ECONOMIC ANALYSIS OF CATHODE RAY TUBE MANAGEMENT, NOTICE OF PROPOSED RULEMAKING U.S. Environmental Protection Agency Office of Solid Waste February 15,2002 ------- 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 Pagei ------- 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 Page ii ------- 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 Page iii ------- 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 Page iv ------- 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. Page 1 ------- 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. Page 2 ------- 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 Page 3 ------- 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. Page 4 ------- 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. Page 5 ------- 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. Page 6 ------- 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. Page? ------- 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 PageS ------- 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. Page 9 ------- 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. Page 10 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Page 21 ------- 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 ------- 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 ------- 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 Page 24 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Page 33 ------- • 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 Page 34 ------- 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 ------- 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 ------- 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 ------- 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 Page 38 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. August 24, 2001 - DRAFT Page 43 ------- 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. August 24, 2001 - DRAFT Page 44 ------- 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 ------- 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 ------- 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 ------- 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 August 24, 2001 - DRAFT Page 48 ------- • 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 ------- 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 ------- 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 ------- 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 Page 52 ------- 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 Page 53 ------- 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 Page 54 ------- 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 Page 55 ------- 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 Page 56 ------- 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 Page 57 ------- 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 Page 58 ------- 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 Page 59 ------- 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 Page 60 ------- 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 Page 61 ------- 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. August 24, 2001 - DRAFT Page 62 ------- 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 Page 63 ------- 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 ------- 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 Page 65 ------- 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. August 24, 2001 - DRAFT Page 66 ------- 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 Page 67 ------- 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 Page 68 ------- 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 Page 69 ------- 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. August 24, 2001 - DRAFT Page 70 ------- $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. August 24, 2001 - DRAFT Page 71 ------- 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 Page 72 ------- 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 Page 73 ------- 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. August 24, 2001 - DRAFT Page 74 ------- 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 Page 75 ------- 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 Page 76 ------- 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 ------- 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 ------- "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 Page 79 ------- 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 Page 80 ------- 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 Page 81 ------- 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 August 24, 2001 - DRAFT Page 82 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- August 24, 2001 - DRAFT Page G-5 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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?" 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ICF Inc., Economic Impact Analysis for the Military Munitions Final Rule, June 1996. ICF Inc., Memorandum to Allen Maples, EPA. "Baseline Costs and Cost Comparisons Between Hazardous Waste, Hazardous Material, and Non-Hazardous Shipments." August 31, 1998. Joyce, Amy. "Reduce, Reuse, Reboot." The Washington Post, January 21, 2000. "The Long-Term Future of CRT Glass Recycling: How NEC Is Planning Ahead." Cutter Information Corporation, Product Stewardship Advisor, www.cutter.com/psa/fulltext/l997/09. Volume I, No. 6: November 1997. Macauley, Molly, Palmer, K., Shih, Shih, J., Cline, S., Holsinger, H., Modeling the Costs and Environmental Benefits of Disposal Options for End-of-Life Electronic Equipment: The Case of Used Computer Monitors. Resources for the Future, Discussion Paper 01-27, June 2001. 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. The Microelectronics and Computer Technology Corporation (MCC), Environmental Consciousness: A Strategic Competitiveness Issue for the Electronics and Computer Industry. Comprehensive Report: Analysis and Synthesis, Task Force Reports and Appendices. March 1993 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, Spring 2001. August 24, 2001 - DRAFT Page 1-2 ------- National Recycling Coalition, "Proper Management of Cathode Ray Tubes (CRTs)." 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EPA web site: epanotesl.rtpnc.epa.gov:7777/rlO/owcm.nsf, October 1998. U.S. Environmental Protection Agency, Office of Solid Waste, Economics, Methods and Risk Analysis Division. Unit Cost Compendium. September 30, 2000. U.S. Environmental Protection Agency, Office of Solid Waste. Capacity Analysis for Land Disposal Restrictions - Phase IV: newly Identified Toxicity Characteristic Metal Wastes and Mineral Processing Wastes (Final Rule), Background Document. April, 1998. U.S. Environmental Protection Agency. Supporting Statement for EPA Information Collection Request Number [] "Reporting and Recordkeeping Requirements for the Proposed Rule on Cathode Ray Tube (CRT) Glass Reuse. " Working Draft, October 9, 1998. "Video and Computer Industry Facts," Consumer Electronics Manufacturing Association Homepage, www.cemacity.org/cemacity/digital/files/hdtvfact.htm. accessed October 6, 1998. August 24, 2001 - DRAFT Page 1-3 ------- |