
2,879
Glass
Processor
$333/ton(I)
$0/ton (C)
5% (I)
0%
5% (I)
10%(C)
NA
1,473
Disposal Options
Municipal
Solid Waste
Landfill
$41 /ton
80% (I)
80% (I)
50% (B)
43% (B)
0%
38,234
Hazardous
Waste
Facility
$l,500/ton(I)
$160/ton(C)
2% (I)
10% (I)
0% (B)
2% (C)
0%
1,168
Reclaimer
$207/ton (I)
$152/ton(C)
5% (I)
0%
5% (B)
5% (C)
2% (C)
2,295
CRT Glass
Manufacturer
-$175/ton(C)
NA
NA
NA
NA
98% (C)
1,443
Total
Percent
100%
100%
100%
100%
100%
Total Tons
Disposed
43,577
2,647
240
2,639
1,473
* Disposal costs shown are representative simplifications of the actual costs used in the analysis. See 3-10 for further details.
(I) = Intact whole monitors.
(B) = Bare CRTs without the casing.
(C) = Crushed CRT glass.
NA = Not Applicable.
August 24, 2001 - DRAFT
Page 42
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Exhibit 3-18: Assumed Distribution of Discarded Monitors Under the Primary Alternative and the Subtitle D Baseline
Entity Distributing
CRTs
Disposal Cost*
Original Users
SQGs and LQGs
Former SQGs and
LQGs
Out of Compliance
SQGs and LQGs
Reuse
$0/ton (I)
NA
2% (I)
NA
Export
$100/ton(I)
NA
0%
NA
Intermediate Processors
Collector
$271 /ton (I)
NA
10% (I)
NA
Glass
Processor
$333/ton(I)
$0/ton (C)
NA
6% (I)
NA
Disposal Options
Municipal
Solid Waste
Landfill
$41 /ton
NA
NA
75% (I)
Hazardous
Waste
Facility
$l,500/ton(I)
$160/ton(C)
2% (I)
NA
NA
Reclaimer
$207/ton (I)
$152/ton(C)
NA
7% (I)
NA
CRT Glass
Manufacturer
-$175/ton(C)
NA
NA
NA
Total
Percent
100%
Total Tons
Disposed
46,224
Collectors
Regulated Post-Rule
SQGs
LQGs
20% (I)
20% (I)
30% (I)
18% (I)
NA
NA
10%(B)
15%(C)
40% (B)
40% (B)
2% (B)
2% (C)
13%(B)
8% (C)
NA
NA
100%
100%
8
83
Unregulated Post-Rule
Former SQGs
Former LQGs
Glass Processors
Total Tons
20% (I)
20% (I)
0%
1,812
15% (I)
15% (I)
0%
680
NA
NA
NA
4,530
10%(B)
15%(C)
NA
2,027
40% (B)
40% (B)
0%
35,788
NA
NA
0%
923
15%(B)
10% (C)
2% (C)
3,494
NA
NA
98% (C)
1,987
100%
100%
100%
370
4,070
2,027
' Disposal costs shown are representative simplifications of the actual costs used in the analysis. See 3-10 for further details.
(I) = Intact whole monitors.
(B) = Bare CRTs without the casing.
(C) = Crushed CRT glass.
NA = Not Applicable.
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Exhibit 3-19: Assumed Distribution of Discarded Monitors Under the CSI Alternative and the Subtitle D Baseline
Entity Distributing
CRTs
Disposal Cost*
Original Users
SQGs and LQGs
Former SQGs and
LQGs (SQHs and
LQHs)
Out of Compliance
SQGs and LQGs
Collectors
SQGs
LQGs
Glass Processors
Total Tons
Reuse
$0/ton (I)
NA
2% (I)
NA
20% (I)
20% (I)
0%
1,572
Export
$100/ton(I)
NA
0% (I)
NA
20% (I)
20% (I)
0%
786
Intermediate Processors
Collector
$271 /ton (I)
NA
10% (I)
NA
NA
NA
NA
3,930
Glass
Processor
$333/ton(I)
$0/ton (C)
NA
10% (I)
NA
10%(B)
15%(C)
NA
2,702
Disposal Options
Municipal
Solid Waste
Landfill
$41 /ton
60% (I)
NA
78%
38% (B)
38% (B)
0%
36,301
Hazardous
Waste
Facility
$l,500/ton(I)
$160/ton(C)
15% (I)
NA
NA
2% (B)
2% (C)
0%
1,086
Reclaimer
$207/ton (I)
$152/ton(C)
25% (I)
NA
NA
10% (B)
5% (C)
2% (C)
1,913
CRT Glass
Manufacturer
-$175/ton(C)
NA
NA
NA
NA
NA
98% (C)
2,648
Total
Percent
100%
22%
78%
100%
100%
100%
Total Tons
Disposed
6,926
8,646
30,652
327
3,602
2,702
* Disposal costs shown are representative simplifications of the actual costs used in the analysis. See Exhibit 3-10 for further details.
(I) = Intact whole monitors.
(B) = Bare CRTs without the casing.
(C) = Crushed CRT glass.
NA = Not Applicable.
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3.12 Limitations of the Methodology and Data
The accuracy of the analysis depends on a wide variety of data and assumptions. The following
is a list of assumptions, limitations, and other factors affecting the accuracy of the analysis. Some
assumptions tend to increase or decrease the savings of the alternatives, as noted in the discussion of
the individual assumptions. Except where noted, assumptions are best estimates and are not believed
to introduce systematic bias into the results.
3.12.1 Assumptions
Life Cycle Flow of CRTs
• The assumed percentages of CRTs sent from generators to Subtitle C or D
landfills, smelters, glass processors, collectors, and for reuse or export.
Information on the flow of CRTs is mostly anecdotal. See Exhibits 3-3, 3-4, 3-5, 3-
17, 3-18, and 3-19 for the percentages used in the analysis. In developing the flow
percentages, the analysis takes into consideration the stigma of hazardous waste.
• The assumed percentage of generators that are no longer regulated under the
primary or CSI alternatives. Under the primary alternative 98 percent of baseline
generators are assumed to no longer be regulated. Under the CSI alternative 85
percent of generators, who are original users, are assumed to no longer be regulated.
More generators become unregulated under the primary alternative because CRTs
going to reclaimers are not regulated.
• The number of CRTs from televisions discarded by businesses is insignificant
compared to the number of CRTs from monitors. Available data on television use in
businesses are not adequate to incorporate into the analysis. The number of televisions
used in businesses is believed to be relatively insignificant compared with the number of
computer monitors.28 Eliminating televisions from the analysis is not believed to
significantly affect the analysis, although this assumption could change if business use of
televisions increases (e.g., due to increases in televideo conferencing). This assumption
may result in the reported savings of the alternatives being understated because the total
number of CRTs generated is underestimated.
• Original users do not export CRTs directly. Only collectors export CRTs.
• All exports of CRTs are of intact CRTs for refurbishment and reuse.
28 One of the most likely industries to discard a significant quantity of televisions is the hotel
industry, which is exempt from the RCRA hazardous waste requirements (40 CFR
§261.4(b)(l)).
August 24, 2001 - DRAFT Page 45
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Monitor Characteristics
• The lifetime of a computer monitor in businesses is assumed to be 3.5 years.
• The estimated percentage of color monitors in use in businesses 3.5 years prior to
the modeled year is 90 percent.
• The assumed percentage of laptop computers in use 3.5 years prior to the
modeled year is 18 percent.
• The estimated average weight of computer monitors being discarded in the
modeled year is 35 pounds.
Transportation
• The assumed transportation costs for hazardous waste generators that are
generators due to non-CRT hazardous wastes. These generators are assumed to
include their CRTs in regular shipments of other hazardous waste when the CRTs are
sent for treatment and disposal in Subtitle C or D landfills. Thus the cost of shipping the
CRTs to these disposal options is only an incremental cost and is assumed to be zero in
the analysis for both the baseline and regulatory alternatives. When these generators
send CRTs to collectors, smelters, or glass processors the analysis assumes that these
are dedicated shipments and the generator incurs transportation costs under both the
baseline and regulatory alternatives. This assumption may result in the reported savings
of the alternatives being underestimated because the costs of shipping CRTs is
underestimated.
• Under the baseline, shipments of CRTs are transported as hazardous waste if the
shipments are going for disposal, to lead smelters, or to glass processors. Under
the primary alternative, shipments of CRTs are transported as hazardous waste
only if the shipments are going for disposal. Under the CSI alternative, shipments
of CRTs are transported as hazardous waste if the shipments are going for
disposal or to lead smelters.
• The distances to each of the CRT management options. See Exhibit 3-14 for the
transportation distances used in the analysis.
Generators
• The assumed distribution ofSQGs across all two-digit SIC codes. Existing
databases do not track the SIC codes of all SQG generators. The analysis assumes
that the distribution of SQGs across SIC codes is the same as it is for SQGs that are
August 24, 2001 - DRAFT Page 46
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reported in the Resource Conservation and Recovery Information System (RCRIS)
database.
• The assumed distribution ofSQGs andLQGs across establishment size ranges
within a two-digit SIC code. The analysis assumes that SQGs are 1.5 times and
LQGs are 2 times more likely to have 250 or more employees than non-generator
establishments. This is based on the presumption that larger facilities with more
employees are more likely to meet the thresholds for establishments becoming SQGs or
LQGs.
• The assumed cost savings for generators that are generators due solely to the
disposal of CRTs. The analysis assumes that establishments qualifying as generators
solely due to CRTs do not generate any other hazardous waste and thus can achieve
the maximum savings possible under the proposed rule. This assumption results in the
reported savings of the alternatives being overstated because the total number of these
generators is likely to be overestimated.
• Under the CSI alternative, all collectors will send some CRTs for disposal or to
lead smelters. Therefore, all collectors continue to be fully regulated under the CSI
alternative. This assumption results in the reported savings of the CSI alternative being
understated because it is unlikely that all collectors will continue to send some CRTs for
disposal or to a lead smelter.
• Original users only send intact CRTs. This assumption results in the reported savings
of the alternatives being overstated because some administrative costs are avoided by
generators in the analysis.
• Collectors who are SQGs send bare CRTs that have had the casing and
electronics removed.
• Collectors who are LQGs are the only entities sending any broken CRTs to
reclaimers, hazardous waste facilities, and glass processors. This assumption
results in the reported savings of the alternatives being overstated because some
administrative costs are avoided by SQGs in the analysis.
• One half of all collectors are assumed to send CRTs for disposal or reclamation
and thus are regulated under the baseline. The other half of the collectors are
assumed to send CRTs for reuse, export, or to glass processors who refurbish CRTs.
• The number of CRTs that glass processors send for reuse is insignificant
compared to the number of CRTs that are processed for new CRT glass. This
assumption results in the reported savings of the alternatives being understated because
potential savings are not captured.
August 24, 2001 - DRAFT Page 47
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Seventeen percent of collectors are assumed to be SQGs. Collectors who are
SQGs are assumed to be primarily refurbishers who are able to resell most CRTs with
only small volumes that they discard. Collectors who are LQGs are assumed to be
primarily recyclers who need to recycle large volumes of CRTs to make their business
profitable.
Eight percent of all CRTs are received by collectors who are SQGs.
The analysis models the flow of all CRTs discarded by original users in amounts
exceeding the threshold for conditionally exempt small quantity generators (more
than 100 kg per month), even though many of these original users are not
regulated (because they send their CRTs to collectors, for reuse, or to glass
processors that refurbish CRTs), and do not accrue incremental costs. The flow of
CRTs from these entities is modeled in order to calculate incremental costs on other
regulated entities (e.g., collectors).
Disposal Options
The assumed available capacity of U.S. lead smelters to take discarded CRTs.
The analysis assumes that all U.S. lead smelters are available to accept discarded
CRTs, storing them as necessary. The actual availability of smelters might be less,
because CRTs are shipped as a hazardous waste and smelters who store CRTs must
obtain a RCRA Part B permit. The resources needed and potential compliance
consequences of obtaining a Part B permit discourage most if not all smelters from
obtaining the permit, thus disqualifying them for storing CRTs.
The analysis assumes that lead smelters do not refurbish CRTs for reuse. Thus
under the baseline all shipments of CRTs to lead smelters are regulated shipments. This
assumption results in the reported savings of the alternatives being overstated because it
tends to increase the difference between the baseline and alternatives.
Storage
The analysis assumes a single storage cost rate ($8/ft2)for all facilities, regardless
of potentially available storage alternatives.
Collectors and processors are not allocated storage costs. These entities are not
allocated storage costs because their storage of CRTs is not driven by the regulations
and is an integral part of their primary business.
3.12.2 Limitations
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• State and local governments and their discarded CRTs are not included in the
model This assumption results in the reported savings of the alternatives being
understated because the total number of generators is underestimated.
• The analysis does not model CRTs coming out of or going into long-term storage.
Long-term storage is defined as more than one year.
• The impacts analysis is likely to overstate economic impacts (whether costs or
savings) because the sales data used in the analysis represent average values for
each SIC code as a whole, whereas the estimated compliance costs arise only for
the entities that are large enough to be considered an SQG or LQG in the
baseline. Such entities are likely to have an average sales value higher than the average
for the industry as a whole.
3.12.3 Other Factors
• Consistent with least-cost behavior, the analysis reflects generators of non-CRT
hazardous wastes only to the extent that these entities generate 30 or more CRTs per
year. Generators discarding less than 30 CRTs per year are assumed in the baseline to
consolidate their CRTs shipments with shipments of other hazardous waste; in this case,
the transportation cost for shipping the CRTs is only an incremental cost (i.e., relative to
the cost of shipping the other hazardous wastes). The incremental cost for shipping less
than 30 CRTs is less than $18 per shipment. Under the two regulatory alternatives, if
these generators were to ship CRTs to glass processors or reclaimers, they would be
assumed to ship the CRTs on a separate truck, thereby incurring a significant increase
in transportation costs of more than $100 per shipment. Given the increase in
transportation cost and the low volume of CRTs (i.e., less than 30), the least cost
behavior for these hazardous waste generators is to continue consolidating CRTs with
other hazardous waste shipments. The model does not include such generators whose
behavior will not be affected by the alternatives. The sensitivity analysis in Sections
4.2.4, 4.3.4, 5.2.4, and 5.3.4 includes the CRTs from these entities as well as from
CESQGs.
• The amount of CRT glass that CRT glass manufacturers can recycle is a potentially
limiting factor in the amount of CRTs that can be economically recycled. A recent
study estimates that CRT glass manufacturers could use 125,100 tons of post-
consumer cullet using the current sorting technology.29 If better sorting technology is
developed, then the amount the CRT glass manufacturers could use will increase to at
29 Monchamp, A., Evans, H., Nardone, J., Wood, S., Proch, E., and Wagner, T., Cathode
Ray Tube Manufacturing and Recycling: Analysis of Industry Survey. Electronics Industries
Alliance, May 2001.
August 24, 2001 - DRAFT Page 49
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least 161,600 tons per year. The model estimates that 12 million color CRT monitors
enter the waste stream each year from all businesses (regulated and unregulated). At
an average weight of 35 pounds per CRT, the total weight of color CRT monitors
entering the waste stream is 210,000 tons. The CRT glass constitutes approximately
60 percent of the CRT weight; so the total amount of CRT glass entering the waste
stream per year from businesses is 126,000 tons.30 Thus, all post consumer CRT glass
that is estimated to be generated by all businesses, not just those entities considered in
this analysis, could be used by CRT glass manufacturers. The amount of CRT glass
currently entering the waste stream from regulated establishments is estimated at below
44,000 tons. Therefore, it does not appear that the amount of glass that CRT glass
manufacturers can accept should be a limiting factor in CRT glass-to-glass recycling.
The production capacity of glass processors is a potentially limiting factor in the amount
of discarded CRTs that can be recycled each year, and thus is a limiting factor for the
success of the proposed rule. Currently there are only a few glass processors. The
largest processor is Envirocycle, with an estimated production capacity of 45,000 tons
of CRTs per year.31 However, the estimated total amount of CRTs generated by
regulated generators is 43,750 tons per year. Envirocycle obtains about 10,000 tons of
CRTs from computer monitor and television manufacturers.32 Thus, Envirocycle seems
unlikely to have enough current capacity to process all CRTs generated by regulated
entities. Envirocycle plans to open two new processing facilities by the end of 2001
that will add additional capacity. Also, the capacity of the second glass processor is
likely to be greater than 8,750 tons per year. Therefore, the production capacity of
glass processors is not likely to be an active constraint on the number of regulated
CRTs that could be recycled each year.
The real-world conditions that are approximated in the analysis are likely to change
significantly over the next several years. For example, both the number of computers
used in businesses and the percent of color monitors in use are expected to increase
over time, which would increase the savings under the proposed rule. On the other
hand, trends towards greater use of laptop computers and other flat screen monitors
may eventually lead to reduced savings.
The analysis does not take into consideration State and local laws that prohibit CRTs
from being disposed in municipal solid waste landfills and incinerators or the inclusion of
30 The Microelectronics and Computer Technology Corporation (MCC), page 231.
31 ICF communication with Greg Voorhees of Envirocycle, 2001.
32 ICF communication with Greg Voorhees of Envirocycle, 1996 and 2001, and Envirocycle
web page.
August 24, 2001 - DRAFT Page 50
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CRTs in various State's Part 273 regulations. By not considering such information, the
analysis tends to overestimate the savings accruing to each regulatory alternative.
4.0 Cost Results and Sensitivity Analysis for Subtitle C Management Baseline
The incremental annual savings attributable to both the primary alternative and the CSI
alternative are calculated by subtracting the estimated costs under each alternative from the estimated
costs under the Subtitle C baseline.
4.1 Costs Under the Subtitle C Baseline
The total applicable cost of compliance in the Subtitle C baseline is calculated for several
groups of affected entities. As shown in Exhibit 4-1, the analysis categorizes affected entities based on
whether they are original users or collectors, the amount of waste they generate (SQGs or LQGs), and,
for original users, whether they are regulated solely because of CRT generation or because of a
combination of CRT and non-CRT hazardous waste generation. Collectors are all assumed to be
regulated solely because of CRT generation. Compliance costs also are calculated for glass
processors. Exhibit 4-1 presents the cost per establishment for administrative, storage, transportation,
and disposal costs, and for the total cost of compliance under the baseline. Administrative costs are
assumed to be the same for all generators in each size category (small or large). The other costs vary
across the categories (based on RCRA requirements for different types of generators, on the average
number of CRTs discarded, and on the disposal method used by that generator). So Exhibit 4-1
presents the average cost for each group of generators.
August 24, 2001 - DRAFT Page 51
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Exhibit 4-1: Subtitle C Baseline Compliance Costs
Average Costs per Generator
Admin.
Storage
Transp.
Disposal
Number of
Regulated
Generators
Average Costs per
Potentially Regulated
Generator
Transp.
Disposal
Number of
Potentially
Regulated
Generators
Total Cost
Original Users (Generating No Non-CRT Hazardous Waste)
SQG
LQG
$660
$ 1,234
Subtotal
$261
$991
$270
$739
$870
$6,616
2,066
61
$270
$739
$870
$6,616
10,085
295
$ 15,763,000
$ 2,754,000
$ 18,517,000
Original Users Also Generating Non-CRT Hazardous Waste
SQG
LQG
$88
$217
Subtotal
$78
$40
$255
$499
$501
$517
534
223
$255
$499
$501
$517
1,602
668
$ 1,703,000
$ 962,000
$ 2,665,000
Collectors
SQG
LQG
$668
$ 1,232
Subtotal
$0
$0
$828
$ 1,554
$ 3,370
$ 3,989
50
250
$828
$ 1,554
$ 3,370
$ 3,989
50
250
$ 453,000
$ 3,080,000
$ 3,533,000
Glass Processors
$2,316
$0
$ 6,754
$ (83,960)
5
N/A
Total Baseline Compliance Costs
N/A
N/A
$ (374,000)
$ 24,342,000
Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.
4.2 Primary Alternative
4.2.1 Costs Under the Primary Alternative
The total applicable cost of compliance under the primary alternative is calculated for all of the
generators described in Section 4.1, and for all of the entities that were formerly generators but that no
longer are required to comply with the hazardous waste regulations. These are called "former
generators." Exhibit 4-2 presents the cost per establishment for administrative, storage, transportation,
and disposal costs, and for the total cost of compliance under the primary alternative. Administrative
costs are assumed to be the same for all generators in each size category (small or large). The other
costs vary across the categories (based on RCRA requirements for different types of generators, on the
average number of CRTs discarded, and on the CRT management method used by that generator).
So Exhibit 4-2 presents the average cost for each group of generators.
The average transportation and disposal cost for SQGs and LQGs changes between the
baseline and the primary alternative because, in the baseline, five CRT management options (collector,
reuse, processor, smelter, and hazardous waste landfill) are available while in the primary alternative
only one disposal option (hazardous waste landfill) is considered for regulated generators and four of
August 24, 2001 - DRAFT
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the CRT management options are available (collector, reuse, processor, and smelter) for "former"
generators. The reason for the changes in average collector costs is similar. Under the baseline, five
CRT management options are available (reuse, processor, smelter, hazardous waste landfill, and
export). Under the primary alternative, the same five CRT management options are averaged for
regulated collectors, while "former" collectors have only four CRT management options (reuse,
processor, smelter, and export).
Exhibit 4-2: Primary Alternative Compliance Costs Under the Subtitle C Baseline
Average Costs per Generator
Admin. Istorage llransp. [Disposal
Number of
Regulated
Generators
Average Costs per
Potentially
Regulated Generator
Transp.
Original Users (Generating No Non-CRT Hazardous Waste)
Former SQG
Former LQG
$0 $522 $136 $798
$0 $1,983 $428 $6,068
1,823
54
$136
$428
Subtotal
Disposal
Number of
Potentially
Regulated
Generators
Total Cost
$798
$ 6,068
10,085
295
$ 12,078,000
$ 2,374,000
$ 14,452,000
Original Users Also Generating Non-CRT Hazardous Waste
Former SQG
Former LQG
$0 $154 $117 $236
$0 $159 $117 $243
491
205
$117
$117
Subtotal
$236
$243
1,602
668
$ 813,000
$ 347,000
$ 1,160,000
Collectors
Former SQG
Former LQG
$0 $0 $558 $3,436
$0 $0 $1,135 $3,319
48
240
$558
$1,135
Subtotal
Total Cost to Regulated Generators
Total Compliance Costs under the Primary Alternative
$ 3,436
$3,319
50
250
$391,000
$2,182,000
$ 2,573,000
$ 1,315,000
$ 19,502,000
Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.
4.2.2 Incremental Cost Difference Between the Subtitle C Baseline and the Primary
Alternative
The primary alternative generates a net savings relative to the baseline, due primarily to reduced
administrative requirements and savings from reduced transportation and disposal costs. Savings from
the primary alternative accrue to former generators that would no longer be regulated. The range of
potential savings under the primary alternative is estimated to be from $2,401,00033 to $5,071,000,34
33 Assumes a six year monitor life, an average monitor weight of 30 pounds, and 75 percent of
discarded monitors are color.
34 Assumes a two year monitor life, an average monitor weight of 41 pounds, and 90 percent
of discarded monitors are color.
August 24, 2001 - DRAFT
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with a best estimate of $4,840,000.35 Exhibit 4-3 summarizes the costs under the baseline and the
primary alternative by cost category.
Exhibit 4-3: Costs of Primary Alternative Relative to Subtitle C Baseline
Cost Category
Administrative
Disposal
Transportation
Storage
Total
Baseline
$ 1,888,000
$ 16,373,000
$5,431,000
$ 650,000
$ 24,342,000
Primary Alternative
$ 197,000
$ 15,128,000
$ 2,936,000
$ 1,241,000
$ 19,502,000
Saving (Cost)
$ 1,691,000
$ 1,245,000
$ 2,495,000
$ (591,000)
$ 4,840,000
Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.
4.2.3 Sensitivity Analysis for the Primary Alternative
Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle
C baseline and the primary alternative for the following four parameters: monitor weight, monitor
lifetime, storage costs, and percent of monitors that are color. Appendix G lists the parameters to
which the analysis results are relatively insensitive. The individual sensitivity analysis is conducted by
changing one parameter at a time while holding all other parameters at their best estimate value. Exhibit
4-4 contains the upper and lower bounds and the best estimate values for the four parameters as well
as the percent change of the lower and upper bounds from the best estimate. The upper and lower
bounds were selected because they represent probable limits on the selected parameters. Exhibit 4-5
contains the model results for each individual change. Exhibit 4-6 plots the data in Exhibit 4-5 from the
individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most
sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. The
graph also indicates that the model results are not linearly related with respect to percent color, monitor
weight, and monitor life, since the lines for these parameters are not straight. To determine a potential
maximum upper bound on the savings, a combined sensitivity analysis is conducted using a monitor
weight of 41 pounds, a monitor lifetime of 3.5 years, the percent of color monitors discarded of 90
percent, and storage cost of zero dollars per square foot. The savings under the combined sensitivity
analysis is $5,723,000.
35 Assumes a 3.5 year monitor life, an average monitor weight of 35 pounds, and 90 percent of
discarded monitors are color.
August 24, 2001 - DRAFT
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Exhibit 4-4: Parameter Values for Individual Sensitivity Analysis
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower
Bound
30 Ibs.
2 years
$0
60%
% Change
from Best
Estimate
-14 %
-43 %
-100 %
-33 %
Best Estimate
35 Ibs.
3. 5 years
$8.30
90%
Upper Bound
40 Ibs.
5 years
$ 15
99%
% Change
from Best
Estimate
14%
43%
81%
10%
Exhibit 4-5: Individual Sensitivity Analysis Results
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower Bound
$ 4,326,000
$4,753,000
$5,431,000
$3,861,000
Best Estimate
$ 4,840,000
$ 4,840,000
$ 4,840,000
$ 4,840,000
Upper Bound
$ 5,091,000
$ 3,934,000
$ 4,364,000
$4,871,000
Numbers rounded to nearest thousand.
Sensitivity analysis is also conducted for disposal costs above and below the best estimate
values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for
whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a
best estimate of $160), the savings ranged from $5,141,000 to $4,175,000. By changing the cost for
disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to
$100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton
for crushed CRTs (from a best estimate of $152), the savings ranged from $4,642,000 to $4,990,000.
By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of
$271), the savings ranged from $4,821,000 to $4,879,000. The sensitivity analysis on disposal costs
shows that the model is moderately sensitive to hazardous waste disposal costs and only slightly
sensitive to the reclaimer and collector disposal costs.
August 24, 2001 - DRAFT
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Exhibit 4-6: Plot of Individual Sensitivity Analysis Results for the Primary Alternative
4.2.4
OJ
B
OS
CQ
o
OS
O
U
O
H
$5,500,000
•Monitor Weight
• Monitor Life
• Storage Cost
-Percent Color
$3,750,000
—i $3,500,000
-150% -100% -50% 0% 50%
Percent Change from Best Estimate
100%
Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or
uncertainty) in the given parameters.
Incremental Cost Difference Between the Subtitle C Baseline and the Primary
Alternative, Including Currently Unregulated Monitors and Televisions
To help understand how the two regulatory alternatives might be affected by capacity issues,
the total cost of compliance under the Subtitle C baseline and the primary alternative is calculated
including CRTs from conditionally exempt small quantity generators (CESQG) and households. It is
assumed that 20 million unregulated television CRTs are disposed and 16.7 million unregulated
computer monitor CRTs are disposed from households and CESQGs.36 Exhibit 4-7 contains a
36 The number of televisions disposed of is based on the assumption that there are 100 million
households each with two televisions and that the TVs are discarded after ten years. The 20
million TVs discarded is also consistent with the number of televisions sold in 1991, which was
19.5 million. The number of computer monitor CRTs disposed of is based on data from the
August 24, 2001 - DRAFT
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summary of the costs under the baseline and the primary alternative by cost category. Disposal costs
are higher under the primary alternative than the baseline because it is assumed that a greater
percentage of unregulated CRTs are sent to collectors, which increases the number of CRTs that have
a non-zero disposal cost under the primary alternative.
Exhibit 4-7: Costs of Primary Alternative Relative to Subtitle C Baseline, Including
Unregulated Monitors and Televisions
Cost Category
Administrative
Disposal
Transportation
Storage
Total
Baseline
$ 1,984,000
$ 20,854,000
$ 6,790,000
$ 650,000
$ 30,278,000
Primary Alternative
$ 197,000
$ 21,824,000
$ 5,893,000
$ 1,241,000
$ 29,155,000
Saving (Cost)
$ 1,787,000
$ (970,000)
$ 897,000
$ (591,000)
$ 1,123,000
Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.
The analysis estimates that 51,800 tons of CRT glass are sent to glass processors and that, of
this, 50,700 tons of CRT glass are sent to CRT glass manufacturers. The quantity of CRTs sent to
glass processors may be above the capacity limit for glass processors, since the capacity of one of the
processors is not precisely known. The quantity sent to CRT glass manufacturers is below the capacity
limits for CRT glass manufacturers. As the CRT recycling infrastructure grows and additional
unregulated CRTs are recycled, the capacities of both glass processors and glass manufacturers will be
exceeded. This analysis does not attempt to predict when this might occur.
4.3 CSI Alternative
4.3.1 Costs Under the CSI Alternative
The total applicable cost of compliance under the CSI alternative is calculated for all of the
entities described in Section 4.1, and for all of the entities that were formerly generators but that no
longer are required to comply with the hazardous waste regulations. These are called CSI handlers.
Exhibit 4-8 presents the cost per CSI handler for administrative, storage, transportation, and disposal,
and for the total cost of compliance under the CSI alternative. Administrative costs are assumed to be
the same for all CSI handlers in each size category (small or large). The other costs vary across the
categories (based on RCRA requirements for different types of generators, on the average number of
US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households
have computers.
August 24, 2001 - DRAFT
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CRTs discarded, and on the CRT management method used by that generator). So Exhibit 4-8
presents the average cost for CSI handlers.
The average transportation and disposal cost for SQGs and LQGs changes between the
baseline and the CSI alternative because, in the baseline, five CRT management options (collector,
reuse, processor, smelter, and hazardous waste landfill) are available while in the CSI alternative only
two CRT management options (lead smelter and hazardous waste landfill) are available for regulated
generators, and only three of the CRT management options are available (collector, reuse, and
processor) for CSI handlers.
Exhibit 4-8: CSI Alternative Compliance Costs Under the Subtitle C Baseline
Average Costs per Generator
Admin. Stor
CSIHandlers
SQH
LQH
$100 $
$0
Subtota
1
age Transp.
529 $ 125
$0 $0
Total Cost to Regulated Generators
Disposal
Number of
Regulated
Generators
Average Costs per
Potentially Regulated
Generator
Transp. Disposal
Number of
Potentially
Regulated
Generators
Total Cost
$809
$0
2,452
0
$ 125 $ 809
$0 $0
10,752
0
$ 13,874,000
$0
$ 13,874,000
7,371,000
Total Compliance Costs under the CSI Alternative $ 21,244,000
Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.
4.3.2 Incremental Cost Difference Between the Subtitle C Baseline and the CSI Alternative
The CSI alternative generates a net savings relative to the baseline, due primarily to reduced
administrative requirements and savings from reduced transportation and disposal costs. Savings from
the CSI alternative accrue to CSI handlers that would no longer be regulated. The range of potential
savings under the CSI alternative is estimated to be from $1,504,00037 to $3,402,000,38 with a best
37 Assumes a six year monitor life, an average monitor weight of 35 pounds, and 75 percent of
discarded monitors are color.
38 Assumes a 3.5 year monitor life, an average monitor weight of 41 pounds, and 89 percent of
discarded monitors are color.
August 24, 2001 - DRAFT
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estimate of $3,098,000.39 Exhibit 4-9 summarizes the costs under the baseline and the CSI alternative
by cost category.
Exhibit 4-9: Costs of CSI Alternative Relative to Subtitle C Baseline
Cost Category
Administrative
Disposal
Transportation
Storage
Total
Baseline
$ 1,888,000
$ 16,373,000
$5,431,000
$ 650,000
$ 24,342,000
Primary Alternative
$ 826,000
$ 15,356,000
$ 3,667,000
$ 1,395,000
$ 21,244,000
Saving (Cost)
$ 1,062,000
$ 1,017,000
$ 1,764,000
$ (745,000)
$ 3,098,000
Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.
4.3.3 Sensitivity Analysis for the CSI Alternative
Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle
C baseline and the CSI alternative for the following four parameters: monitor weight, monitor lifetime,
storage costs, and percent of monitors that are color. Appendix G lists the parameters to which the
analysis results are relatively insensitive. The individual sensitivity analysis is conducted by changing one
parameter at a time while holding all other parameters at their best estimate value. Exhibit 4-10
contains the upper and lower bounds and the best estimate values for the four parameters as well as the
percent change of the lower and upper bounds from the best estimate. The upper and lower bounds
were selected because they represent probable limits on the selected parameters. Exhibit 4-11
contains the model results for each individual change. Exhibit 4-12 plots the data in Exhibit 4-11 from
the individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most
sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. The
graph also indicates that the model results are not linearly related with respect to percent color, monitor
weight, and monitor life, since the lines for these parameters are not straight. To determine a potential
maximum upper bound on the savings, a combined sensitivity analysis is conducted using a monitor
weight of 35 pounds, a monitor lifetime of 2 years, the percent of color monitors discarded of 99
percent, and storage cost of zero per square foot. The savings under the combined sensitivity analysis
is $4,221,000.
39 Assumes a 3.5 year monitor life, an average monitor weight of 35 pounds, and 90 percent of
discarded monitors are color.
August 24, 2001 - DRAFT
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Exhibit 4-10: Parameter Values for Individual Sensitivity Analysis
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower
Bound
30 Ibs.
2 years
$0
60%
% Change
from Best
Estimate
-14 %
-43 %
-100 %
-33 %
Best Estimate
35 Ibs.
3. 5 years
$8.30
90%
Upper Bound
40 Ibs.
5 years
$ 15
99%
% Change
from Best
Estimate
14%
43%
81%
10%
Exhibit 4-11: Individual Sensitivity Analysis Results
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower Bound
$ 2,677,000
$2,735,000
$ 3,843,000
$ 2,343,000
Best Estimate
$ 3,098,000
$ 3,098,000
$ 3,098,000
$ 3,098,000
Upper Bound
$ 3,365,000
$ 2,386,000
$2,496,000
$3,157,000
Numbers rounded to nearest thousand.
Sensitivity analysis is also conducted for disposal costs above and below the best estimate
values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for
whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a
best estimate of $160), the savings ranged from $3,336,000 to $2,580,000. By changing the cost for
disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to
$100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton
for crushed CRTs (from abest estimate of $152), the savings ranged from $3,171,000 to $3,050,000.
By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of
$271), the savings ranged from $3,139,000 to $3,008,000. The sensitivity analysis on disposal costs
shows that the model is moderately sensitive to hazardous waste disposal costs and only slightly
sensitive to the reclaimer and collector disposal costs.
August 24, 2001 - DRAFT
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Exhibit 4-12: Plot of Individual Sensitivity Analysis Results for the CSI Alternative
$4,000,000
OS
CQ
o
&B
a
OS
O
U
O
H
Monitor Weight
Monitor Life
Storage Cost
Percent Color
$2,200,000
-150% -100% -50% 0% 50%
Percent Change from Best Estimate
100%
Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or
uncertainty) in the given parameters.
4.3.4 Incremental Cost Difference Between the Subtitle C Baseline and the CSI Alternative,
Including Currently Unregulated Monitors and Televisions
To help understand how the two regulatory alternatives might be affected by capacity issues,
the total cost of compliance under the Subtitle C baseline and the CSI alternative is also calculated
including CRTs from households and CESQGs. It is assumed that 20 million unregulated television
CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from
August 24, 2001 - DRAFT
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households and CESQGs.40 Exhibit 4-13 contains a summary of the costs under the baseline and the
CSI alternative by cost category.
Exhibit 4-13: Costs of CSI Alternative Relative to Subtitle C Baseline, Including Unregulated
Monitors and Televisions
Cost Category
Administrative
Disposal
Transportation
Storage
Total
Baseline
$ 1,984,000
$ 20,854,000
$ 6,790,000
$ 650,000
$ 30,278,000
CSI Alternative
$ 855,000
$ 18,834,000
$ 4,988,000
$ 1,395,000
$ 26,072,000
Saving (Cost)
$ 1,129,000
$ 2,020,000
$ 1,802,000
$ (745,000)
$ 4,206,000
The analysis estimates that 32,000 tons of CRT glass is sent to glass processors and that, of
this, 31,300 tons of CRT glass is sent to CRT glass manufacturers. These quantities are below the
capacity limits for glass processors and CRT glass manufacturers. As the CRT recycling infrastructure
grows and additional unregulated CRTs are recycled, the capacities of both glass processors and glass
manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.
5.0 Cost Results and Sensitivity Analysis for Subtitle D Management Baseline
The incremental annual savings attributable to both the primary alternative and the CSI
alternative are calculated by subtracting the estimated costs under each alternative from the estimated
costs under the Subtitle D baseline.
5.1 Costs Under the Subtitle D Baseline
The total applicable cost of the Subtitle D management baseline is calculated for several groups
of entities. As shown in Exhibit 5-1, the analysis groups affected entities based on whether they are
original users or collectors, the amount of waste they generate (SQGs or LQGs), and, for original
users, whether they are regulated solely because of CRT generation or because of a combination of
CRT and non-CRT hazardous waste generation. Collectors are all assumed to be regulated solely
40 The number of televisions disposed of is based on the assumption that there are 100 million
households each with two televisions and that the TVs are discarded after ten years. The 20
million TVs discarded is also consistent with the number of televisions sold in 1991, which was
19.5 million. The number of computer monitor CRTs disposed of is based on data from the
US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households
have computers.
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because of CRT generation. Compliance costs also are calculated for glass processors. Exhibit 5-1
presents the cost per establishment for administrative, storage, transportation, and disposal, and for the
total cost of compliance under the baseline. Administrative costs are assumed to be the same for all
generators in each size category (small or large). The other costs vary across the categories (based on
RCRA requirements for different types of generators, on the average number of CRTs discarded, and
on the disposal method used by that generator). So Exhibit 5-1 presents the average cost for each
group of generators. As discussed in Section 3.11, generators sending CRTs to Subtitle D landfills only
incur a disposal cost.
Exhibit 5-1: Subtitle D Baseline Compliance Costs
Average Costs per Generator
Admin.
Storag
e
Original Users (Generating
SQG
LQG
$663
$ 1,327
Subtota
1
$ 1,304
$3,314
Transp
Disposal
Except
Subtitle D
Subtitle
D
Disposal
Number
of
Regulate
d
Generator
s
Average Costs per
Potentially Regulated
Generator
Disposal
Transp. Except
Subtitle D
Subtitle
D
Disposal
Number
of
Potentiall
y
Regulate
d
Generator
s
Total Cost
No Non-CRT Hazardous Waste)
$120
$682
$1,139
$ 8,681
$485
$ 3,696
170
5
$120 $1,139
$ 682 $ 8,681
$485
$ 3,696
2,260
66
$4,571,000
$ 950,000
$5,521,000
Original Users Also Generating Non-CRT Hazardous Waste
SQG
LQG
$87
$325
Subtota
1
$386
$134
$73
$182
$768
$792
$143
$148
43
18
$ 73 $ 768
$182 $792
$143
$148
384
160
$441,000
$ 208,000
$ 649,000
Collectors
SQG
LQG
$647
$ 1,290
Subtota
1
$0
$0
$234
$630
$95
$166
$50
$94
10
85
$ 234 $ 95
$ 630 $ 166
$50
$94
90
415
$ 44,000
$ 554,000
$ 598,000
Glass Processors
$ 1,284
$0
$ 1,542
$ (16,405)
N/A
5
N/A N/A
Total Baseline Compliance Costs
N/A
N/A
$ (68,000)
$ 6,700,000
Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.
5.2 Primary Alternative
5.2.1 Costs Under the Primary Alternative
August 24, 2001 - DRAFT
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The total applicable cost of compliance under the primary alternative is calculated for all of the
entities described in Section 5.1, and for all of the entities that were formerly generators but that no
longer are required to comply with the hazardous waste regulations. These are called "former
generators." Exhibit 5-2 presents the cost per establishment for administrative, storage, transportation,
and disposal, and for the total cost of compliance under the primary alternative. Administrative costs
are assumed to be the same for all generators in each size category (small or large). The other costs
vary across the categories (based on RCRA requirements for different types of generators, on the
average number of CRTs discarded, and on the disposal method used by that generator). So Exhibit
5-2 presents the average cost for each group of generators. As discussed in section 3.11, generators
sending CRTs to Subtitle D landfills only incur a disposal cost.
The average transportation and disposal cost for SQGs and LQGs changes between the
baseline and the primary alternative because, in the baseline, six CRT management options (collector,
reuse, processor, smelter, hazardous waste landfill, and municipal landfill) are available while in the
primary alternative only one disposal option (hazardous waste landfill) is available for regulated
generators and five of the CRT management options are available (collector, reuse, processor, smelter,
hazardous waste landfill, and municipal landfill) for former generators. The reason for the changes in
average collector costs is similar. Under the baseline, six CRT management options are available
(reuse, processor, smelter, hazardous waste landfill, municipal landfill, and export). Under the primary
alternative, the same six CRT management options are available for regulated collectors, while former
generators have five CRT management options (reuse, municipal landfill, processor, smelter, and
export).
August 24, 2001 - DRAFT Page 64
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Exhibit 5-2: Primary Alternative Compliance Costs Under the Subtitle D Baseline
Average
Admin.
Storag
e
Costs per Generator
Trans
P-
Disposal
Except
Subtitle D
Original Users (Generating No Non-CRT Hazardous
Former SQG
Former LQG
$0
$0
Subtotal
$ 1,304
$ 3,295
$119
$654
$993
$ 7,527
Subtitle
D
Dispos
al
Number
of
Regulate
d
Generator
s
Average Costs per
Potentially Regulated
Generator
Disposal
Transp
Except
Subtitle D
Waste)
$455
$ 3,445
121
4
$119 $993
$ 654 $ 7,527
Subtitle D
Disposal
Number
of
Potentiall
y
Regulate
d
Generator
s
Total Cost
$455
$ 3,445
2,260
66
$ 3,888,000
$ 827,000
$4,715,000
Original Users Also Generating Non-CRT Hazardous Waste
Former SQG
Former LQG
$0
$0
Subtotal
$772
$798
$47
$48
$294
$304
$134
$139
34
14
$ 47 $ 294
$ 48 $ 304
$134
$139
384
160
$ 225,000
$ 97,000
$ 322,000
Collectors
Former SQG
Former LQG
$0
$0
Subtotal
$0
$0
$94
$120
$ 199
$255
$62
$137
8
75
$94 $199
$120 $255
Total Cost to Regulated Generators
Total Compliance Costs under the Primary Alternative
$62
$137
90
415
$ 35,000
$251,000
$ 286,000
$ 1,484,000
$ 6,806,000
Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.
5.2.2 Incremental Cost Difference Between the Subtitle D Baseline and the Primary
Alternative
The primary alternative generates a net savings relative to the baseline, due primarily to reduced
administrative requirements and savings from reduced transportation and disposal costs. Savings from
the primary alternative accrue to former generators that would no longer be regulated. The range of
potential savings under the primary alternative is estimated to be from a net cost of 1,301,00041 to a net
41 Assumes a two year monitor life, an average monitor weight of 40 pounds, and 95 percent
of discarded monitors are color.
August 24, 2001 - DRAFT
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savings of $291,000,42 with a best estimate of a cost of $106,000.43 Exhibit 5-3 summarizes the costs
under the baseline and the primary alternative by cost category.
Exhibit 5-3: Costs of Primary Alternative Relative to Subtitle D Baseline
Cost Category
Administrative
Disposal Except Subtitle D
Subtitle D Disposal
Transportation
Storage
Total
Baseline
$251,000
$ 3,863,000
$ 1,580,000
$ 749,000
$ 257,000
$ 6,700,000
Primary Alternative
$ 56,000
$ 4,485,000
$ 1,479,000
$ 507,000
$ 279,000
$ 6,806,000
Saving (Cost)
$ 195,000
$ (622,000)
$ 101,000
$ (242,000)
$ 22,000
$ 106,000
Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.
5.2.3 Sensitivity Analysis for the Primary Alternative
Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle
D baseline and the primary alternative for the following four parameters: monitor weight, monitor
lifetime, storage costs, and percent of monitors that are color. The individual sensitivity analysis is
conducted by changing one parameter at a time while holding all other parameters at their best estimate
value. Exhibit 5-4 contains the upper and lower bounds and the best estimate values for the four
parameters as well as the percent change of the lower and upper bounds from the best estimate. The
upper and lower bounds were selected because they represent probable limits on the selected
parameters. Exhibit 5-5 contains the model results for each individual change. Exhibit 5-6 plots the
data in Exhibit 5-5 from the individual sensitivity analysis for the four parameters. The graph illustrates
that the analysis is most sensitive to the monitor weight, monitor lifetime, and the percent of color
monitors discarded. To determine a potential maximum upper bound on the savings, a combined
sensitivity analysis is conducted using a monitor weight of 30 pounds, a monitor lifetime of 6 years, the
percent of color monitors discarded of 85 percent, and storage cost of zero dollars per square foot.
The savings under the combined sensitivity analysis is $349,000.
42 Assumes a six year monitor life, an average monitor weight of 30 pounds, and 75 percent of
discarded monitors are color.
43 Assumes a three and one half year monitor life, an average monitor weight of 35 pounds,
and 90 percent of discarded monitors are color.
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Exhibit 5-4: Parameter Values for Individual Sensitivity Analysis
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower
Bound
30 Ibs.
2 years
$0
60%
% Change
from Best
Estimate
-14 %
-43 %
-100 %
-33 %
Best Estimate
35 Ibs.
3. 5 years
$8.30
90%
Upper Bound
40 Ibs.
5 years
$ 15
99%
% Change
from Best
Estimate
14%
43%
81%
10%
Exhibit 5-5: Individual Sensitivity Analysis Results
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower Bound
$ 17,000
$ (916,000)
$ (84,000)
$ 120,000
Best Estimate
$ (106,000)
$ (106,000)
$ (106,000)
$ (106,000)
Upper Bound
$ (247,000)
$ 93,000
$ (123,000)
$ (191,000)
Note: Cost numbers rounded to nearest thousand.
Sensitivity analysis is also conducted for disposal costs above and below the best estimate
values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for
whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a
best estimate of $160), the savings ranged from $ (61,000) to $(259,000). By changing the cost for
disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to
$100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton
for crushed CRTs (from a best estimate of $152), the savings ranged from $(330,000) to $54,000. By
changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of $271),
the savings ranged from $(236,000) to $176,000. The sensitivity analysis on disposal costs shows that
the model is moderately sensitive to hazardous waste, reclaimer, and collector disposal costs.
August 24, 2001 - DRAFT
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Exhibit 5-6: Plot of Individual Sensitivity Analysis Results for the Primary Alternative
4*
pa
o
f/3
O
u
"eS
•M
o
H
•Monitor Weight
•Monitor Life
• Storage Cost
•Percent Color
-150%
1 - 1 ($950,000)
-100% -50% 0%
50%
100%
Percent Change from Best Estimate
5.2.4
Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or
uncertainty) in the given parameters.
Incremental Cost Difference Between the Subtitle D Baseline and the Primary
Alternative, Including Currently Unregulated Monitors and Televisions
To help understand how the two regulatory alternatives might be affected by capacity issues,
the total cost of compliance under the Subtitle D baseline and the primary alternative is also calculated
including CRTs from households and CESQGs. It is assumed that 20 million unregulated television
CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from
households and CESQGs.44 Exhibit 5-7 contains a summary of the costs under the baseline and the
44 The number of televisions disposed of is based on the assumption that there are 100 million
households each with two televisions and that the TVs are discarded after ten years. The 20
August 24, 2001 - DRAFT
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primary alternative by cost category. Transportation and disposal costs are higher under the primary
alternative than the baseline because it is assumed that a greater percentage of unregulated CRTs are
sent to collectors, which increases the number of CRTs that have a non-zero disposal cost under the
primary alternative.
Exhibit 5-7: Costs of Primary Alternative Relative to Subtitle D Baseline Including
Unregulated Monitors and Televisions
Cost Category
Administrative
Disposal Except Subtitle D
Subtitle D Disposal
Transportation
Storage
Total
Baseline
$ 269,000
$6,155,000
$ 3,007,000
$ 1,063,000
$ 257,000
$ 10,751,000
Primary Alternative
$ 56,000
$ 6,677,000
$ 2,789,000
$ 1,213,000
$ 279,000
$ 11,014,000
Saving (Cost)
$213,000
$ (522,000)
$218,000
$(150,000)
$ (22,000)
$ (263,000)
Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.
The analysis estimates that 9,600 tons of CRT glass is sent to glass processors and that, of this,
8,800 tons of CRT glass is sent to CRT glass manufacturers. These quantities are below the capacity
limits for glass processors and CRT glass manufacturers. As the CRT recycling infrastructure grows
and additional unregulated CRTs are recycled, the capacities of both glass processors and glass
manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.
5.3 CSI Alternative
5.3.1 Costs Under the CSI Alternative
The total applicable cost of compliance under the CSI alternative is calculated for all of the
entities described in Section 5.1, and for all of the entities that were formerly generators but that no
longer are required to comply with the hazardous waste regulations. These are called CSI handlers.
Exhibit 5-8 presents the cost per establishment for administrative, storage, transportation, and disposal,
and for the total cost of compliance under the CSI alternative. Administrative costs are assumed to be
the same for all CSI handlers in each size category (small or large). The other costs vary across the
million TVs discarded is also consistent with the number of televisions sold in 1991, which was
19.5 million. The number of computer monitor CRTs disposed of is based on data from the
US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households
have computers.
August 24, 2001 - DRAFT
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categories (based on RCRA requirements for different types of generators, on the average number of
CRTs discarded, and on the CRT management method used by that generator). So Exhibit 5-8
presents the average cost for CSI handlers. As discussed in section 3.11, generators sending CRTs to
Subtitle D landfills only incur a disposal cost.
The average transportation and disposal cost for SQGs and LQGs changes between the
baseline and the CSI alternative because, in the baseline, six CRT management options (collector,
reuse, processor, smelter, hazardous waste landfill, and municipal landfill) are available while in the CSI
alternative only three CRT management options (lead smelter, hazardous waste landfill, and municipal
landfill) are available for regulated generators, and four of the CRT management options are available
(collector, reuse, processor, and municipal landfill) for CSI handlers.
Exhibit 5-8: CSI Alternative Compliance Costs Under the Subtitle D Baseline
Average Costs per Generator
Admin
CSI Handlers
SQH
LQH
$100
$0
Subtotal
Total Cost to
Storage
$883
$0
Transp.
$114
$0
Disposal
Except
Subtitle
D
Subtitle
D
Disposal
Number
of
Regulated
Generator
Average Costs per Potentially
Regulated Generator
Transp.
$ 900 $ 480
$0 $0
200
0
$114
$0
Disposal
Except
Subtitle D
$900
$0
Regulated Generators
Total Compliance Costs under the CSI Alternative
Subtitle
D
Disposal
Number of
Potentially
Regulated
Generators
Total Cost
$480
$0
2,439
0
$4,138,OOC
$C
$4,138,OOC
$ 2,996,OOC
$7,134,OOC
Note: Total cost numbers rounded to nearest thousand. Costs may not add due to rounding.
5.3.2 Incremental Cost Difference Between the Subtitle D Baseline and the CSI Alternative
The CSI alternative generates a net savings relative to the baseline, due primarily to reduced
administrative requirements and savings from reduced transportation and disposal costs. Savings from
the CSI alternative accrue to CSI handlers that would no longer be regulated. The range of potential
savings under the CSI alternative is estimated to be from a net cost of $1,521,00045 to a net cost of
45 Assumes a two year monitor life, an average monitor weight of 40 pounds, and 95 percent
of discarded monitors are color.
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$33,000,46 with a best estimate of a net cost of $434,000.47 Exhibit 5-9 summarizes the costs under
the baseline and the CSI alternative by cost category.
Exhibit 5-9: Costs of CSI Alternative Relative to Subtitle D Baseline
Cost Category
Administrative
Disposal Except Subtitle D
Subtitle D Disposal
Transportation
Storage
Total
Baseline
$251,000
$3,863,000
$ 1,580,000
$ 749,000
$ 257,000
$ 6,700,000
Primary Alternative
$ 129,000
$ 4,435,000
$ 1,500,000
$ 875,000
$ 195,000
$7,134,000
Saving (Cost)
$ 122,000
$ (572,000)
$ 80,000
$ (126,000)
$ 62,000
$ (434,000)
Note: Cost numbers rounded to nearest thousand. Costs may not add due to rounding.
5.3.3 Sensitivity Analysis for the CSI Alternative
Individual sensitivity and bounding analysis is conducted on the difference between the Subtitle
D baseline and the CSI alternative for the following four parameters: monitor weight, monitor lifetime,
storage costs, and percent of monitors that are color. The individual sensitivity analysis is conducted by
changing one parameter at a time while holding all other parameters at their best estimate value. Exhibit
5-10 contains the upper and lower bounds and the best estimate values for the four parameters as well
as the percent change of the lower and upper bounds from the best estimate. The upper and lower
bounds were selected because they represent probable limits on the selected parameters. Exhibit 5-11
contains the model results for each individual change. Exhibit 5-12 plots the data in Exhibit 5-11 from
the individual sensitivity analysis for the four parameters. The graph illustrates that the analysis is most
sensitive to the monitor weight, monitor lifetime, and the percent of color monitors discarded. To
determine a potential maximum upper bound on the savings, a combined sensitivity analysis is
conducted using a monitor weight of 26 pounds, a monitor lifetime of 5.5 years, the percent of color
monitors discarded of 75 percent, and storage cost of $15 per square foot. The savings under the
combined sensitivity analysis is $5,000.
46 Assumes a six year monitor life, an average monitor weight of 30 pounds, and 86 percent of
discarded monitors are color.
47 Assumes a three and one half year monitor life, an average monitor weight of 35 pounds,
and 90 percent of discarded monitors are color.
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Exhibit 5-10: Parameter Values for Individual Sensitivity Analysis
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower
Bound
30 Ibs.
2 years
$0
60%
% Change
from Best
Estimate
-14 %
-43 %
-100 %
-33 %
Best Estimate
35 Ibs.
3. 5 years
$8.30
90%
Upper Bound
40 Ibs.
5 years
$ 15
99%
% Change
from Best
Estimate
14%
43%
81%
10%
Exhibit 5-11: Individual Sensitivity Analysis Results
Monitor Weight
Monitor Life
Storage Cost
Percent Color
Lower Bound
$(315,000)
$(1,153,000)
$ (496,000)
$ (223,000)
Best Estimate
$ (434,000)
$ (434,000)
$ (434,000)
$ (434,000)
Upper Bound
$ (568,000)
$ (259,000)
$ (383,000)
$ (509,000)
Numbers rounded to nearest thousand.
Sensitivity analysis is also conducted for disposal costs above and below the best estimate
values. By changing the cost for disposal to a hazardous waste landfill to $800 and $1700 per ton for
whole CRTs (from a best estimate of $1,500), and to $50 and $250 per ton for crushed CRTs (from a
best estimate of $160), the savings ranged from $( 417,000) to $(499,000). By changing the cost for
disposal to a reclaimer to $150 and $500 per ton for whole CRTs (from a best estimate of $295), to
$100 and $300 per ton for bare CRTs (from a best estimate of $207), and to $75 and $250 per ton
for crushed CRTs (from a best estimate of $152), the savings ranged from $(349,000) to $(493,000).
By changing the cost for disposal to a collector to $100 and $350 per ton (from a best estimate of
$271), the savings ranged from $(577,000) to $(255,000).
August 24, 2001 - DRAFT
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Exhibit 5-12: Plot of Individual Sensitivity Analysis Results for the CSI Alternative
4*
"3
pa
o
VI
O
U
"eS
•M
o
H
Monitor Weight
Monitor Life
Storage Cost
-150% -100% -50% 0% 50%
Percent Change from Best Estimate
100%
5.3.4
Note: Lines with relatively steeper slopes indicate greater sensitivity of the results to changes (or
uncertainty) in the given parameters.
Incremental Cost Difference Between the Subtitle D Baseline and the CSI
Alternative, Including Currently Unregulated Monitors and Televisions
To help understand how the two regulatory alternatives might be affected by capacity issues,
the total cost of compliance under the Subtitle D baseline and the CSI alternative is also calculated
including CRTs from households and CESQGs. It is assumed that 20 million unregulated television
CRTs are disposed and 16.7 million unregulated computer monitor CRTs are disposed from
August 24, 2001 - DRAFT
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households and CESQGs.48 Exhibit 5-13 summarizes the costs under the baseline and the CSI
alternative by cost category.
Exhibit 5-13: Costs of CSI Alternative Relative to Subtitle D Baseline, Including Unregulated
Monitors and Televisions
Cost Category
Administrative
Disposal Except Subtitle D
Subtitle D Disposal
Transportation
Storage
Total
Baseline
$ 269,000
$6,155,000
$ 3,007,000
$ 1,063,000
$ 257,000
$ 10,751,000
Primary Alternative
$ 136,000
$ 6,934,000
$ 2,745,000
$ 1,224,000
$ 195,000
$ 11,234,000
Saving (Cost)
$ 133,000
$ (779,000)
$ 262,000
$(161,000)
$ 62,000
$ (483,000)
The analysis estimates that 9,600 tons of CRT glass is sent to glass processors and that, of this,
9,400 tons of CRT glass is sent to CRT glass manufacturers. These quantities are below the capacity
limits for glass processors and CRT glass manufacturers. As the CRT recycling infrastructure grows
and additional unregulated CRTs are recycled, the capacities of both glass processors and glass
manufacturers will be exceeded. This analysis does not attempt to predict when this might occur.
6.0 Economic Impacts
This section presents the estimated first-order economic impacts associated with the
incremental cost savings from the primary and CSI alternatives over the Subtitle C management
baseline using the cost to sales ratio. As noted in Section 3.10, the impacts analysis is likely to
overstate economic impacts (whether costs or savings) because the sales data used in the analysis
represent average values for each SIC code as a whole, whereas the estimated compliance costs arise
only for the entities that are large enough to be considered an SQG or LQG in the baseline. Such
entities are likely to have an average sales value higher than the average for the industry as a whole.
48 The number of televisions disposed of is based on the assumption that there are 100 million
households each with two televisions and that the TVs are discarded after ten years. The 20
million TVs discarded is also consistent with the number of televisions sold in 1991, which was
19.5 million. The number of computer monitor CRTs disposed of is based on data from the
US Census, Survey of Computer Use, 1997, which estimates that 52 percent of households
have computers.
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Primary Alternative
Exhibit 6-1 shows the impacts of the cost savings for original users that were baseline small
quantity generators (SQGs). Their average savings is $606 per year, due primarily to reduced
administrative requirements and transportation savings. The highest impact on SQGs is on the
"Personal Services" sector (SIC code 72). Establishments in SIC code 72 have average annual sales
of $219,582. The incremental cost savings represents 0.28 percent of the average annual sales.
Establishments in all but one other SIC code have impacts of less than 0.17 percent of the average
annual sales.
Exhibit 6-2 presents the results for original users that were baseline large quantity generators
(LQGs). Their average savings is $1,101 per year, due to reduced administrative requirements, and
transportation and disposal costs. The LQGs under the baseline are in 25 SIC codes. The highest
impact for LQHs is on the Retail Trade Administrative and Auxiliary category. The maximum
incremental cost savings represents 0.30 percent of the average annual sales. Establishments in all other
SIC codes have impacts of less than 0.23 percent of the average annual sales.
Exhibit 6-1: Estimated Impact of Savings Under the Primary Alternative
on Former SQGs that were Baseline SQGs
Industry
SIC
Code
Average Sales per
Establishment
Number of
Baseline
Potential SQGs
Savings (Cost) Impact of
Primary Alternative
MINING
Metal Mining
Coal Mining
Oil & Gas Extraction
STon-metallic minerals, except fuels
Administrative & Auxiliary
10
12
13
14
1
$9,642,717
$8,841,349
$5,338,313
$2,338,749
$1,545,768
24
21
52
5
37
CONSTRUCTION
General contractors
Heavy construction
Special trade contractors
15
16
17
$1,280,404
$2,570,507
$590,600
8
24
5
MANUFACTURING
Food & kindred products
Tobacco products
Textile mill products
Apparel & other textile products
Lumber & wood products
Furniture & Fixtures
Paper & allied products
20
21
22
23
24
25
26
$19,567,362
$308,752,632
$12,020,557
$3,103,014
$2,277,901
$3,759,298
$20,760,708
178
10
56
9
3
30
208
0.01%
0.01%
0.01%
0.03%
0.04%
0.05%
0.02%
0.10%
0.00%
0.00%
0.01%
0.02%
0.03%
0.02%
0.00%
August 24, 2001 - DRAFT
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Industry
Printing & publishing
Chemicals & allied products
Petroleum and Coal Products
Rubber & miscellaneous plastics products
Leather & leather products
Stone, clay, and glass products
Primary metal industries
Fabricated metal products
Industrial machinery & equipment
Electronic & other electronic equipment
Transportation equipment
Instrument & related products
Miscellaneous manufacturing
Administrative & Auxiliary
SIC
Code
27
28
29
30
31
32
33
34
35
36
37
38
39
1
Average Sales per
Establishment
$2,540,878
$25,443,194
$70,728,296
$7,170,357
$4,751,863
$3,846,475
$21,271,651
$4,571,413
$4,793,932
$12,809,615
$35,374,262
$11,884,834
$2,318,656
$3,156,356
Number of
Baseline
Potential SQGs
328
297
44
225
5
22
72
62
483
578
459
121
19
212
TRANSPORTATION
Local & Interurban passenger transit
Trucking & Warehousing
Water transportation
Transportation by Air
Pipelines, except natural gases
Communication
Electronic, gas, & sanitary services
Administrative & Auxiliary
41
42
44
45
46
48
49
1
$ 710,436
$1,296,519
$3,585,027
$2,338,134
$8,368,550
$5,877,769
$15,510,062
$1,766,775
7
98
16
78
1
303
255
43
WHOLESALE
Wholesale trade-durable goods
Wholesale trade-nondurable goods
Bldg. Materials & garden supplies
Administrative & Auxiliary
50
51
52
1
$5,084,711
$9,036,867
$1,422,393
$781,548
168
213
1
98
RETAIL TRADE
General merchandise store
Food stores
Auto dealers & service station
Apparel & accessory stores
Furniture & home furnishing stores
Eating & drinking places
Miscellaneous retail
Administrative & Auxiliary
53
54
55
56
57
58
59
1
$7,089,224
$2,044,651
$4,100,193
$699,117
$846,766
$450,446
$607,995
$370,918
28
2
1
4
2
6
31
96
Savings (Cost) Impact of
Primary Alternative
0.02%
0.00%
0.00%
0.01%
0.01%
0.02%
0.00%
0.01%
0.01%
0.00%
0.00%
0.01%
0.03%
0.02%
0.09%
0.05%
0.02%
0.03%
0.01%
0.01%
0.00%
0.03%
0.01%
0.01%
0.04%
0.08%
0.01%
0.03%
0.01%
0.09%
0.07%
0.13%
0.10%
0.16%
August 24, 2001 - DRAFT
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Industry
SIC
Code
Average Sales per
Establishment
Number of
Baseline
Potential SQGs
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
STondepository Institution
Security & commodity brokers
Insurance carriers
Insurance agents, brokers, & servicers
Real Estate
Holding & other investment offices
Administrative & Auxiliary
60
61
62
63
64
65
67
1
$5,091,211
$3,432,819
$3,491,738
$20,422,940
$424,989
$617,331
$3,237,932
$1,054,687
339
87
86
482
27
74
37
23
SERVICES
Personal services
Business services
Auto repair, services, and parking
Misc. repair services
Motion picture
Amusement & recreation services
Health services
Legal services
Educational services
Social services
Museums, botanical, zoological gardens
Membership organization
Engineering & management service
Services, n.e.c
Administrative & Auxiliary
72
73
75
76
78
79
80
81
82
83
84
86
87
89
1
$219,582
$896,726
$407,237
$429,359
$1,040,439
$793,715
$677,073
$641,030
$491,509
$225,786
$611,305
$500,857
$827,956
$546,119
$1,053,680
6
1,432
1
2
15
69
3,177
52
580
18
3
83
365
8
134
Savings (Cost) Impact of
Primary Alternative
0.01%
0.02%
0.02%
0.00%
0.14%
0.10%
0.02%
0.06%
0.28%
0.07%
0.15%
0.14%
0.06%
0.08%
0.09%
0.09%
0.12%
0.27%
0.10%
0.12%
0.07%
0.11%
0.06%
Exhibit 6-2: Estimated Impact of Savings Under the Primary Alternative
on Former LQGs that were Baseline LQGs
Industry
SIC Code
Average Sales per
Establishment
Number of
Baseline
Potential LQGs
Savings (Cost) Impact
of Primary Alternative
MANUFACTURING
Food and kindred products
Tobacco products
Chemicals & allied products
Primary metal industries
20
21
28
33
$19,567,362
$308,752,632
$25,443,194
$21,271,651
3
1
4
5
0.01%
0.00%
0.01%
0.01%
August 24, 2001 - DRAFT
Page 77
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Industry
Industrial machinery & equipment
Electronic & other electronic equipment
Transportation equipment
SIC Code
35
36
37
Average Sales per
Establishment
$4,793,932
$12,809,615
$35,374,262
Number of
Baseline
Potential LQGs
7
12
51
TRANSPORTATION
Local & Interurban passenger transit
Trucking & Warehousing
Transportation by Air
Communication
Electronic, gas, & sanitary services
Administrative & Auxiliary
41
42
45
48
49
1
$710,436
$1,296,519
$2,338,134
$5,877,769
$15,510,062
$1,766,775
1
12
20
11
4
5
WHOLESALE
Administrative & Auxiliary
1
$781,548
1
RETAIL TRADE
Food stores
Administrative & Auxiliary
54
1
$2,044,651
$370,918
1
1
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
STondepository institution
Security and commodity brokers
Insurance carriers
Holding and other investment offices
60
61
62
63
67
$5,091,211
$3,432,819
$3,491,738
$20,422,940
$3,237,932
18
5
5
14
3
Savings (Cost) Impact
of Primary Alternative
0.02%
0.01%
0.00%
0.16%
0.08%
0.05%
0.02%
0.01%
0.06%
0.14%
0.05%
0.30%
0.02%
0.03%
0.03%
0.01%
0.03%
SERVICES
Business services
Motion picture
Amusement & recreation services
Health services
Educational services
Membership organization
Engineering & management service
Administrative & Auxiliary
73
78
79
80
82
86
87
1
$896,726
$1,040,439
$793,715
$677,073
$491,509
$500,857
$827,956
$1,053,680
22
5
3
65
33
6
31
7
0.12%
0.11%
0.14%
0.16%
0.22%
0.22%
0.13%
0.10%
CSIA her native
Exhibit 6-3 shows the impacts of the cost savings for small quantity handlers (SQHs) that were
baseline small quantity generators (SQGs). Their average savings is $498 per year, due primarily to
reduced administrative requirements and transportation savings. The highest impact on SQGs is on the
August 24, 2001 - DRAFT
Page 78
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"Personal Services" sector (SIC code 72). Establishments in SIC code 72 have average annual sales
of $219,582. The incremental cost savings represents 0.23 percent of the average annual sales.
Establishments in all but one other SIC codes have impacts of less than 0.14 percent of the average
annual sales.
Exhibit 6-4 presents the results for the small quantity handlers (SQHs) that were baseline large
quantity generators (LQGs). Their average savings is $8,017 per year, due primarily to reduced
administrative requirements and disposal costs. Fifteen percent of the LQGs under the baseline are
assumed to continue following RCRA regulations because they send their waste to destinations other
than glass processors. These establishments realize no cost savings under the CSI alternative. The
former LQGs are regulated as SQHs under the CSI alternative, and are the main beneficiaries of the
regulatory burden reduction.
The model estimates that no large quantity handlers will exist under the CSI alternative. Thus,
the baseline large quantity generators that become SQHs by sending discarded CRTs to processors
under the CSI alternative realize the most cost savings. The LQGs under the baseline are in 25 SIC
codes. The highest impact for LQHs is on the Retail Trade Administrative and Auxiliary category. The
maximum incremental cost savings represents 2.16 percent of the average annual sales. Establishments
in all other SIC codes have impacts of less than 1.64 percent of the average annual sales.
Exhibit 6-3: Estimated Impact of Savings Under the CSI Alternative
on Small Quantity Handlers that were Baseline SQGs
Industry
SIC
Code
Average Sales per
Establishment
Number of
Baseline
Potential SQGs
Savings (Cost) Impact of
Primary Alternative
MINING
Metal Mining
Coal Mining
Oil & Gas Extraction
STon-metallic minerals, except fuels
Administrative & Auxiliary
10
12
13
14
1
$9,642,717
$8,841,349
$5,338,313
$2,338,749
$1,545,768
24
21
52
5
37
CONSTRUCTION
General contractors
Heavy construction
Special trade contractors
15
16
17
$1,280,404
$2,570,507
$590,600
8
24
5
MANUFACTURING
Food & kindred products
Tobacco products
Textile mill products
Apparel & other textile products
Lumber & wood products
20
21
22
23
24
$19,567,362
$308,752,632
$12,020,557
$3,103,014
$2,277,901
178
10
56
9
3
0.01%
0.01%
0.01%
0.02%
0.03%
0.04%
0.02%
0.08%
0.00%
0.00%
0.00%
0.02%
0.02%
August 24, 2001 - DRAFT
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Industry
Furniture & Fixtures
Paper & allied products
Printing & publishing
Chemicals & allied products
Petroleum and Coal Products
Rubber & miscellaneous plastics products
Leather & leather products
Stone, clay, and glass products
Primary metal industries
Fabricated metal products
Industrial machinery & equipment
Electronic & other electronic equipment
Transportation equipment
Instrument & related products
Miscellaneous manufacturing
Administrative & Auxiliary
SIC
Code
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
1
Average Sales per
Establishment
$3,759,298
$20,760,708
$2,540,878
$25,443,194
$70,728,296
$7,170,357
$4,751,863
$3,846,475
$21,271,651
$4,571,413
$4,793,932
$12,809,615
$35,374,262
$11,884,834
$2,318,656
$3,156,356
Number of
Baseline
Potential SQGs
30
208
328
297
44
225
5
22
72
62
483
578
459
121
19
212
TRANSPORTATION
Local & Interurban passenger transit
Trucking & Warehousing
Water transportation
Transportation by Air
Pipelines, except natural gases
Communication
Electronic, gas, & sanitary services
Administrative & Auxiliary
41
42
44
45
46
48
49
1
$ 710,436
$1,296,519
$3,585,027
$2,338,134
$8,368,550
$5,877,769
$15,510,062
$1,766,775
7
98
16
78
1
303
255
43
WHOLESALE
Wholesale trade-durable goods
Wholesale trade-nondurable goods
Bldg. Materials & garden supplies
Administrative & Auxiliary
50
51
52
1
$5,084,711
$9,036,867
$1,422,393
$781,548
168
213
1
98
RETAIL TRADE
General merchandise store
Food stores
Auto dealers & service station
Apparel & accessory stores
Furniture & home furnishing stores
Eating & drinking places
53
54
55
56
57
58
$7,089,224
$2,044,651
$4,100,193
$699,117
$846,766
$450,446
28
2
1
4
2
6
Savings (Cost) Impact of
Primary Alternative
0.01%
0.00%
0.02%
0.00%
0.00%
0.01%
0.01%
0.01%
0.00%
0.01%
0.01%
0.00%
0.00%
0.00%
0.02%
0.02%
0.07%
0.04%
0.01%
0.02%
0.01%
0.01%
0.00%
0.03%
0.01%
0.01%
0.04%
0.06%
0.01%
0.02%
0.01%
0.07%
0.06%
0.11%
August 24, 2001 - DRAFT
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Industry
Miscellaneous retail
Administrative & Auxiliary
SIC
Code
59
1
Average Sales per
Establishment
$607,995
$370,918
Number of
Baseline
Potential SQGs
31
96
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
STondepository Institution
Security & commodity brokers
Insurance carriers
Insurance agents, brokers, & servicers
Real Estate
Holding & other investment offices
Administrative & Auxiliary
60
61
62
63
64
65
67
1
$5,091,211
$3,432,819
$3,491,738
$20,422,940
$424,989
$617,331
$3,237,932
$1,054,687
339
87
86
482
27
74
37
23
SERVICES
Personal services
Business services
Auto repair, services, and parking
Misc. repair services
Motion picture
Amusement & recreation services
Health services
Legal services
Educational services
Social services
Museums, botanical, zoological gardens
Membership organization
Engineering & management service
Services, n.e.c
Administrative & Auxiliary
72
73
75
76
78
79
80
81
82
83
84
86
87
89
1
$219,582
$896,726
$407,237
$429,359
$1,040,439
$793,715
$677,073
$641,030
$491,509
$225,786
$611,305
$500,857
$827,956
$546,119
$1,053,680
6
1,432
1
2
15
69
3,177
52
580
18
3
83
365
8
134
Savings (Cost) Impact of
Primary Alternative
0.08%
0.13%
0.01%
0.01%
0.01%
0.00%
0.12%
0.08%
0.02%
0.05%
0.23%
0.06%
0.12%
0.12%
0.05%
0.06%
0.07%
0.08%
0.10%
0.22%
0.08%
0.10%
0.06%
0.09%
0.05%
Exhibit 6-4: Estimated Impact of Savings Under the CSI Alternative
on Small Quantity Handlers that were Baseline LQGs
Industry
SIC Code
Average Sales per
Establishment
Number of
Baseline
Potential LQGs
Savings (Cost) Impact
of Primary Alternative
MANUFACTURING
Food and kindred products
Tobacco products
20
21
$19,567,362
$308,752,632
3
1
0.04%
0.00%
August 24, 2001 - DRAFT
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Industry
Chemicals & allied products
Primary metal industries
Industrial machinery & equipment
Electronic & other electronic equipment
Transportation equipment
SIC Code
28
33
35
36
37
Average Sales per
Establishment
$25,443,194
$21,271,651
$4,793,932
$12,809,615
$35,374,262
Number of
Baseline
Potential LQGs
4
5
7
12
51
TRANSPORTATION
Local & Interurban passenger transit
Trucking & Warehousing
Transportation by Air
Communication
Electronic, gas, & sanitary services
Administrative & Auxiliary
41
42
45
48
49
1
$710,436
$1,296,519
$2,338,134
$5,877,769
$15,510,062
$1,766,775
1
12
20
11
4
5
WHOLESALE
Administrative & Auxiliary
1
$781,548
1
RETAIL TRADE
Food stores
Administrative & Auxiliary
54
1
$2,044,651
$370,918
1
1
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
STondepository institution
Security and commodity brokers
Insurance carriers
Holding and other investment offices
60
61
62
63
67
$5,091,211
$3,432,819
$3,491,738
$20,422,940
$3,237,932
18
5
5
14
3
Savings (Cost) Impact
of Primary Alternative
0.03%
0.04%
0.17%
0.06%
0.02%
1.13%
0.62%
0.34%
0.14%
0.05%
0.45%
1.03%
0.39%
2.16%
0.16%
0.23%
0.23%
0.04%
0.25%
SERVICES
Business services
Motion picture
Amusement & recreation services
Health services
Educational services
Membership organization
Engineering & management service
Administrative & Auxiliary
73
78
79
80
82
86
87
1
$896,726
$1,040,439
$793,715
$677,073
$491,509
$500,857
$827,956
$1,053,680
22
5
3
65
33
6
31
7
0.89%
0.77%
1.01%
1.18%
1.63%
1.60%
0.97%
0.76%
* The only LQGs under the CSI Alternative are those required to follow RCRA regulations because they send their
waste to destinations other than Glass-to-Glass recyclers. Eighty-five percent of the Baseline LQGs are regulated as
SQHs under the proposed rule, the others remain RCRA LQGs and therefore realize no cost savings.
7.0 Qualitative Environmental Benefits
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The shift of waste CRTs from landfills and incinerators to glass processors, and thus to CRT
glass manufacturers, has four major potential qualitative environmental benefits. The four potential
qualitative benefits are (1) increase in the availability of landfill space; (2) increase in resource efficiency;
(3) increase in recycling by non-regulated entities; and (4) reduction of lead emissions from incinerators.
This section discusses these four qualitative environmental benefits.
Landfill Capacity
A qualitative benefit of both alternatives is the shift of CRTs from Subtitle C and D landfills to
CRT glass processors. The analysis estimates that approximately 2,600 tons or 456,000 cubic feet of
CRTs will be redirected away from landfills each year under the primary alternative. This additional
space can be used for other waste. By not disposing of CRTs in Subtitle C and D landfills, the landfill
capacity will not be reached as quickly and new landfills will not be needed as soon. This unused
Subtitle C and D landfill capacity is seen as a minor qualitative benefit, because so few regulated CRTs
currently are being sent to these landfills.
Increase in Resource Efficiency
The resources that could be used more efficiently under the two regulatory alternatives include
energy, CRT glass, raw materials for glass manufacturing, and landfill space. The amount of energy
required to turn discarded televisions and computer monitors into an input for CRT glass manufacturers
may be less than the energy required to mine, process, and transport the raw materials for glass making.
Discarded CRTs are a direct replacement for raw materials to glass manufacturing, thus reserving those
raw materials for future use.
Recycling by Non-Regulated Entities
The alternatives are designed to stimulate an increase in glass-to-glass CRT recycling in certain
effected entities (i.e., firms that disposition a sufficient number of CRTs that they could potentially
qualify as SQGs or LQGs). If the initiative is successful, the glass-to-glass recycling industry may
develop and expand its operations. As CRT recycling infrastructure develops, it will become a more
attractive option for smaller entities and for the general public. Thus, some additional entities may shift
the management of their waste from Subtitle D landfills to glass recycling. This shift has the benefit of
saving additional landfill space, and provides for more environmentally sound disposal of unregulated
CRTs. The increased recycling infrastructure is already proving itself to be a valuable incentive for
increased non-regulated CRT recycling in states such as Massachusetts and Minnesota.
Reduction of Lead Emissions
Exposure to lead may result in health problems to adults and children. These effects include
hypertension, stroke, cancer in adults and decreased IQ and gestational age, reduced birth weight, and
other neurological effects in infants and children. By shifting disposal of CRTs from municipal waste
incinerators, the total lead emitted from CRT incineration can be reduced. However, the benefits of
August 24, 2001 - DRAFT Page 83
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reducing lead emissions from CRT incineration are reported to be small.49 One report estimates that
the value of the health effects due to a complete ban on incineration of any CRTs is on the order of $5
million.50
8.0 Other Administrative Requirements
This section describes the Agency's response to other rulemaking requirements established by
statute and executive order, within the context of the proposed rule for CRTs.
8.1 Environmental Justice
The EPA is committed to addressing environmental justice concerns and is assuming a
leadership role in environmental justice initiatives to enhance environmental quality for all residents of the
United States. The Agency's goals are to ensure that no segment of the population, regardless of race,
color, national origin, or income bears disproportionately high and adverse human health and
environmental impacts as a result of the EPA's policies, programs, and activities, and that all people live
in clean and sustainable communities. In response to Executive Order 12898 and to concerns voiced
by many groups outside the Agency, the EPA's Office of Solid Waste and Emergency Response
formed an Environmental Justice Task Force to analyze the array of environmental justice issues
specific to waste programs and to develop an overall strategy to identify and address these issues
(OSWER Directive No. 9200.3-17).
Because CRTs are ubiquitous, it is not certain whether the environmental problems addressed
by the proposed rule could disproportionately affect minority or low income communities. CRTs are
used throughout the country and many are located within highly populated areas. Because the
proposed rule establishes general environmental performance requirements to minimizes breakage, and
helps prevent the release of glass particulates, the Agency does not believe that this rule will increase
risks from CRT wastes. Moreover, the CSI alternative establishes an environmental justice procedure
for new CRT processors. The procedure calls for new processors to advise the local community
through notice and possibly public meeting regarding the nature of the activities conducted, including the
potential for residential or worker exposure to lead or chemical coatings. It is, therefore, not expected
to result in any disproportionately negative impacts on minority or low income communities relative to
affluent or non-minority communities.
49 Macauley et al., 2001, page 51.
50 Macauley et al., 2001, page 45.
August 24, 2001 - DRAFT Page 84
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8.2 Unfunded Mandates Reform Act
Under Section 202 of the Unfunded Mandates Reform Act of 1995, signed into law on March
22, 1995, the EPA must prepare a statement to accompany any rule for which the estimated costs to
state, local, or tribal governments in the aggregate, or to the private sector, will be $100 million or more
in any one year. Under Section 205, the EPA must select the most cost-effective and least
burdensome alternative that achieves the objective of the rule and is consistent with statutory
requirements. Section 203 requires the EPA to establish a plan for informing and advising any small
governments that may be significantly affected by the rule.
An analysis of the costs and benefits of the proposed rule was conducted and it was determined
that this rule does not include a federal mandate that may result in estimated costs of $100 million or
more to either state, local, or tribal governments in the aggregate. The private sector also is not
expected to incur costs exceeding $100 million per year in this EA.
8.3 Protection of Children from Environmental Health Risks and Safety Risks
Executive Order 13045, entitled "Protection of Children from Environmental Health Risks and
Safety Risks" requires all economically significant rules51 that concern an environmental health risk or
safety risk that may disproportionately affect children to comply with requirements of the Executive
Order. Because the EPA does not consider the proposed rule to be economically significant, it is not
subject to Executive Order 13045. Because this rulemaking establishes general environmental
performance requirements, minimizes breakage, and prevents of release of glass particulates, the EPA
believes that the proposed rule will not result in increased exposures to children. For these reasons, the
environmental health risks or safety risks addressed by this action do not have a disproportionate effect
on children.
8.4 Regulatory Flexibility
The Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory
Enforcement and Fairness Act, 5 U.S.C. §§ 601-612, generally requires an agency to conduct a
regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements unless
the agency certifies that the rule will not have a significant economic impact on a substantial number of
small entities. Small entities include small businesses, small not-for-profit enterprises, and small
governmental jurisdictions. This proposed rule does not have a significant impact on a substantial
number of small entities because today's proposed rule relieves regulatory burden for CRT handlers
through reduced regulatory requirements. In addition, the Agency estimates that this proposed rule
An economically significant rule is defined by Executive Order 12866 as any rulemaking that has an
annual effect on the economy of $100 million or more, or adversely affects in a material way the economy, a
sector of the economy, productivity, competition, jobs, the environment, public health, or safety, or State,
local, or tribal governments or communities.
August 24, 2001 - DRAFT Page 85
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leads to an overall cost savings in the range of $4 to 5 million annually. Accordingly, EPA believes that
the rule will not have a significant economic impact on a substantial number of small entities.
9.0 Discussion of Findings and Summary
The main conclusion of this analysis is that both the overall savings and the savings for individual
establishments are small, and that the results are sensitive to a few key parameters (CRT life in
businesses, the average weight of CRTs, storage costs, and the percent of color monitors discarded).
A second conclusion is that both the glass processing and CRT glass manufacturer capacities are
adequate to handle all regulated CRTs. However, if a new rule induces significantly more unregulated
CRTs to be recycled than is modeled in this analysis, then both the glass processing and CRT glass
manufacturer capacities may become inadequate to handle this larger volume of CRT glass.
The primary alternative, as modeled in this analysis, is expected to impact approximately 2,900
establishments in 66 different two-digit SIC codes. Under the Subtitle C baseline the proposed rule
will lead to total savings of approximately $4,840,000 for current generators that elect not to send their
discarded CRTs for disposal. These savings are due primarily to reduced administrative, disposal, and
transportation costs. Under the Subtitle D baseline the proposed rule will lead to a total savings of
approximately $106,000, due to reduced administrative and transportation costs.
The CSI alternative, as modeled in this analysis, is expected to impact approximately 2,500
establishments in 66 different two-digit SIC codes. Under the Subtitle C baseline the proposed rule
will lead to total savings of approximately $3,098,000 for current generators that elect not to send their
discarded CRTs for disposal. These savings are due primarily to reduced administrative, disposal, and
transportation costs. Under the Subtitle D baseline the proposed rule will lead to a total savings of
approximately $434,000, due to reduced administrative and transportation costs.
Relative to the Subtitle C baseline, the economic impacts on the entities in the regulated
community are expected to be negligible because the rule provides savings for all entities managing
CRTs. A significant benefit of the proposed rule is the possible increase in glass-to-glass recycling by
the non-regulated community.
August 24, 2001 - DRAFT Page 86
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Appendices
Appendix A: Number of Establishments and the Number of Employees for all Two-Digit SIC Codes
Appendix B: Ratios of Computers per Employee Calculated for Each SIC Code
Appendix C: Disposal Cost Source Details
Appendix D: Flow of CRTs in Both Number and Tons
Appendix E: Average Shipment Sizes for Each Type of Establishment Distributing CRTs to Each
CRT Management Option
Appendix F: Revenues per Establishment for All Two-Digit SIC Codes
Appendix G: List of Parameters to Which the Analysis Results are Relatively Insensitive
Appendix H: Telephone Contacts
Appendix I: Bibliography
August 24, 2001 - DRAFT Page 87
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Appendix A
Total Employees, Establishments, and Number of Establishments by Number of Employees,
and by 2-Digit SIC Code
Industry
SIC
code
Total
Employees
Total
Est.
Number of Establishments per Employee Size Range
250 to
499
500 to
999
1,000 to
1,499
1,500 to
2,499
2,500 to
4,999
5,000 or
more
AGRICULTURE
Agricultural services
Forestry
Fishing, hunting, trapping
Administrative & Auxiliary
7
8
9
-
595,842
20,488
11,871
0
103,543
2,512
2,236
62
51
4
5
2
18
1
0
0
4
1
1
1
MINING
Metal Mining
Coal Mining
Oil & Gas Extraction
Non-metallic minerals,
except fuels
Administrative & Auxiliary
10
12
13
14
-
48,105
104,204
295,990
99,182
80,002
921
2,294
17,513
5,572
1,056
20
82
87
18
48
16
21
37
3
29
5
10
2
6
3
5
1
1
CONSTRUCTION
General contractors
Heavy construction
Special trade contractors
Administrative & Auxiliary
15
16
17
-
1,222,061
707,811
3,091,307
17,660
190,316
34,168
409,114
402
141
174
325
11
49
60
66
3
10
13
9
5
11
5
2
8
1
5
MANUFACTURING
Food & kindred products
Tobacco products
Textile mill products
Apparel & other textile
products
Lumber & wood products
Furniture & Fixtures
Paper & allied products
Printing & publishing
Chemicals & allied products
Petroleum and coal
sroducts
Rubber & miscellaneous
plastics products
Leather & leather products
Stone, clay, and glass
sroducts
Primary metal industries
Fabricated metal products
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
1,525,070
30,411
624,005
910,919
730,144
505,956
634,737
1,505,794
826,839
111,369
1,001,010
95,151
491,795
684,703
1,450,089
21,285
112
6,452
24,216
37,601
11,611
6,552
64,690
12,328
2,042
16,611
1,957
16,214
6,768
36,314
872
16
492
513
254
291
305
531
352
53
526
68
190
365
606
408
4
200
186
50
113
153
200
190
26
169
23
75
165
192
118
1
38
19
9
16
40
78
58
12
26
3
16
34
34
50
5
11
7
1
9
15
37
35
6
26
2
6
21
18
10
7
2
3
4
13
14
4
17
10
3
1
1
4
5
August 24, 2001 - DRAFT
Page A-1
-------
Industry
Industrial machinery &
equipment
Electronic & other
electronic equipment
Transportation equipment
Instrument & related
sroducts
Miscellaneous
manufacturing
Administrative & Auxiliary
SIC
code
35
36
37
38
39
-
Total
Employees
1,883,431
1,503,923
1,543,731
832,706
394,287
1,326,527
Total
Est.
55,476
17,058
11,256
11,378
17,899
12,105
Number of Establishments per Employee Size Range
250 to
499
686
775
463
361
153
560
500 to
999
338
373
255
177
57
315
1,000 to
1,499
74
101
75
55
11
104
1,500 to
2,499
46
67
62
33
7
64
2,500 to
4,999
25
37
67
23
1
32
5,000 or
more
7
12
51
10
12
TRANSPORTATION & PUBLIC UTILITIES
Local & Interurban
passenger transit
Trucking & Warehousing
Water transportation
Transportation by Air
Pipelines, except natural
gases
Transportation services
Communication
Electronic, gas, & sanitary
services
Administrative & Auxiliary
41
42
44
45
46
47
48
49
-
403,025
1,808,949
164,920
715,137
16,395
391,340
1,340,061
908,820
175,605
18,900
124,190
8,707
12,076
1,091
50,172
44,713
22,455
2,682
101
306
45
150
4
50
563
340
57
22
150
31
78
0
17
224
152
30
4
30
13
32
1
51
57
6
2
12
2
27
28
35
3
1
56
1
19
7
11
4
1
12
20
4
4
5
WHOLESALE
Wholesale trade-durable
goods
Wholesale trade-
nondurable goods
Administrative & Auxiliary
50
51
_
3,683,301
2,582,397
340,488
327,640
184,384
5,713
488
550
177
135
146
69
19
39
15
13
15
11
1
13
3
1
RETAIL TRADE
Bldg. Materials & garden
supplies
General merchandise store
Food stores
Auto dealers & service
station
Apparel & accessory stores
Furniture & home
furnishing stores
Eating & drinking places
Miscellaneous retail
Administrative & Auxiliary
52
53
54
55
56
57
58
59
_
739,615
2,290,572
3,188,462
2,189,767
1,147,856
859,460
7,208,158
2,610,918
849.766
64,436
36,216
181,870
199,791
135,270
116,727
456,732
360,787
16.055
35
1,541
452
79
37
36
209
110
433
1
217
51
5
44
5
46
53
254
14
2
4
2
4
16
65
13
2
8
19
1
1
7
12
1
1
August 24, 2001 - DRAFT
Page A-2
-------
Industry
SIC
code
Total
Employees
Total
Est.
Number of Establishments per Employee Size Range
250 to
499
500 to
999
1,000 to
1,499
1,500 to
2,499
2,500 to
4,999
5,000 or
more
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
STondepository Institution
Security & commodity
arokers
Insurance carriers
Insurance agents, brokers,
& servicers
Real Estate
Holding & other investment
offices
Administrative & Auxiliary
60
61
62
63
64
65
67
-
2,079,264
489,804
522,895
1,502,920
676,602
1,402,828
255,044
68,799
104,666
45,408
40,961
41,330
125,361
246,119
23,202
1,452
491
136
115
594
70
212
71
50
223
62
63
287
20
64
27
18
68
15
14
93
2
8
5
3
48
10
9
80
5
1
5
2
13
5
5
22
1
3
5
14
SERVICES
Hotels & other lodging
places
Personal services
Business services
Auto repair, services, &
parking
Misc. repair services
Motion picture
Amusement & recreation
services
Health services
Legal services
Educational services
Social services
Museums, botanical,
zoological gardens
Membership organization
Engineering & management
service
Service
Administrative & Auxiliary
Unclassified
70
72
73
75
76
78
79
80
81
82
83
84
86
87
89
_
-
1,575,077
1,281,898
6,824,962
990,658
456,425
511,651
1,324,194
10,851,331
960,693
2,066,531
2,263,314
76,079
2,151,350
2,795,304
100,472
477,226
105,336
54,130
202,349
352,658
181,336
73,562
42,946
93,500
478,286
163,554
46,224
155,846
3,790
243,592
269,243
14,877
9,639
68,916
669
156
2,651
62
33
40
242
2,528
167
521
475
40
274
673
14
221
1
261
12
1,031
18
5
17
107
1,525
49
323
97
7
61
255
6
92
66
3
217
1
5
42
731
2
140
12
1
15
50
1
31
35
2
123
2
5
19
611
1
80
6
1
7
60
1
11
30
1
61
5
8
310
37
1
3
21
4
4
22
5
3
65
33
3
10
3
Note: (D) Data withheld to avoid disclosing data for individual companies: data included in broader industry totals.
Source: US Bureau of Census, County Business Patterns 1995.
August 24, 2001 - DRAFT
Page A-3
-------
Appendix B
Computer Use By Employees
SIC Category
All industries
Agriculture services
Other agriculture
Mining
Construction
Lumber and wood
Furniture
Stone, clay
Primary metals
Fabricated metals
Machinery, excluding electric
Electrical machinery
Motor vehicles
Aircraft and parts
Other transportation
Professional photo equipment
Toys, sporting goods
Miscellaneous manufacturing
Food and kindred products
Tobacco manufacturing
Textile mill products
Apparel & other finished goods
Paper and allied products
Printing, publishing
Chemicals and allied products
Petroleum, coal
Rubber and plastics
Leather and leather products
Transportation
Communications
Utilities & sanitary
Wholesale trade
Retail trade
Banking and finance
Insurance & real estate
Private household services
Business services
Number of Survey
Respondents
Employed
118,400
968
2006
689
7,567
841
665
568
653
1,290
2,238
1,689
1,120
502
624
680
128
437
1,776
52
664
970
740
1,705
1,220
145
791
107
5,410
1,637
1,501
4,531
18,706
3,417
4,561
1,099
5,038
Respondents Using a
Computer at Work
51,106
160
219
307
1,182
114
161
165
217
442
1,233
950
428
335
376
406
44
100
532
25
177
143
339
857
729
88
293
24
1,866
1,283
807
2,226
5,837
2,888
3,094
16
2,646
Computer Use per
Employee in 1993
0.43
0.17
0.11
0.45
0.16
0.14
0.24
0.29
0.33
0.34
0.55
0.56
0.38
0.67
0.60
0.60
0.34
0.23
0.30
0.48
0.27
0.15
0.46
0.50
0.60
0.61
0.37
0.22
0.34
0.78
0.54
0.49
0.31
0.85
0.68
0.01
0.53
Estimated Computer
Use per Employee in
2001
0.56
0.24
0.16
0.46
0.25
0.17
0.30
0.36
0.42
0.43
0.69
0.70
0.48
0.84
0.75
0.75
0.43
0.29
0.37
0.60
0.33
0.18
0.57
0.63
0.75
0.76
0.46
0.28
0.42
0.96
0.66
0.66
0.42
0.99
0.79
0.02
0.75
August 24, 2001 - DRAFT
PageB-1
-------
SIC Category
Repair services
Personal services
Entertainment, recreation
Hospitals
Health services, excluding
lospitals
Education services
Social services
Other professional
Forestry, fisheries
Justice, public order
Administration human resource
STational security
Other public administration
Number of Survey
Respondents
Employed
1,915
3,220
1,735
5,182
5,377
9,845
2,721
5,578
166
2,179
834
802
2,112
Respondents Using a
Computer at Work
382
662
538
3,105
1,963
5,066
753
3,735
56
1,324
632
597
1,584
Computer Use per
Employee in 1993
0.20
0.21
0.31
0.60
0.37
0.51
0.28
0.67
0.34
0.61
0.76
0.74
0.75
Estimated Computer
Use per Employee in
2001
0.28
0.29
0.44
0.85
0.52
0.73
0.39
0.95
0.48
0.69
0.86
0.85
0.85
Sources: 1993 Census Data, Table 7WK Uses of Computers at work, by Sex and Intermediate Industry, in "Computer Use in the United States: October
1993." and Table D Use of Computers at Work by People 18 Years and Older by Gender: October 1997, "Computer Use in the United States: October
1997."
August 24, 2001 - DRAFT
Page B-2
-------
Appendix C
Disposal Cost Source Details
Disposal Option
Source
Source Cost
per Ton
Year of cost
estimate
Cost (Price
Paid) per Ton
(2001$)
Collectors
1
2
3
4
Average
$240
$400
$0
$383
$250
1998
2001
2001
1997
1998
$271
Export
4
$ 100
1999
$ 107
Reuse
None
$0
2001
$0
Treatment and Subtitle C or D Landfill Disposal
Whole CRTs
5
6
7
Value used in analysis
Crushed CRTs
7
8
9
Value used in analysis
$ 1,196
$1,300
$ 1,500
$ 1,500
$ 160
$ 100
$ 125
$ 160
1998
2001
2001
2001
2001
2000
2000
2001
$ 1,500
$ 160
Subtitle D Landfill Disposal
8
$40
2000
$41
Reclaimer
4
8
8
10
$667
$200
$420
$200
1997
2000
2000
1998
August 24, 2001 - DRAFT
Page C-l
-------
Disposal Option
Source
10
11
12
12
13
13
14
Whole CRTs - Average
Whole bare CRTs - Average
Crushed CRTs - Average
Source Cost
per Ton
$350
$ 140
$200
$500
$200
$300
$200
$284
$200
$ 140
Year of cost
estimate
1998
1998
1997
1997
1997
1997
1998
2000
2000
1998
Cost (Price
Paid) per Ton
(2001$)
$295
$207
$ 152
Glass Processor
Broken CRTs with no metal
Broken CRTs with metal
Whole bare CRTs
Broken mixed color and
monochrome CRTs
Whole CRTs
15,16
$0
$ 100
$ 192
$325
$333
2001
2001
2001
2001
2001
$0
$ 100
$ 192
$325
$333
CRT Glass Manufacturer
15
($ 175)
2001
($ 175)
August 24, 2001 - DRAFT
Page C-2
-------
Source
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Source Title
DMC Recycling Inc, 1998.
F&M Bay Electronics Co. Inc./SEER Inc., 2001.
WasteNot Recycling, 2001.
U.S. Environmental Protection Agency, Region 1. Analysis of Five Community
Consumer/Residential Collections, End-of-Life Electronic and Electrical
Equipment. EPA-901-R-98-003, April 1999.
Personal communications with Chem Waste Management, 1998.
Personal communications with Clean Harbors of Braintree, 2001.
Personal communications with Envirosafe Services of Ohio, 2001.
U.S. Environmental Protection Agency, Office of Solid Waste, Economics, Methods
and Risk Analysis Division. Unit Cost Compendium . September 30, 2000.
ETC's landfill cost survey, 2000.
Personal communications with Noranda, 1998.
Personal communications with Doe Run, 1998.
Aanstoos, T., Mizuki, C., Nichols, S., and Pitts, G. CRT Disposition: An Assessment
of Limitations and Opportunities in Reuses, Refurbishment, and Recycling in the
U.S.. IEEE International Symposium on Electronics & the Environment 1997
Cutter Information Corp.'s "Product Stewardship Advisor" Vol. I, No. 4, 1997.
National Safety Council, Electronic Product Recovery and Recycling Baseline
Report, Recycling of Selected Electronic Products in the United States. May
1999.
Personal communications with Greg Voorhees of Envirocycle, 2001.
Price list from Envirocycle, 2001.
August 24, 2001 - DRAFT
Page C-3
-------
Appendix D
Flow of CRTs under Subtitle C (Number)
Total Number
of CRTs
To Collector
To Reuse
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
To Glass
Processor
To Exporter
To CRT
Manufacturer
Baseline
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
2,036,512
105,753
453,584
45,517
1,547,749
79,315
344,724
34,138
40,730
9,072
40,730
26,438
9,072
11,379
305,477
68,038
101,826
22,679
Collectors
SQGs
LQGs
167,160
1,838,765
33,432
367,753
3,343
183,877
38,447
183,877
41,790
551,630
50,148
551,630
Glass Processor
Funnel glass
Panel glass
All CRTs
245,826
472,098
2,005,925
450,987
0
274,839
4,917
9,442
610,196
717,924
601,778
240,910
462,656
703,566
Primary Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
Former SQG - CRT
only
Former SQG - all
HW
40,727
2,129
8,919
920
1,995,785
103,624
1,556,712
80,827
39,916
2,072
40,727
2,129
8,919
920
299,368
15,544
99,789
5,181
August 24, 2001 - DRAFT
PageD-1
-------
Former LQG - CRT
only
Former LQG - all
HW
Total Number
of CRTs
444,665
44,597
To Collector
346,839
34,786
To Reuse
8,893
892
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
66,700
6,690
To Glass
Processor
22,233
2,230
To Exporter
To CRT
Manufacturer
Collectors
SQGs
LQGs
Former SQG
Former LQG
3,365
37,018
164,898
1,813,882
673
7,404
32,980
362,776
67
740
774
5,553
41,225
308,360
841
16,658
41,225
816,247
1,010
6,663
49,470
326,499
Glass Processor
Funnel glass
Panel glass
All CRTs
343,921
660,484
2,019,164
455,606
0
53,502
6,878
13,210
764,300
1,004,405
383,641
337,042
647,274
984,317
CSI Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
305,535
15,843
67,528
6,845
45,830
2,376
10,129
1,027
259,705
13,467
57,399
5,819
Collectors
SQGs
LQGs
164,678
1,811,462
32,936
362,292
3,294
36,229
37,876
235,490
41,170
815,158
49,404
362,292
Glass Processor
Funnel glass
Panel glass
370,110
710,779
7,402
14,216
362,708
696,563
CSI Handlers
CSI SQHs
2,245,614
1,976,140
44,912
224,561
August 24, 2001 - DRAFT
Page D-2
-------
CSQ LQHs
All CRTs
Total Number
of CRTs
To Collector
1,976,140
To Reuse
440,140
ToMSW
Landfill
(Subtitle D)
0
ToHW
Landfill
(Subtitle C)
98,886
To Reclaimer
631,373
To Glass
Processor
1,080,889
To Exporter
411,696
To CRT
Manufacturer
1,059,271
Flow of CRTs under Subtitle C (Tons)
Baseline
Total Tons of
CRTs
To Collector
To Reuse
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
To Glass
Processor
To Exporter
To CRT
Manufacturer
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
35,639
1,851
7,938
797
27,086
1,388
6,033
597
713
159
713
463
159
199
5,346
1,191
1,782
397
Collectors
SQGs
LQGs
2,925
32,178
585
6,436
35
1,931
404
1,931
439
5,792
878
9,654
Glass Processor
Funnel glass
Panel glass
All CRTs
2,581
4,957
35,104
7,892
3,499
52
99
9,022
7,538
10,531
2,530
4,858
7,387
Primary Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
713
37
156
16
713
37
156
16
August 24, 2001 - DRAFT
Page D-3
-------
Former SQG - CRT
only
Former SQG - all
HW
Former LQG - CRT
only
Former LQG - all
HW
Total Tons of
CRTs
34,926
1,813
7,782
780
To Collector
27,242
1,414
6,070
609
To Reuse
699
36
156
16
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
5,239
272
1,167
117
To Glass
Processor
1,746
91
389
39
To Exporter
To CRT
Manufacturer
Collectors
SQHs
LQHs
Former SQH
Former LQH
59
648
2,886
31,743
12
130
577
6,349
1
8
8
58
433
3,238
9
175
433
8,571
18
117
866
5,714
Glass Processor
Funnel glass
Panel glass
All CRTs
3,611
6,935
35,335
7,973
931
72
139
10,743
10,546
6,714
3,539
6,796
10,335
CSI Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
5,347
Til
1,182
120
802
42
177
18
4,545
236
1,004
102
Collectors
SQHs
LQHs
2,882
31,701
576
6,340
35
380
398
2,473
432
8,559
865
6,340
Glass Processor
August 24, 2001 - DRAFT
Page D-4
-------
Funnel glass
Panel glass
Total Tons of
CRTs
3,886
7,463
To Collector
To Reuse
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
78
149
To Glass
Processor
To Exporter
To CRT
Manufacturer
3,808
7,314
CSI Handlers
CSI SQHs
CSQ LQHs
All CRTs
39,298
34,582
34,582
786
7,702
0
1,454
8,984
3,930
11,349
7,205
11,122
Bolded entries include the weight of the CRT glass only. Non-bolded entries include the weight of the entire monitor.
August 24, 2001 - DRAFT
Page D-5
-------
Flow of CRTs under Subtitle D (Number)
Total Number of
CRTs
To Collector
To Reuse
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
To Glass
Processor
To Exporter
To CRT
Manufacturer
Baseline
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
2,036,512
105,753
453,584
45,517
122,191
10,575
27,215
4,552
40,730
9,072
1,629,210
84,602
362,867
36,414
40,730
10,575
9,072
4,552
101,826
22,679
101,826
22,679
Collectors
SQGs
LQGs
13,711
150,822
2,742
30,164
6,856
64,853
3,016
686
7,541
686
15,082
2,742
30,164
Glass Processor
Funnel glass
Panel glass
All CRTs
48,031
92,241
164,533
82,708
2,184,802
67,945
961
1,845
135,537
140,273
32,907
47,070
90,397
137,467
Primary Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
Former SQG -
CRT only
Former SQG -HW
Former LQG-CRT
only
40,727
2,129
8,919
920
1,995,785
103,624
444,665
199,579
10,362
44,467
39,916
2,072
8,893
1,496,839
77,718
333,499
40,727
2,129
8,919
920
139,705
7,254
31,127
119,747
6,217
26,680
August 24, 2001 - DRAFT
Page D-6
-------
Former LQG -HW
Total Number of
CRTs
44,597
To Collector
4,460
To Reuse
892
ToMSW
Landfill
(Subtitle D)
33,448
ToHW
Landfill
(Subtitle C)
To Reclaimer
3,122
To Glass
Processor
2,676
To Exporter
To CRT
Manufacturer
Collectors
SQGs
LQGs
Former SQG
Former LQG
431
4,746
21,141
232,549
86
949
4,228
46,510
173
1,898
8,456
93,020
9
95
56
380
3,171
23,255
43
712
2,114
34,882
65
712
3,171
34,882
Glass Processor
Funnel glass
Panel glass
All CRTs
66,110
126,962
39,031
17,564
405,924
9,793
1,322
2,539
29,046
30,086
5,855
64,788
124,422
29,485
CSIAlternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
305,535
15,843
67,528
6,845
183,321
9,506
40,517
4,107
45,830
2,376
10,129
1,027
76,384
3,961
16,882
1,711
Collectors
SQGs
LQGs
18,713
205,848
3,743
41,170
7,111
78,222
374
4,117
1,871
10,292
1,871
30,877
3,743
41,170
Glass Processor
Funnel glass
Panel glass
88,106
169,204
1,762
3,384
86,344
165,820
CSI Handlers
CSI SQHs
CSI LQHs
All CRTs
2,245,614
224,561
258,867
44,912
103,547
1,751,579
2,045,051
52,798
211,930
224,561
193,072
38,830
189,210
August 24, 2001 - DRAFT
Page D-7
-------
Flow of CRTs under Subtitle D (Tons)
Total Tons of
CRTs
To Collector
To Reuse
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
To Glass
Processor
To Exporter
To CRT
Manufacturer
Baseline
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
35,639
1,851
7,938
797
2,138
185
476
80
713
159
28,511
1,481
6,350
637
713
185
159
80
1,782
397
1,782
397
Collectors
SQGs
LQGs
240
2,639
48
528
120
1,135
0
32
7
79
7
158
48
528
Glass Processor
Funnel glass
Panel glass
All CRTs
504
969
2,879
1,447
38,234
1,168
10
19
2,295
1,473
576
494
949
1,443
Primary Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
Former SQG -
CRT only
Former SQG -
HW
Former LQG-
CRT only
Former LQG -
HW
713
37
156
16
34,926
1,813
7,782
780
3,493
181
778
78
699
36
156
16
26,195
1,360
5,836
585
713
37
156
16
2,445
127
545
55
2,096
109
467
47
August 24, 2001 - DRAFT
Page D-8
-------
Total Tons of
CRTs
To Collector
To Reuse
ToMSW
Landfill
(Subtitle D)
ToHW
Landfill
(Subtitle C)
To Reclaimer
To Glass
Processor
To Exporter
To CRT
Manufacturer
Collectors
SQHs
LQHs
Former SQH
Former LQH
8
83
370
4,070
2
17
74
814
3
33
148
1,628
0
1
1
4
33
244
0
7
22
366
1
12
55
610
Glass Processor
Funnel glass
Panel glass
All CRTs
694
1,333
4,530
1,812
35,788
923
14
27
3,494
2,027
680
680
1,306
1,987
CSI Alternative
Original User
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
5,347
111
1,182
120
3,208
166
709
72
802
42
177
18
1,337
69
295
30
Collectors
SQGs
LQGs
327
3,602
65
720
124
1,369
4
43
20
108
20
324
65
720
Glass Processor
Funnel glass
Panel glass
925
1,777
19
36
907
1,741
CSI Handlers
CSI SQHs
CSI LQHs
All CRTs
39,298
3,930
3,930
786
1,572
30,653
36,301
1,086
1,913
3,930
2,702
786
2,648
Bolded entries include the weight of the CRT glass only. Non-bolded entries include the weight of the entire monitor.
August 24, 2001 - DRAFT
Page D-9
-------
Appendix E
Average Shipment Sizes for Each Type of Establishment Distributing CRTs to Each CRT
Management Option
Baseline - Subtitle C
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
To
Collector
1.4
0.4
5.2
0.2
SQHs
LQHs
To
Reuse
1.4
_
5.1
_
11.8
13.0
ToHW
(Subtitle C)
1.4
0.4
5.1
0.2
7.1
8.1
Glass Processor - Funnel
Glass Processor - Panel
Primary Alternative - Subtitle C
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
_
_
_
_
SQHs
LQHs
_
_
_
_
9.5
13.1
1.4
0.4
5.2
0.2
0.6
6.3
Glass Processor - Funnel
Glass Processor - Panel
Former SQG - CRT only
PA
Former SQG - HW PA
Former LQG - CRT only
PA
Former LQG - HW PA
2.8
0.8
20.7
0.8
Former SQH
Former LQH
2.8
0.8
19.8
0.7
"
"
11.6
21.9
CSI Alternative - Subtitle C
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
-
_
_
_
SQHs
LQHs
-
_
_
_
11.6
12.8
1.4
0.4
_
0.6
7.0
7.9
Glass Processor - Funnel
Glass Processor - Panel
CSI SQHs
CSI LQHs
-
-
-
-
-
-
To Reclaimer
1.4
_
5.2
_
7.4
8.1
9.3
13.4
_
_
_
_
6.6
7.8
12.7
12.2
2.8
0.8
20.7
0.8
7.4
13.7
1.4
0.4
_
0.6
7.3
8.0
13.2
12.7
-
-
To Glass
Processor
1.4
_
5.1
_
7.4
8.1
_
_
_
_
7.1
7.8
2.8
0.8
19.8
0.8
7.4
13.8
-
_
_
_
7.3
8.0
-
-
To To CRT
Exporter Manufacturer
11.8
13.0
13.2
13.6
7.1
11.8
13.5
13.8
11.8
21.9
11.6
12.8
13.6
13.6
Number of Shipments each Year Under Subtitle C
August 24, 2001 - DRAFT
PageE-1
-------
Collectors
Reuse
Subtitle C
Disposal
Reclaimers
Glass
Processors
Exporters
CRT Glass
Manufacturers
Totals
Baseline
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
15,526
3,342
888
2,763
409
24
409
1,114
24
921
3,065
176
1,022
59
20,431
4,456
1,171
3,684
Collectors
SQGs
LQGs
40
400
4
192
44
192
48
574
60
600
196
1,958
Glass Processors
Funnel glass
Panel glass
2
4
94
172
96
176
Primary Alternative
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
Former SQG -
CRT only
Former SQG -all
HW
Former LQG -
CRT only
Former LQG -all
HW
15,616
1,703
2,454
705
401
44
63
19
408
90
24
72
3,003
328
472
136
1,001
110
158
46
408
90
24
72
20,021
2,185
3,147
906
Collectors
SQGs
LQGs
Former SQGs
Former LQGs
1
8
40
294
1
1
1
6
47
211
1
18
47
633
2
8
59
294
6
41
193
1,432
Glass Processors
Funnel glass
Panel glass
3
5
128
241
131
246
CSI Alternative
August 24, 2001 - DRAFT
Page E-2
-------
Collectors
Reuse
Subtitle C
Disposal
Reclaimers
Glass
Processors
Exporters
CRT Glass
Manufacturers
Totals
Original Users
SQGs CRT only
SQGs all HW
LQGs CRT only
LQGs all HW
460
101
27
83
2,605
568
150
470
3,065
669
177
553
Collectors
SQHs
LQHs
40
400
4
39
44
287
48
861
60
360
196
1,947
Glass Processors
Funnel glass
Panel glass
3
6
138
260
141
266
CSI Handlers
CSI SQHs
CSI LQHs
30,643
697
3,483
34,823
August 24, 2001 - DRAFT
Page E-3
-------
Appendix F
Average Annual Sales per Establishment by 2-Digit SIC Code
Industry
SIC Code
Average Sales per
Establishment (S)
AGRICULTURE
Agricultural services
Forestry
Fishing, hunting, trapping
Administrative & Auxiliary
7
8
9
-
$
$
$
MINING
Metal Mining
Coal Mining
Oil & Gas Extraction
Non-metallic minerals, except fuels
Administrative & Auxiliary
10
12
13
14
-
$ 9,642,717
$ 8,841,349
$ 5,338,313
$ 2,338,749
$ 1,545,768
CONSTRUCTION
General contractors
Heavy construction
Special trade contractors
Administrative & Auxiliary
15
16
17
-
$ 1,280,404
$ 2,570,507
$ 590,600
$ 2,207,600
MANUFACTURING
Food & kindred products
Tobacco products
Textile mill products
Apparel & other textile products
Lumber & wood products
Furniture & Fixtures
Paper & allied products
Printing & publishing
Chemicals & allied products
Petroleum and coal products
Rubber & miscellaneous plastics products
Leather & leather products
Stone, clay, and glass products
Primary metal industries
Fabricated metal products
Industrial machinery & equipment
Electronic & other electronic equipment
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
$ 19,567,362
$ 308,752,632
$ 12,020,557
$ 3,103,014
$ 2,277,901
$ 3,759,298
$ 20,760,708
$ 2,540,878
$ 25,443,194
$ 70,728,296
$ 7,170,357
$ 4,751,863
$ 3,846,475
$ 21,271,651
$ 4,571,413
$ 4,793,932
$ 12,809,615
August 24, 2001 - DRAFT
PageF-1
-------
Industry
Transportation equipment
Instrument & related products
Miscellaneous manufacturing
Administrative & Auxiliary
SIC Code
37
38
39
-
Average Sales per
Establishment (S)
$ 35,374,262
$ 11,884,834
$ 2,318,656
$ 3,156,356
TRANSPORTATION
Local & Interurban passenger transit
Trucking & Warehousing
Water transportation
Transportation by Air
Pipelines, except natural gases
Transportation services
Communication
Electronic, gas, & sanitary services
Administrative & Auxiliary
41
42
44
45
46
47
48
49
_
$ 710,436
$ 1,296,519
$ 3,585,027
$ 2,338,134
$ 8,368,550
$ 512,735
$ 5,877,769
$ 15,510,062
$ 1,766,775
WHOLESALE TRADE
Wholesale trade-durable goods
Wholesale trade-nondurable goods
Administrative & Auxiliary
50
51
-
$ 5,084,711
$ 9,036,867
$ 781,548
RETAIL TRADE
Bldg. Materials & garden supplies
General merchandise store
Food stores
Auto dealers & service station
Apparel & accessory stores
Furniture & home furnishing stores
Eating & drinking places
Miscellaneous retail
Administrative & Auxiliary
52
53
54
55
56
57
58
59
_
$ 1,422,393
$ 7,089,224
$ 2,044,651
$ 4,100,193
$ 699,117
$ 846,766
$ 450,446
$ 607,995
$ 370,918
FINANCE, INSURANCE, AND REAL ESTATE
Depository Institution
NTondepository Institution
Security & commodity brokers
Insurance carriers
Insurance agents, brokers, & servicers
Real Estate
Holding & other investment offices
Administrative & Auxiliary
60
61
62
63
64
65
67
-
$ 5,091,211
$ 3,432,819
$ 3,491,738
$ 20,422,940
$ 424,989
$ 617,331
$ 3,237,932
$ 1,054,687
August 24, 2001 - DRAFT
Page F-2
-------
Industry
SIC Code
Average Sales per
Establishment (S)
SERVICES
Hotels & other lodging places
Personal services
Business services
Auto repair, services, & parking
Misc. repair services
Motion picture
Amusement & recreation services
Health services
Legal services
Educational services
Social services
Museums, botanical, zoological gardens
Membership organization
Engineering & management service
Services, n.e.c
Administrative & Auxiliary
Unclassified
70
72
73
75
76
78
79
80
81
82
83
84
86
87
89
-
-
$ 1,423,393
$ 219,582
$ 896,726
$ 407,237
$ 429,359
$ 1,040,439
$ 793,715
$ 677,073
$ 641,030
$ 491,509
$ 225,786
$ 611,305
$ 500,857
$ 827,956
$ 546,119
$ 1,053,680
NA
Source: U.S. Bureau of the Census (1992). Includes County Business Patterns data and data from the Enterprise
Statistics Program.
August 24, 2001 - DRAFT
Page F-3
-------
Appendix G
Detailed Sensitivity Analysis Results on All Parameters Tested
Parameter
Names
Sensitivity Test
Parameter
Values
Percent Change
from Best
Estimate
Savings Under
Primary
Alternative
Savings Under
Primary Alternative
Using the Sensitivity
Test Parameter
Values
Percent
increase
(decrease) in
amount saved
Savings
Under CSI
Alternative
Savings Under
CSI Alternative
Using the
Sensitivity Test
Parameter Values
Percent
increase
(decrease)
in amount
saved
Entry/exit rate for establishments
Best Estimate
Low Range
High Range
1%
0.10%
5%
-90 %
400 %
$ 4,840,000
$ 4,840,000
$4,811,000
$ 4,962,000
-1%
3%
$ 3,098,000
$ 3,098,000
$ 3,095,000
$ 3,109,000
0%
0%
Percent laptops disposed
Best Estimate
Low Range
High Range
18%
10%
33%
-44 %
83%
$ 4,840,000
$ 4,840,000
$ 4,830,000
$4,132,000
0%
-15%
$ 3,098,000
$ 3,098,000
$ 3,127,000
$ 2,582,000
1%
-17%
Percent funnel glass (vs panel glass)
Best Estimate
Low Range
High Range
34%
30%
40%
-12 %
18%
$ 4,840,000
$ 4,840,000
$ 4,840,000
$ 4,840,000
0%
0%
$ 3,098,000
$ 3,098,000
$ 3,098,000
$ 3,098,000
0%
0%
Percent of shipments that include broken CRTs
Best Estimate
Low Range
High Range
100 %
25%
100 %
-75 %
0%
$ 4,840,000
$ 4,840,000
$ 4,754,000
$ 4,840,000
-2%
0%
$ 3,098,000
$ 3,098,000
$ 3,005,000
$ 3,098,000
-3%
0%
Percent of CRTs sent to SQ Collectors
Best Estimate
Low Range
High Range
8%
2%
50%
-75 %
525 %
$ 4,840,000
$ 4,840,000
$4,812,000
$ 5,002,000
-1%
3%
$ 3,098,000
$ 3,098,000
$3,152,000
$ 2,850,000
2%
-8%
Percent of CRTs sent to former SQ Collectors (Primary Alternative only)
Best Estimate
Low Range
High Range
98%
50%
99%
-49 %
1%
$ 4,840,000
$ 4,840,000
$ 4,347,000
$ 4,849,000
-10 %
0%
N/A
N/A
N/A
N/A
N/A
N/A
Percent of generators sending to reuse
August 24, 2001 - DRAFT
PageG-1
-------
Parameter
Names
Best Estimate
Low Range
High Range
Sensitivity Test
Parameter
Values
2%
0%
15%
Percent Change
from Best
Estimate
Savings Under
Primary
Alternative
Savings Under
Primary Alternative
Using the Sensitivity
Test Parameter
Values
Percent
increase
(decrease) in
amount saved
Savings
Under CSI
Alternative
Savings Under
CSI Alternative
Using the
Sensitivity Test
Parameter Values
Percent
increase
(decrease)
in amount
saved
-100 %
650 %
$ 4,840,000
$ 4,840,000
$ 4,767,000
$ 4,893,000
-2%
1%
$ 3,098,000
$ 3,098,000
$3,195,000
$2,851,000
3%
-8%
Percent of CRTs sent for export (Baseline only)
Best Estimate
Low Range
High Range
30%
10%
50%
-67 %
67%
$ 4,840,000
$ 4,840,000
$ 4,630,000
$ 4,764,000
-4%
-2%
$ 3,098,000
$ 3,098,000
$ 2,888,000
$ 3,022,000
-7%
-2%
Percent of CRTs sent for export (Primary Alternative only)
Best Estimate
Low Range
High Range
30% or 18%
5%
30%
-83 % or -72 %
0 % or 66 %
$ 4,840,000
$ 4,840,000
$ 5,244,000
$ 4,523,000
8%
-7%
N/A
N/A
N/A
N/A
N/A
N/A
Percent of CRTs sent for export (CSI Alternative only)
Best Estimate
Low Range
High Range
30% or 20%
5%
40%
0 % or -75 %
33% or 100%
N/A
N/A
N/A
N/A
N/A
N/A
$ 3,098,000
$ 3,098,000
$ 3,487,000
$ 2,627,000
13%
-15%
Maximum shipment weight (in tons) for whole CRTs
Best Estimate
Low Range
High Range
22
18
24
-18%
9%
$ 4,840,000
$ 4,840,000
$ 4,670,000
$ 4,897,000
-4%
1%
$ 3,098,000
$ 3,098,000
$ 3,085,000
$ 3,104,000
0%
0%
Maximum shipment weight (in tons) for crushed CRTs
Best Estimate
Low Range
High Range
23
20
25
-13%
9%
$ 4,840,000
$ 4,840,000
$ 4,932,000
$ 4,788,000
2%
-1%
$ 3,098,000
$ 3,098,000
$ 3,104,000
$3,091,000
0%
0%
Shipping Distances (in miles):
to Handler
Best Estimate
Low Range
High Range
20
5
50
-75 %
150%
$ 4,840,000
$ 4,840,000
$ 4,840,000
$ 4,838,000
0%
0%
$ 3,098,000
$ 3,098,000
$ 3,096,000
$ 3,100,000
0%
0%
to Reuse
Best Estimate
20
August 24, 2001 - DRAFT
Page G-2
-------
Parameter
Names
Low Range
High Range
Sensitivity Test
Parameter
Values
5
50
Percent Change
from Best
Estimate
-75 %
150%
Savings Under
Primary
Alternative
$ 4,840,000
$ 4,840,000
Savings Under
Primary Alternative
Using the Sensitivity
Test Parameter
Values
$ 4,840,000
$ 4,839,000
Percent
increase
(decrease) in
amount saved
0%
0%
Savings
Under CSI
Alternative
$ 3,098,000
$ 3,098,000
Savings Under
CSI Alternative
Using the
Sensitivity Test
Parameter Values
$ 3,097,000
$ 3,099,000
Percent
increase
(decrease)
in amount
saved
0%
0%
to Subtitle C Landfill
Best Estimate
Low Range
High Range
250
100
500
-60 %
100 %
$ 4,840,000
$ 4,840,000
$ 4,738,000
$ 5,008,000
-2%
3%
$ 3,098,000
$ 3,098,000
$3,018,000
$ 3,230,000
-3%
4%
to Glass Processor
Best Estimate
Low Range
High Range
200
100
400
-50 %
100 %
$ 4,840,000
$ 4,840,000
$ 4,767,000
$ 4,984,000
-2%
3%
$ 3,098,000
$ 3,098,000
$3,137,000
$ 3,017,000
1%
-3%
to CRT Glass Manufacturer
Best Estimate
Low Range
High Range
100
50
200
-50 %
100 %
$ 4,840,000
$ 4,840,000
$ 4,844,000
$ 4,829,000
0%
0%
$ 3,098,000
$ 3,098,000
$ 3,104,000
$ 3,085,000
0%
0%
to Reclaimer (from Generator or Collectors)
Best Estimate
Low Range
High Range
300
100
500
-67 %
67%
$ 4,840,000
$ 4,840,000
$ 4,744,000
$ 4,935,000
-2%
2%
$ 3,098,000
$ 3,098,000
$3,116,000
$ 3,080,000
1%
-1%
to Reclaimer (from Glass Processors)
Best Estimate
Low Range
High Range
350
200
500
-43 %
43%
$ 4,840,000
$ 4,840,000
$ 4,839,000
$ 4,839,000
0%
0%
$ 3,098,000
$ 3,098,000
$ 3,099,000
$ 3,096,000
0%
0%
Costs for Disposal to Glass Processor (per ton):
Broken CRTs, no metal
Best Estimate
Low Range
High Range
$0
$0
$ 10.00
N/A
N/A
$ 4,840,000
$ 4,840,000
$ 4,840,000
$ 4,820,000
0%
0%
$ 3,098,000
$ 3,098,000
$ 3,098,000
$3,136,000
0%
1%
Broken CRTs, with metal
Best Estimate
Low Range
$ 100.00
$ 50.00
-50 %
$ 4,840,000
$ 4,859,000
0 %| $ 3,098,000
$3,115,000
1%
August 24, 2001 - DRAFT
Page G-3
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Parameter
Names
High Range
Sensitivity Test
Parameter
Values
$ 150.00
Percent Change
from Best
Estimate
50%
Savings Under
Primary
Alternative
$ 4,840,000
Savings Under
Primary Alternative
Using the Sensitivity
Test Parameter
Values
$4,818,000
Percent
increase
(decrease) in
amount saved
0%
Savings
Under CSI
Alternative
$ 3,098,000
Savings Under
CSI Alternative
Using the
Sensitivity Test
Parameter Values
$ 3,077,000
Percent
increase
(decrease)
in amount
saved
-1%
Whole Bare CRTs
Best Estimate
Low Range
High Range
$ 192.00
$ 100.00
$ 300.00
-48 %
56%
$ 4,840,000
$ 4,840,000
$ 4,859,000
$4,814,000
0%
-1%
$ 3,098,000
$ 3,098,000
$3,115,000
$ 3,073,000
1%
-1%
Broken mixed color/monochrome
Best Estimate
Low Range
High Range
$ 325.00
$250.00
$ 400.00
-23 %
23%
$ 4,840,000
$ 4,840,000
$ 4,868,000
$ 4,808,000
1%
-1%
$ 3,098,000
$ 3,098,000
$ 3,124,000
$ 3,067,000
1%
-1%
Whole CRTs with casing
Best Estimate
Low Range
High Range
$333.33
$ 200.00
$450.00
-40 %
35%
$ 4,840,000
$ 4,840,000
$ 4,853,000
$ 4,825,000
0%
0%
$ 3,098,000
$ 3,098,000
$ 3,332,000
$ 2,889,000
8%
-7%
Exporter, Disposal
Best Estimate
Low Range
High Range
$ 107.00
$0
$ 200.00
-100 %
87%
$ 4,840,000
$ 4,840,000
$4,431,000
$5,195,000
-8%
7%
$ 3,098,000
$ 3,098,000
$2,741,000
$ 3,407,000
-12 %
10%
CRT Glass Manufacturer, Disposal
Best Estimate
Low Range
High Range
$(175.00)
$ (250.00)
$0
43%
-100 %
$ 4,840,000
$ 4,840,000
$4,914,000
$4,661,000
2%
-4%
$ 3,098,000
$ 3,098,000
$3,191,000
$2,871,000
3%
-7%
Number of TVs from unregulated users
Best Estimate
LowRange
High Range
20,000,000
15,000,000
30,000,000
-25 %
50%
$ 1,117,000
$ 1,117,000
$ 1,660,000
$ (10,000)
49%
-101 %
$ 4,202,000
$ 4,202,000
$ 4,024,000
$ 4,552,000
-4%
8%
Number of monitors from unregulated users
Best Estimate
Low Range
High Range
16,886,411
10,000,000
25,000,000
-41 %
48%
$1,117,000
$1,117,000
$ 1,621,000
$ 434,000
45%
-61 %
$ 4,202,000
$ 4,202,000
$ 4,033,000
$ 4,402,000
-4%
5%
August 24, 2001 - DRAFT
Page G-4
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August 24, 2001 - DRAFT Page G-5
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Appendix H
Telephone Contacts
Contacts made by Sue Chotikajan:
Tony Catareno, LG. Inc., 3476 Saint Rocco CT., Cleveland, OH 44109, (216) 631 -7710.
November 6,1998.
Questions:
(1) Where do you get your discarded CRTs?
(2) What types of industries/manufacturers are your sources (TV and computer manufacturers or
post-consumer)?
(3) How much do you charge for taking discarded CRTs (Specifically for a 30 pound monitor)?
(4) What do you with the glass? Is it landfilled, sent to smelters, or sent to CRT glass
manufacturers?
(5) What is the percentage of this allocation?
(6) What is the cost of sending glass to each disposal or recycling alternative?
(7) What is the total number of CRTs processed annually and total weight processed?
(8) Do you have information on the number of color vs. monochrome monitors processed?
Responses:
• LG. Inc. receives used CRTs from leasing companies, a few from households, but none from
manufacturers.
• LG. Inc. charges $3-$5 per monitor for pick-up services of discarded computers, and leasing
companies pay for their own transportation.
• CRTs are pulled out of monitor and processed. Some parts (phosphorous, metals, glass) are
sent to recycling companies and glass manufacturers.
• All CRT glass is sent to CRT glass manufacturers.
• Information on cost sent to each glass manufacturers isn't shared with the public.
• The total number of CRTs processed annually is approximately 5,000 monitors.
• Since LG, Inc. is only processing CRTs as a sideline, we do not track down the types of
monitors processed.
August 24, 2001 - DRAFT Page H-1
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Jim Weber, Federal Prison Industries, Ohio, (330) 424 -7448 (ext. 1313). November 6,1998.
Questions:
(1) Where do you get your discarded CRTs?
(2) What types of industries/manufacturers are your sources (TV and computer manufacturers or
post-consumer)?
(3) How much do you charge for taking discarded CRTs (Specifically for a 30 pound monitor)?
(4) What do you with the glass? Is it landfilled, sent to smelters, or sent to CRT glass
manufacturers?
(5) What is the percentage of this allocation?
(6) What is the cost of sending glass to each disposal or recycling alternative?
(7) What is the total number of CRTs processed annually and total weight processed?
(8) Do you have information on the number of color vs. monochrome monitors processed?
Responses:
• Federal Prison Industries receives discarded computers from GE, Motorola, computer
manufacturers, and schools. Federal Prison Industries doesn't receive any discarded
televisions.
• Federal Prison Industries charges $4-$5 per monitor, and the manufacturer or entity discarding
the computer monitors pays for the shipping.
• Generally, Federal Prison Industries' picks up and sorts the computer monitors and then sends
them to Envirocycle, a CRT glass-to-glass recycling center. None of the discarded CRTs are
landfilled or sent to smelters.
• All discarded CRTs are sent to CRT glass manufacturers, through CRT glass-to-glass
recyclers, such as Envirocycle.
• Envirocycle pays $0.25 per pound of glass or $500 per ton of glass.
• Federal Prison Industries processes around 4,000 monitors per year.
• On average, they process an equal number of color and monochrome monitors. The most
common types of color monitors discarded are GEA and CEA. They separate the glass into
four types: PB, color, NPHS, and miscellaneous plastic filament.
Gary DiRusso, DMC Recycling, New Hampshire, gdirusso@dmcrecycling.com. October 30,
1998.
Questions:
(1) Where do you get your discarded CRTs?
August 24, 2001 - DRAFT Page H-2
-------
(2) What types of industries/manufacturers are your sources (TV and computer manufacturers or
post-consumer)?
(3) How much do you charge for taking discarded CRTs (Specifically for a 30 pound monitor)?
(4) What do you with the glass? Is it landfilled, sent to smelters, or sent to CRT glass
manufacturers?
(5) What is the percentage of this allocation?
(6) What is the cost sent to each?
(7) What is the total number of CRTs processed annually and total weight processed?
(8) Do you have information on the number of color vs. monochrome monitors processed?
Responses:
• DMC receives monitors from a government agency (NSA), businesses such as (SunMicro,
AT&T, etc) and computer monitor manufacturers, such as Nissei, Sangyo (Hitachi).
• Approximately 50 percent by weight of the monitors that DMC receives from the government
can be reused; the other 50 percent is disassembled and recycled. Reusable computer
monitors represent approximately 30 percent of the total materials received from the
government. The remaining 70 percent is computers, telecommunications equipment, and other
electronic equipment.
• DMC charges $0.11 - 0.13 per pound (based on quantity) for recycling monitors.
• DMC receives shipments of 10,000 to 30,000 pounds at a time from monitor manufacturers.
• DMC currently processes approximately 1 million pounds of monitors per year with
expectations that this could increase considerably because of the landfill ban pending in
Massachusetts effective July 1999. [One million pounds of monitors is approximately 33,000,
30 pound computer monitors.]
• DMCs current capacity is 6.5 million pounds in a 40-hour workweek. DMC can process this
large capacity because all of their equipment is automated to recycle whole monitors or CRTs.
• DMC recycles glass, steel, copper, plastic, and aluminum from the computer monitors.
• All the glass from CRTs that DMC recycles is sent to a lead smelter. Typically they ship the
glass by rail in quantities of about 100,000 pounds (50 tons).
• The primary lead smelter uses the glass silicate in place of a commercial fluxing agent and
recovers the lead.
• DMC's recycling process entails 5 steps to breakup and separate the computer monitor
materials: (1) shredding; (2) ferrous separation; (3) pulverizing the glass; (4) sifting the glass; (5)
containerizing the copper, aluminum, and plastic.
August 24, 2001 - DRAFT Page H-3
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Contacts made by Tom Uden:
Robert Bouma, Noranda, Toronto, Ontario, (416) 982-7237. November 4,1998.
Questions:
(1) What is the cost for disposal/recycling of CRTs at your facility?
(2) Where do CRTs fit in your process?
(3) How many CRTs are processed each year?
(4) What types of companies/organizations typically provide you CRTs?
(5) Any other general information?
Responses:
• The price for taking CRTs is several hundred dollars, but typically less than $500 per ton. This
value is closely guarded, because various companies "compete" for monitors. The fee is the
money maker in this operation, not the copper, silica, and precious metal values recovered.
CRT glass is less valuable than a whole monitor, because there are no precious metals or
copper in the CRT glass.
• CRTs are introduced whole, or shredded into a copper smelter. Copper (principally from the
yoke) and small amounts of precious metal are recovered. Lead is discarded in the furnace
slag to a secure impoundment. CRTs also contain silica, which is useful as a fluxing agent.
• Noranda accepts approximately 1,000 - 2,000 tons of monitors per year. [This weight range
represents between 50,000 to 130,000 monitors.] Weight assumptions would allow calculation
of absolute numbers. The principle input is whole monitors, as opposed to broken CRT glass,
or only the CRT. TVS are generally too large for the shredder. Some non-viable TV tubes are
obtained from OEMs.
• Generally electronic scrap brokers supply the CRTs. Often, these brokers will go into an office
facility, to obtain the highest value components (the computer "boxes"). They may attempt to
refurbish and sell monitors. However, most brokers take the monitors even though they do not
want them. They take the monitors as part of a package deal, to get the computers which
contain much greater levels of precious metals. Another source of monitors is from OEMs. If
an OEM (e.g., IBM, Digital, HP) replaces an entire office's PCS, the broker, as part of a
package deal, will take away the old systems, including monitors. Taking the monitors is part of
the service.
• CRT glass direct from OEMs (broken in manufacturing for example) is an ideal input for their
lead smelter in New Brunswick. The glass must be clean, because plastic fouls the sulfuric acid
plant that is part of the process.
August 24, 2001 - DRAFT Page H-4
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Cliff Asbury, Doe Run, Glover, MO, (573) 546-7492, x-237. November 10,1998.
Questions:
(1) What is the cost for disposal/recycling of CRTs at your facility?
(2) Where do CRTs fit in your process?
(3) How many CRTs are processed each year?
(4) What types of companies/organizations typically provide you CRTs?
(5) Any other general information?
Responses:
• A general number for disposal of CRTs at Doe Run is $ 140 per ton of CRT glass. The number
will vary depending on the quality of the glass, and the volume (Doe Run offers high-volume
discounts).
• CRT glass is introduced as a fluxing agent at the primary smelter. Some lead is recovered from
the lead content in the glass, but the primary value is as a fluxing agent. The CRTs are exempt
from being manifested to the smelter, under a 50% material substitution provision.
• 100-125 tons of CRT glass are processed each year. [This weight range represents between
5,000 to 8,000 monitors.] CRT glass is generally shipped in "gaylord" boxes. These are 1
cubic yard cardboard boxes. Doe Run would like to receive the glass in dump trucks, or rail
cars. This would eliminate the need to dispose of several thousand boxes a year.
• CRT glass comes from recovery services, that scavenge used computers. Some try to refurbish
the computers, often sending them overseas. A lot of these companies are primarily interested
in the precious metal and copper values in the computer "box." They take the monitors as part
of the deal, and have to get rid of the glass. They only dump the glass after fully disassembling
and recovering valuable components from the monitor.
• One broker/processor (DMC) sends glass to Doe Run crushed to 3/8 inch particles. The
crushing is good for the broker/processor (because they can use magnetic separation
techniques to get the metal out), and for Doe Run (because fewer contaminants remain in the
glass, and the glass is already crushed for introduction into the smelting furnace).
• Mr. Asbury mentioned three brokers/processors:
• Asset Recovery, MN; 612-602-0789, Bruce Janovic. This may be an affiliate of
Digital Corp.
DMC, NH; 603-772-7236, Mike Mogliano.
SEER, FL; 800-376-7888, Mike Flynn.
• Mr. Asbury expressed concern that the current CSI proposal favors glass-to-glass recycling.
Doe Run does not want to lose CRTs as an input and revenue generator. [CRTs may represent
an important revenue source, especially when the price of lead is low.]
August 24, 2001 - DRAFT Page H-5
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Mike Flynn, SEER (Secure Environmental Electronic Recovery), Tampa, FL. (888) 600-7337.
November 11,1998.
Questions:
(1) What is the cost for disposal/recycling of CRTs at your facility?
(2) Where do CRTs fit in your process?
(3) How many CRTs are processed each year?
(4) What types of companies/organizations typically provide you CRTs?
(5) Any other general information?
Responses:
• SEER charges $7.50 per computer monitor, $12.50 per table-top television, and $35.00 per
console television.
• Typically whole computer systems are recovered from companies. Usually this results from a
modernization of company hardware. Very often, these companies have old equipment in a
warehouse that is removed at the same time. SEER determines if the equipment (including
monitor) has resale or refurbishment value. If re-sale or refurbishment is not an option (as with
older equipment that has been stored for a while) demanufacturing occurs. Some consumers
give SEER computer monitors and televisions, if they are concerned with "doing the right thing"
environmentally.
• For monitors, the mercury switches, and valuable parts are removed. The vacuum is released.
The front panel is cut away. CRTs are shipped in gaylord boxes. 950 pounds of CRTs fit in
one box, although Mike could not say how many CRTs this represents. [950 pounds of CRTs
is approximately 30 CRTs.] They currently ship to Doe Run only. Mr. Flynn is going to visit
Envirocycle next week to look into sending some CRT glass to them. He predicts that there
will be increased disposal in the near future, and that he will need more than one outlet for
CRTs. If SEER contracts with Envirocycle, the monitor flow would be: (1) end user, (2)
SEER, (3) Envirocycle, (4) Techniglass.
• Mr. Flynn did not have the number of CRTs processed per year available at the time of the call.
• Companies with a large computer base, usually located in large office buildings or complexes,
are SEER's typical customers. They find out about SEER through Subtitle D landfills. For
instance, many CWM Inc. Subtitle D landfills in the area refer companies with large CRT
volumes to SEER. It was not apparent whether this is a formal arrangement, although it seems
unlikely.
• Florida recently adopted Universal Waste Regulations, and SEER is a Universal Waste
Handler and Transporter. This allows them to handle batteries and mercury switches. Mr.
Flynn claimed that when the CRTs are brought to SEER, they are in monitor format and are
August 24, 2001 - DRAFT Page H-6
-------
therefore still potentially a viable product. They are therefore exempt from RCRA manifest and
other requirements. When they are sent to Doe Run, they are exempt because they are primary
process feed. He is not sure what the RCRA status of shipping to Envirocycle would be; he
intends to find out next week.
Mr. Flynn also expressed concern that the CSI proposal will preferentially treat the glass-to-
glass channel. He thinks that any increased regulations on smelters would create a problem,
because the glass-to-glass processors do not have the capacity to handle the projected increase
in CRT disposal.
Various, Chemical Waste Management (CWM). November 2-3,1998.
Questions:
(1) What is the cost for disposal/recycling of CRTs at your facility?
(2) Where do CRTs fit in your process?
(3) How many CRTs are processed each year?
(4) What types of companies/organizations typically provide you CRTs?
(5) Any other general information?
Responses:
• The disposal cost is $285/cu yard for macroencapsulation, and $150-175 for 55 gal drum of
whole monitors/CRTs (Street, AL). In addition, for Model City NY, if the shipment is from out
of state it is subject to a $27/ton state hazardous waste tax. All shipments to the facility are
subject to a 6% town tax, and a 7% sales tax (Customer Service, NY). Mr. Street mentioned
that LA has a more favorable tax structure.
• CWM is a RCRA Subtitle C facility, with the ability to stabilize lead leaching components.
Monitors would be encapsulated (without crushing/breakage) in impermeable containers, with a
concrete type substance poured around them (Customer Service, NY).
• Model City (Buffalo) NY and Emelle AL could not think of specific instances of CRT disposal.
(Although Dr. Street in Emelle thought that the NY facility would likely deal with CRTs; he
suggested talking to their environmental person, Jill Knickerbocker, who did not return my
calls). The Lake Charles LA facility contact could recall one shipment of CRTs that was
macroencapsulated (Grant, LA).
• The contact at Emelle thought that shipments of monitors would likely come from Fortune 500
companies with strong environmental programs. He thinks that many monitors are being
recycled, some by the same facilities that recycle Hg lamps (Street, AL).
• Contacts:
CWM Model City NY (716) 754-8231 Jill Knickerbocker
August 24, 2001 - DRAFT Page H-7
-------
CWM Emelle AL (205) 652-9721 Dr. Jim Street
CWM Lake Charles LA (318) 583-2144 Chuck Grant
Heather McCarthy, Clean Harbors of Braintree. May 9 and 24, 2001.
Questions:
(1) Have you mostly received CRTs from the users, brokers, or other types of businesses?
(2) Are the CRTs mostly sent to you whole or crushed?
(3) What are your rates for stabilization and disposal of bulk waste?
(4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in
the last year?
(5) Does your company provide transportation services?
Responses:
• CRTs are mostly received from businesses, but some are received from brokers.
• CRTs are received whole in flex bins, which are similar to but smaller than gaylord boxes.
• CRTs are dismantled and recycled to the maximum extent possible in their Bristol, CT facility.
Clean Harbors charges $300 to $500 per flex bin depending on the size and frequency of
shipments. The CRT glass is sent to Canada where it is crushed, treated, and disposed. Clean
Harbors does not have a minimum charge for shipments of CRTs
• Do not have a current estimate of the number or tons of CRTs processed.
• Clean Harbors provides transportation services and charges a flat rate of $150 per shipment for
the Boston area. For locations farther away (e.g., Maine) they charge about $300 per
shipment.
Lisa Humfry, Envirosafe Services of Ohio. May 10, 2001.
Questions:
(1) Have you mostly received CRTs from the users, brokers, or other types of businesses?
(2) Are the CRTs mostly sent to you whole or crushed?
(3) What are your rates for stabilization and disposal of bulk waste?
(4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in
the last year?
(5) Does your company provide transportation services?
Responses:
August 24, 2001 - DRAFT Page H-8
-------
CRTs are mostly received from brokers, but some are received from businesses. One
customer consolidated CRTs from many of its facilities and crushed the CRTs before sending
them to Envirosafe. Envirosafe macro-encapsulates CRTs sent in poly drums, and encapsulates
whole CRTs. If the CRTs are sent crushed in a roll-off container, they will stabilize the CRTs
for disposal.
CRTs sometimes are received whole, but mostly crushed in roll off containers.
The rate for crushed CRTs in a roll-off container is $160 per ton. The rate for whole monitors
is $360 per cubic yard. The rate for whole CRTs in drums is $150 per drum. Envirosafe does
not have a minimum charge for shipments of CRTs.
Envirosafe received no CRTs last year and about 20 to 30 tons the previous year.
Envirosafe subcontracts out transportation.
Mark Cardamone, F&M Bay Electronics Co. Inc./SEER Inc., Tampa, FL. (813) 621-8870.
May 14, 2001.
Questions:
(1) What do you do with the CRTs you receive?
(2) Who do you receive CRTs from? e.g., the users, brokers, or other types of businesses?
(3) What are your rates for processing monitors?
(4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in
the last year?
(5) What do you do with the CRT glass?
(6) Does your company provide transportation services?
Responses:
• All monitors that were manufactured during or after 1996 are tested to see if they are
operational. About 10 percent of the CRTs received are resold. The remaining monitors are
demanufactured and the plastic, steel, aluminum, and copper are recycled. The bare CRTs are
cut in half to separate the panel from the funnel. The CRT glass is sent to Envirocycle and to
Dlubeck Glass.
• Most of the monitors are received from original users. Monitors are also obtained from
municipal solid waste facilities that remove the CRTs from the solid waste stream at landfills or
transfer stations.
• For monitors that are 17 inches or less, they charge $6 to $7.50 per monitor. For monitors that
are larger than 17 inches, they charge $9.50 per monitor. For bare CRTs, they charge $4.00
per bare CRT.
August 24, 2001 - DRAFT Page H-9
-------
• The facility processed 40,000 CRTs in the last year. This includes both TVs and monitors.
• The CRT glass is sent to Envirocycle and to Dlubeck Glass.
• Transportation services are provided and include scheduled pickups through common carriers
and their own trucks. Local pickup includes a range of 50 miles and costs $25 per pickup. In
Florida transportation costs are generally $25 to $150 per pickup.
Jack Hope, WasteNot Recycling, Sterling, VA. (703) 787-0200. May 15, 2001.
Questions:
(1) What do you do with the CRTs you receive?
(2) Who do you receive CRTs from? e.g., the users, brokers, or other types of businesses?
(3) What are your rates for processing monitors?
(4) Can you estimate how many CRTs or how many tons of CRTs your facility has processed in
the last year?
Responses:
• WasteNot Recycling is a not for profit organization that trains and employs developmentally
disabled adults. They only take functional monitors right now. They are looking into the
options for demanufacturing monitors in the future.
• Monitors are received from local companies, such as ATT, SAIC, and Boeing.
• There is no charge for donating monitors.
• Mr. Hope did not have an estimate of the number of computer or monitors received.
Greg Voorhees, Envirocycle, Halstead, PA. (570) 879-2862. April 25, 2001.
Questions:
(1) What percent of the CRT glass that you receive is sold as fines?
(2) What percent of Envirocycle's processed CRT glass is sent to lead smelters?
(3) What is Envirocycle's recycling capacity?
(4) Is the facility in North Carolina that is mentioned on your web site open yet?
(5) What do you charge for intact whole monitors?
(6) What percent of CRTs are received as whole monitors, bare CRTs, or crushed glass?
Responses:
August 24, 2001 - DRAFT Page H-10
-------
None.
All of the fines generated in the processing of CRTs are sent to a primary lead smelter, for
which Envirocycle must pay. The processing of CRTs generates about two percent fines by
weight. Envirocycle is working to improve the efficiency of its process to reduce the generation
of fines.
Envirocycle is currently operating at about 20 percent of its capacity in its Halstead, PA facility.
Envirocycle's current operating tempo is about 1.5 million pounds per month
The North Carolina facility will not be opened. Two other locations are being pursued and will
be open by the end of the year. One facility will be located in the north east and the other will
be on the west coast.
Envirocycle charges about $5 to $6 per monitor for whole monitors. The actual price paid is
volume dependant.
About 50 to 60 percent of the glass received is "dirty-mix with no metals." This glass comes
from other demanufacturing facilities. Envirocycle still receives about the same amount of CRT
glass from OEMs as in 1996.
August 24, 2001 - DRAFT Page H-11
-------
Appendix I
Bibliography
Aanstoos, T., Mizuki, C., Nichols, S., and Pitts, G. CRT Disposition: An Assessment of Limitations
and Opportunities in Reuses, Refurbishment, and Recycling in the U.S., IEEE International
Symposium on Electronics & the Environment. 1997.
"April Showers Grew May Color TV Sales," Consumer Electronics Manufacturing Association
Homepage, www.cemacity.org/cemacity/gazette/files2/vidmay98.htm. October 6, 1998.
"Closed-Loop CRT Recycling: Why Europe and the U.S. Differ?" Cutter Information Corporation,
Product Stewardship Advisor, www.cutter.com/psa/fulltext/l997/09. Volume I, No. 4:
September 1997.
"Consumer Electronics Industry Forecast for 1997 - 27.6 Million New TV Sets and Much More,"
Consumer Electronics Manufacturing Association Homepage,
www. cemacity. org/cemacity/gazette/files2/vidmay 98 .htm.
DPRA Incorporated. "Regulatory Impact Analysis of the Proposed Rule for a 180-Day Accumulation
Time for F006 Wastewater Treatment Sludges," August 4, 1998.
Notes from personal communication with Greg Voorhees from Envirocycle, 1996.
Data series for Personal Computers, Color TV Receivers, Color TV Receivers, Monochrome TV
Receivers - U.S. Sales to Dealers, Electronic Industries Alliance, 1998.
Department of Environmental Protection, DEP's 1998 CRT/Electronics Recycling Strategy
Cost/Benefit Analysis, May 1, 1998.
DMC Monitor Recycling, DMC Electronics Homepage, www.nh.ultranet.com/~dmc/monitor.html.
accessed October 20, 1998.
Electronic Industries (EIA) Sector, Cathode Ray Tube Industry Subsector Presentation, September
26-28, 1994.
Electronics Industry Sector-Cathode Ray Tube Industries, Alternative Strategies Work Group, Green
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