RCRA Hazardous Waste Delisting: The First 20 Years


  RCRA Hazardous Waste
  Delisting:
  The First 20 Years
Program Evaluation
U.S. Environmental Protection Agency
 Effice of Solid Waste
 ne, 2002

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RCRA Hazardous Waste Delisting

      The First Twenty Years
          Off ice of Sol id Waste
              June 2002
             530-R-02-014

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      RCRA Hazardous Waste Delisting: The First Twenty Years

EXECUTIVE SUMMARY  	« 1 »
     PURPOSE  	« 1 »
     THE HAZARDOUS WASTE DELISTING PROGRAM 	« 1 »
     METHODOLOGY OF THE EVALUATION	« 2 »
     DESCRIPTIVE STATISTICS 	« 2 »
     ECONOMIC IMPACTS OF THE DELISTING PROGRAM	« 2 »
     ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM 	« 3 »
     CONCLUSIONS  	« 3 »

CHAPTER ONE: EVALUATION OF THE DELISTING PROGRAM 	« 4 »
     1.1  PURPOSE	« 4 »
     1.2  PROGRAM EVALUATION AND GPRA 	« 4 »
     1.3  THE HAZARDOUS WASTE DELISTING PROGRAM  	« 5 »
     1.4  EVALUATION OF THE DELISTING PROGRAM 	« 8 »
           1.4.1   Why Evaluate the Delisting Program?	« 8 »
           1.4.2   What are the Outcomes and Impacts of the Delisting Program? .... « 10 »
           1.4.3   Is the Delisting Program Fulfilling Its Goals? 	« 10 »
     1.5  METHODOLOGY OF THE EVALUATION	« 10 »
           1.5.1 Creating the Database	« 11 »
           1.5.2 Assessing the Data	« 11 »
CHAPTER TWO: RESULTS OF THE EVALUATION	« 13 »
     2.1  DESCRIPTIVE STATISTICS  	« 13 »
           2.1.1  Total Quantities of Waste Delisted  	« 15 »
     2.2    ECONOMIC IMPACTS OF THE DELISTING PROGRAM	« 16 »
           2.2.1  Administrative Costs  	« 16 »
           2.2.2  Costs of Treatment and Disposal 	« 17 »
           2.2.3  Net Cost Impacts 	« 22 »
     2.3    ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM  .... « 22 »
           2.3.1  Environmental Releases	« 23 »
           2.3.2  Recycling  	« 24 »
           2.3.3  Opportunity Costs to EPA	« 25 »
     2.4    DISTRIBUTION OF IMPACTS  	« 25 »
           2.4.1 Geography  	« 25 »
           2.4.2 Small Businesses	« 26 »
           2.4.3 Industries Affected	« 26 »

CHAPTER THREE: RECOMMENDATIONS AND CONCLUSIONS 	« 28 »
     3.1    RECOMMENDATIONS  	« 28 »
           3.1.1  Regulatory Impacts Analysis	« 28 »
           3.1.2  Evaluation of the Listing Program 	« 28 »
     3.2    CONCLUSIONS	« 28 »

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                             EXECUTIVE SUMMARY
PURPOSE

       This report documents an evaluation of the outcomes and impacts of the hazardous waste
delisting program, conducted by the United States Environmental Protection Agency under the
Resources Conservation and Recovery Act (RCRA).  The report describes the rationale for
conducting a program evaluation, the results and outcomes of the delisting program, and other
findings and issues raised in this evaluation.

       This evaluation was undertaken as part of EPA's implementation of the Government
Performance and Results Act (GPRA) of 1993. That statute requires federal agencies to include
program evaluations in the strategic planning process.

THE HAZARDOUS WASTE DELISTING PROGRAM

The Resource Conservation and Recovery Act, which guides EPA's hazardous waste
management programs, provides for a process to remove, or "delist", a waste generated at a facility
from the list of hazardous wastes. This delisting process is initiated by the generator (person who
creates the waste), who prepares a petition for delisting the waste.  The petition provides
information about the waste,  including its chemical composition, to demonstrate the rationale for
delisting the waste. The petition is reviewed by the appropriate regulatory agency (either EPA or
a state hazardous waste regulatory agency which has been authorized to grant delisting petitions)
to determine whether the waste should continue to be listed as hazardous.l

EPA's Office of Solid Waste decided that the delisting program would be a good candidate for
evaluation. After consultation with staff and management in both headquarters and the regional
offices, OSW decided that this evaluation would be most useful if focused on the outcomes and
impacts of the federal delisting program, rather than focus on the mechanisms for conducting
delistings.  Therefore, this study examines how the program has functioned,  and what has been
gained by the operation of the delisting program.  This "big picture" focus also results in findings
that provide useful information for assessing the future direction and management of the delisting
program.   This report looks at three different categories of outcomes of the delisting program:

       •>       Cost savings and aggregate economic impacts
       •>       Impacts of delisting on the environment
       •>       Impacts of delisting on the RCRA hazardous waste management program
        See Section 1.3 for more detail on the full process of the regulatory determination.


                                          « 1 »

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METHODOLOGY OF THE EVALUATION

EPA assembled a database listing all the delisting applications granted by the EPA (not including
those granted by state governments) between calendar years 1980 and 1999. Some of the
information had been kept by the delisting program, either in paper files or in the Delisting
Petition Data Management System. This database had been discontinued in 1995. Other data
was taken from the Federal Register notices announcing each proposed and final delisting granted.
Data elements in the current database include:

» Name and address of petitioning facility
•> Date petition submitted and final decision reached
* Date delisting became effective
* Waste volume, matrix, form, quantity, and source
* Chemical test results for wastes
» RCRA waste codes
» Management of wastes before and after delisting

Using the database, we calculated total volumes of waste delisted. We also estimated the cost of
administering the program, and cost savings that have been realized through delisting.

DESCRIPTIVE STATISTICS

Over the 20-year period from 1980 through 1999, delistings were granted to a total of 136
separate waste streams, generated at 115 separate facilities. By far the most common waste code
for which delistings were granted is F006, an electroplating waste, found in 51 delisted waste
streams. Over this period, a cumulative total of 45 million tons of waste has been excluded
from subtitle C requirements; over 80% of that volume is wastewater.

ECONOMIC IMPACTS OF THE DELISTING PROGRAM

The reduced social costs associated with the delisting program are derived through calculating the
administrative costs of operating the delisting program, and the offset of lowered costs of waste
treatment and disposal.

The total administrative costs associated with this twenty year period of the delisting program
ranges from $107 million to $226 million. The costs to petitioners is between 70-85% of that
total. The costs of running the program, while large, are far outweighed by the cost savings
achieved, however. From the inception of the delisting program through the year 2000,
cumulative net cost savings attributable to the delisting program range between $1.2 billion and
$2.4 billion. Even if no further delistings are ever granted, the delisting program will save over
$105 million each year, from wastes that have already been removed from Subtitle C regulation.

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ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM

An complete investigation into previously delisted wastes was outside the scope of this program
evaluation. However, given a strict risk assessment process (which has been made progressively
more accurate), the Agency has little reason to believe that these streams are causing
environmental problems. The Agency has also taken steps to limit the possibilities for harmful
environmental releases in the future, and to facilitate review of the consequences of disposal of
delisted waste streams.

Another issue of concern is the impact of delisting on recycling. It seems logical that delisting
might inhibit recycling in some cases, and promote it in others. We found anecdotal evidence of
both impacts, but were unable to identify clear trends in either direction.

CONCLUSIONS

The findings of this evaluation distinctly demonstrate the significant economic impacts of the
delisting program: reductions in deadweight loss to the economy totaling over $100 million each
year. Continued efficiencies and refinements in the delisting petition review process should only
improve those results. The environmental impacts are not as clear, although EPA does not
have reason to suspect that delisted wastes are causing environmental problems.

As one of the first program evaluations undertaken by the RCRA program in response to GPRA,
there is also clear value to this evaluation study itself. Not only has it helped the RCRA program
understand the process of program evaluation, it has also helped us understand the nature of the
value of a program. The analysis demonstrates that benefits can take many forms, not just risk
reduction. A program like delisting demonstrates its value in terms of reduction in economic
losses, and concomitant improvement in human welfare.

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CHAPTER ONE:
EVALUATION OF THE DELISTING PROGRAM
1.1 PURPOSE

This report documents an evaluation of the outcomes and impacts of the hazardous waste
delisting program, conducted by the United States Environmental Protection Agency under the
Resources Conservation and Recovery Act (RCRA). The report describes the rationale for
conducting a program evaluation, the results and outcomes of the delisting program, and other
findings and issues raised in this evaluation.

1.2 PROGRAM EVALUATION AND GPRA

This evaluation was undertaken as part of EPA's implementation of the Government
Performance and Results Act (GPRA) of 1993. Under that statute, program evaluation has been
defined as "an objective and formal assessment of the results, impact, or effects of a program or
policy."2 Program evaluations also may examine the implementation, operations, and/or
processes of programs.3 A program evaluation will draw conclusions about the effectiveness of
the design, implementation, and/or impacts of a program. The term program here includes the
usual connotation of a set of staff activities with a defined goal or purpose; the term may also
include a policy initiative, an investment project, or even a change in procedures.

Why conduct a program evaluation? Evaluation is clearly a good practice for effective
management, whether public, private, or non-profit. Among the advantages of conducting
evaluations are

» Assessing the impact of programs and policies
•> Documenting that functions have been carried out and outcomes reached
•> Documenting a lasting record of the program
•> Assisting with decisions about program continuation, expansion, and future funding.

Although the GPRA statute does not require a specific schedule of program evaluations, the law
clearly presumes they will be conducted. The committee report accompanying the legislation, as
well as the legislation itself, speaks specifically of the role of program evaluations in the annual
cycle of performance planning and reporting. Guidance from the Office of Management and
Government Performance and Results Act oj 1993: Report ojthe Committee on Governmental Affairs, United States

Senate, to Providejor the Establishment, Testing, and Evaluation oj Strategic Planning and Performance Measurement in the
Federal Government, andjbr Other Purposes, p. 32.

3 See, for example, U.S. Office of Management and Budget, Circular A-l 1, §210.11: "Program Evaluations
and Strategic Plans," 1998.

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Budget4 directs agencies to prepare a planned schedule of program evaluations. According to
the GPRA, the 5-year strategic plan should contain a "description of the program evaluations
used in establishing or revising general goals and objectives." The legislation also guides the
agency to include a schedule for future program evaluations to be conducted. An October, 1998
memo from Sallyanne Harper, then Chief Financial Officer of the EPA, documents the Agency's
expectation that programs will conduct program evaluations as part of GPRA implementation,
and provides basic guidelines for conducting such evaluations.

1.3 THE HAZARDOUS WASTE DELISTING PROGRAM

EPA uses a formal assessment process to determine whether certain industrial wastes should be
placed on a list of "hazardous wastes." These determinations include wastes from specific
industrial processes or particular chemical formulations. Any waste that meets the listing
description (regardless of its specific chemical composition) is a listed hazardous waste, and is
regulated under RCRA Subtitle C. Those regulations include requirements for specific waste
handling procedures, from generation through storage, treatment, and disposal.

Congress and EPA recognized, however, that listing wastes incurs the possibility of regulating
wastes which do not truly pose a threat to human health or the environment. A facility may
have a process or raw material that produces a waste with different attributes than others in the
listed group. In other cases, waste treatment techniques may remove or destroy hazardous
constituents. For example, a facility in Indiana was granted a petition to delist wastewater
treatment sludges from an electroplating process, after demonstrating that concentrations of
specific constituents in the the sludges were not large enough to present significant risk from
disposal.

The RCRA statute5 and regulations, therefore, also provides for a process to remove, or "delist", a
waste generated at a facility from the list of hazardous wastes. This delisting process is initiated by
the person generating the waste, who prepares a petition for delisting the waste. The petition
provides information about the waste, including its chemical composition, to demonstrate the
rationale for delisting the waste. The petition is reviewed by the appropriate regulatory agency
(either EPA or a state hazardous waste regulatory agency which has been authorized to grant
delisting petitions) to determine whether the waste should continue to be listed as hazardous.6
This determination is subject to notice and comment before a final decision is made.
4 U.S. Office of Management and Budget, Circular A-11, §210.11: "Preparation and Submission of Strategic

Plans," 1998.

5 §3001(1).

6The process is explained in regulations at 40 CFR 260.20 and 260.22, and in Petitions to Delist Hazardous
Wastes: A Guidance Manual, Office of Solid Waste, 1993.

« 5 »

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To gain a better understanding of the operations of the delisting program, this study employed a
tool called a program logic model. A program logic model is a kind of input/output model of a
program's operations. Figure 1 presents a simplified logic model of the waste delisting program.
The steps in the delisting process are shown down the center of the diagram. These steps
represent

•> inputs,
•> outputs (work processes and results), and
» outcomes (final results of the outputs)

of the delisting processes. In addition to these steps, the model also shows:

•> objectives: desirable attributes of the process, outputs, or outcomes.
* contextual variables: factors exogeneous to the Agency's performance of outputs that can
affect the degree to which process objectives are successfully met.

The following is a description of the delisting program, using these terms of program logic.

INPUT: Hazardous waste generators prepare petitions and send them to the EPA.

Process objective: Ensure that generators are aware that a waste can be delisted if
they can demonstrate that it should not be regulated as a hazardous waste.

OUTPUT 1 Agency staff review the applications for completeness, according to criteria
in the delisting manual7.

Process objectives: The review should be speedy; petitioners should not be left
waiting too long for a decision.

Contextual Variables: The speed of the review and decision process is dependent
on a number of variables, including the complexity of the applications submitted,
time needed for the petitioner to submit additional materials, and the budget and
FTE time available for the task. Other factors outside of EPA control, which can
affect the degree of achievement of the objectives, include the nature and extent
of public comments on proposed delisting decisions, and any legal challenges that
might ensue.

OUTPUT 2 The next output is a decision to either reject or accept the delisting
petition; that is, the decision is to either retain the hazardous status of the waste, or give it
a new non-hazardous status. This initial decision is subject to notice and comment, and
then a final decision is reached and published.
7USEPA Office of Solid Waste, "Petitions to Delist Hazardous Wastes: A Guidance Manual", March 1993.

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Delisting Program Logic Model

r ,. . _ ,. Ccnts
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Contextual Variables: The risk assessment is sufficiently conservative to cover
actual post-delisting waste management. Management of delisted wastes should be
no more risky than the management scenarios assessed.

OUTCOME 2 If the waste is allowed to exit Subtitle C regulation, a secondary outcome
follows: resources previously devoted to managing that waste as hazardous can be freed up
for other uses.

1.4 EVALUATION OF THE DELISTING PROGRAM

1.4.1 Why Evaluate the Delisting Program?

The delisting program has faced changes recently, which makes it a good candidate for
program evaluation. Among these changes:

* Responsibility for review of petitions and issuing decisions on delistings was delegated to
EPA's regional offices in October, 1995. Until that point, these functions had resided in
the Office of Solid Waste (at EPA headquarters) since the beginning of the program. This
change suggests that a process evaluation might be appropriate, comparing the
implementation of delisting by headquarters and regional offices.

» In 2000, responsibility for national coordination of the delisting program was also
delegated from OSW, this time to the Region 6 delisting staff. This change in program
operations also tends to recommend a process evaluation.

•> In 1999, EPA proposed revisions to the "mixture" and "derived-from" rules, which provide
another way to remove low-risk wastes from Subtitle C regulation. EPA is also working on
a Hazardous Waste Identification Rule (HWIR), with regulatory standards identifying
wastes that are low-risk. This regulation, once fully implemented, will provide an
alternative means for industry to have these wastes removed from Subtitle C regulation.8
In light of this initiative, it seems reasonable to conclude that EPA should gain a better
understanding of the delisting program, in order to better understand how it might work
with HWIR. Will delisting be redundant? What roles will delisting and HWIR play, and
how can EPA use the tools together to get more effective environmental regulation?
8See http://www.epa.gov/epaoswer/hazwaste/id/hwirwste/index.htm for more information on HWIR
and the mixture and derived-from rules.
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What might be the best type of evaluation for the delisting program?

There are three basic types of program evaluations:

1) Formative evaluations are conducted in the early stages of development (or implementation) of
a program. They are intended to get an early indication of any problems with the program, and
the likelihood of success.
2) Process evaluations focus on the operations and implementation of a program.
3) Outcome evaluations focus on the results, consequences, or products of a program.

The type of evaluation performed depends on the situation of the program, and the type of
information that will prove useful to program managers.

The delisting program, having been carried out for 20 years, is probably not a candidate for a
formative evaluation. The delegations of responsibility to Regional staff advanced the possibility
of a process evaluation, looking at changes in delisting functions and operations. A process
evaluation would also seem to be of limited usefulness, since EPA's Inspector General has recently
completed a study of the process and operations of the delisting program9.

After extensive consultation with managers and staff in both OSW and regional offices, OSW
decided that this evaluation would be most useful it if focused on the outcomes and impacts of the
federal delisting program.10 Rather than focus on the mechanisms for conducting delistings,
therefore, this study examines how the program has functioned, and what has been gained by the
operation of the delisting program. This "big picture" focus also results in findings that provide
useful information for assessing the future direction and management of the delisting program.

There is a great deal to be learned through this evaluation. By examining the outcomes of the
program, EPA gains an understanding of what impacts the program has on industry, on waste
management, and on the economy overall. The evaluation also provides RCRA managers with
information to make decisions about the delisting program itself, and about interactions with
other deregulatory initiatives (e.g., HWIR). This information should be useful as EPA continues
working to tailor regulatory requirements to meet the risks addressed.
'USEPA, Office of Inspector General, RCRA Hazardous Waste: RCRA Delisting of Hazardous Waste.
Report #E1DSB7-11-002108700001, June 1998.

'"Although some states are authorized to delist wastes, this evaluation focuses on EPA's
program.
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1.4.2 What are the Outcomes and Impacts of the Delisting Program?

The principal outcomes of the delisting program are the cost savings and economic impacts that
result from shifting wastes from Subtitle C management to less stringent Subtitle D management
standards. This report looks at three different categories of outcomes of the delisting program:

•> Cost savings and aggregate economic impacts
•> Impacts of delisting on the environment
* Impacts of delisting on the RCRA hazardous waste management program

The report also examines the distribution of these impacts, on different industries, geographic
areas, and types of businesses.

1.4.3 Is the Delisting Program Fulfilling Its Goals?

In many cases, an important part of an outcome evaluation is an assessment of the performance of
a program against some kind of standard. Is the program making good progress toward strategic
goals and objectives? Are there any deficiencies in performance because of program
implementation?

For the delisting program, this is not an easy question. The delisting program doesn't have
strategic goals, in terms of what it hopes to accomplish in outcomes; EPA does not set targets, for
example, of numbers of wastes to be delisted each year. Goals are operational and process-oriented
(as in the process objectives noted in section 1.3), but driven by the receipt of applications, not
by strategic goals. It is difficult to set goals for an essentially reactive program, which aims at
processing applications as they are received.

An overall goal for federal regulatory operations, however, is to maximize regulatory efficiency.
To do that, EPA attempts to make sure that the burden placed on the regulated entities is no
heavier than necessary to achieve regulatory goals of protection of human health and the
environment. n To the extent that the delisting program is promoting efficient regulation and
efficient use of resources, it is meeting that overall goal of federal regulation. Section 2.2 measures
how well EPA is meeting that goal.

1.5 METHODOLOGY OF THE EVALUATION

The evaluation question asks: What are the economic, environmental, and programmatic impacts of
delistings? The evaluation design uses a simple "before-and-after" framework to assess what
changes have come about as a result of the delisting program. The evaluation design rests on the
assumption that without the delisting, the waste would continue to be generated and managed
under RCRA Subtitle C.
'See "Regulatory Planning and Review", Executive Order 12866, September 30, 1993.
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1.5.1 Creating the Database

EPA assembled a database listing all the delisting applications granted by the EPA (not including
those granted by state governments) between calendar years 1980 and 1999. Some of the
information had been kept by the delisting program, either in paper files or in the Delisting
Petition Data Management System. This database had been discontinued in 1995. Other data
were taken from the Federal Register notices announcing each proposed and final delisting
granted.

Data elements in the current database include:

1.5.2 Assessing the Data

Using the database, we calculated total volumes of waste delisted. These volumes were calculated
using the following assumptions:

- We assumed that savings from delisting begin to accrue in the year after the exclusion
takes effect. This likely results in understatement of savings, since there could be some
savings in the same year as the exemption is granted.

- We assumed that waste generation in the absence of the delisting would have continued
indefinitely at the same quantities.12 This may lead to overstatement of savings, since
companies may have ceased generating these wastes or may have implemented pollution
prevention measures to reduce the quantity of waste generated. Conversely, it could lead
to understatement, since increased production might have led to increased quantities of
the wastes being generated13.
12This assumption was not made for wastes which were given "one-time" standard exclusions. These
delistings are granted to a quantity of waste generated in the past, and are not applicable to any subsequent wastes
generated. We did not assume that these wastes were generated or delisted in any other year.

13This assumption is especially tricky with one of the wastes, granted to Conversion Systems,
Inc. for K061. There may be much larger amounts of K061 that have been delisted since the original
amount, since the delisting was predicated on a particular treatment regimen.

«11 »
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- We assumed that after delisting, generators manage their wastes as if they were Subtitle
D industrial wastes. However, there may be state requirements for management of these
wastes, even in the absence of being listed as hazardous waste. To the extent that such
requirements exist, the costs savings from delisting are overestimated.

Using data on unit costs of waste management under Subtitle C and Subtitle D, we also calculated
the total cost savings attributable to delistings, on an annual basis and cumulatively. Results of
the analysis are presented in Chapter Two.
12:
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CHAPTER TWO:
RESULTS OF THE EVALUATION
This chapter presents the results of the data analysis, and conclusions from the data. It includes
basic statistics on delistings, the economic and environmental impacts of delistings, and some data
on the distribution of those impacts.

All of these statistics refer only to the federal delisting program. Incorporating the results of state
delistings would lead to different results for most of these categories.
2.1 DESCRIPTIVE STATISTICS

Over the 20-year period from 1980 through 1999, delistings were granted to a total of 136
separate waste streams, generated at 115 separate facilities14. Table 1 below gives an overview of
the individual waste streams delisted.

As-generated process wastes make up fewer than 15% of the waste streams; the majority were
treatment residuals and wastewaters. Wastewater treatment sludges alone account for more than
half the waste streams. Although only 4% of the waste streams were wastewaters, they are large
volume wastes. 36 of the streams (26%) of the waste streams were not part of an on-going
process, but only generated one time.

Table 2 shows the most frequent waste codes present in delisted wastes15. By far the most
common code is F006, found in 51 waste streams. F019, F003, K071, and F005 were also quite
common.
Delisted K061 waste streams were quite large, averaging 81,600 tons each. K071 wastes, on the
other hand, averaged only 1,800 tons per year.
14 One delisting was granted and then later revoked, so there were actually 137 wastes delisted.

"The numbers of waste streams appear higher than in Table 1 because many wastes carry multiple codes.

« 13 »
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Table 1
OVERVIEW OF DELISTED WASTE STREAMS

Type of Waste

F001-F005
Solvent Wastes
F006,F009,F019
Electroplating
Wastes
F020-F028
Dioxin Wastes
K048,K051
Petroleum
K060,K062
Steel
K071.K106
Chlor-Alkali
Miscell

TOTAL

% of Waste
Streams
Total

21
(15%)
69
(51%)
9
(7%)
3
(2%)
10
(7%)
12
(9%)
12
(9%)
136
(100
100%

Wastewater
• ' s-.

Process
Wastes

14%

WWT
Sludges

54%

Other
Treatmen
t
Residuals
6

25%

Contaminate
d Media

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Table 2
MOST FREQUENT WASTE CODES PRESENT IN DELISTED WASTES
Waste
Code
F006
F019
F003
K071
F005
K062
F020
F002
K061
K002-K008
No, of Streams
51
34
16
13
12
8
7
7
6
5
Average Size of Stream (tons)
4,500
5,400
14,000
1,800
13,800*
19,200
1,500
19,700*
81,600
25,400
*Figures for F005 and F002 exclude the single outlier wastestream described below in section 2.1.1.
2.1.1 Total Quantities of Waste Delisted

The waste quantities discussed in the previous section only show generation in a single year. In
the absence of the delisting program, however, these wastes would have continued to have been
managed under Subtitle C management. For example, in 1985, a waste stream of sluiced bottom
ash sludges was delisted; this waste is generated at an annual rate of 19,100 tons. Using the
assumption of continuous generation (discussed in section 1.5.2), this analysis estimates that an
aggregate total of 286,500 tons of this particular waste stream had been taken out of subtitle C
management through 1999.

Cumulatively, a total of 45 million tons of waste has been excluded from subtitle C
requirements. Over 80% of that volume is wastewater, with 32 million tons attributed to one
waste stream at one facility.16
6This stream, the single largest volume waste delisted, consisted of scrubber effluent wastewaters.
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2.2 ECONOMIC IMPACTS OF THE DELISTING PROGRAM

2.2.1 Administrative Costs
A total of 906 delisting petitions have been submitted to EPA between 1980 and 1999. Table 3
provides a breakdown of the disposition of those petitions — those which were granted, those
which were denied, and those which never completed the full review process.

Each delisting petition submitted to EPA incurs a cost to the petitioner (to gather the necessary
data and prepare the petition) and to the government (for review of the petition and analysis of
the data). For petitions that
are incomplete, or that never
complete the review process,
these costs are lower.
Table 3
DELISTING ACTIVITY, 1980-1999
Si ATUS
WITHDRAWN
DENIED
REFERRED TO STATE
INCOMPLETE / IN PROCESS
RULE-MAKING PETITION/
DISMISSED*
GRANTED
TOTAL
NUMBER OF
PETITIONS
503
108
32
122
26
115
906
PERCENT OF
, TOTAL ' • •
56%
12%
4%
13%
3%
13%
100%
*These petitions were all listed as "dismissed, " indicating that the
Agency staff decided that the petition did not warrant further review .
EPA has previously estimated
the recordkeeping burden for
a petitioner as well as the
burden to the government for
review of a delisting
petition.17 This report
estimated that the cost to the
EPA for reviewing a petition is
approximately $28,000. The
report estimated the cost to a
petitioner at approximately
$82,000.18 Because an earlier
report to EPA19 suggested that
petitions sometimes cost as
much as $100,000 or more, we
"Supporting Statement JOT EPA Information Collection Request Number 1189.05, Identification, Listing, and

Rulemaking Petitions, 16 January, 1998.

18 We assumed that a petitioner incurs all the costs of preparing a petition, even for those petitions which
were withdrawn or mooted.
"industrial Economics, Inc. "Final Analysis of Delisting Program Policies and Procedures", 17 February
1992.
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conducted a sensitivity analysis and estimated petitioners' costs using that per-petition cost
estimate, as well.
Finally, we calculated the net present value of the aggregate administrative costs by applying a
discount rate. Discounting reflects the time value of money, in that the value of a dollar lost in
future years is greater than a dollar, since the capacity to invest and earn extra income is also lost.
The discount rate represents the displaced investments and consumption that could have been
made in the absence of spending these funds on preparing and reviewing delisting petitions.

Table 4 presents the administrative costs of conducting the delisting program20. The total
administrative costs associated with this twenty year period of the delisting program ranges from
$107 million to $226 million. The costs to petitioners ranges is estimated to be 70-85% of that
total.
Table 4
CUMULATIVE ADMINISTRATIVE COSTS OF DELISTING PROGRAM
(millions of dollars)

Low-End
High-End
Government
Costs

22.14
22.14
Petitioner
Costs

74.01
148.02
Total

96.15
170.15
7%
discount
rate21
112.93
225.86
2% discount
rate21 . • •

107.15
189.55
2.2.2 Costs of Treatment and Disposal

The most obvious and significant impact of the delisting program is the reduction in the costs of
waste management. Waste management costs under RCRA Subtitle C (hazardous waste
standards) are usually significantly more expensive than waste management under RCRA Subtitle
D (non-hazardous waste standards). Where these wastes were being managed more stringently
than necessary, these additional costs of waste management represent an unnecessary cost to the
economy. In economic terms, this is referred to as a deadweight loss to the economy. By
reducing these unnecessary costs, the delisting program is restoring value to the economy. These
resources can now be devoted to producing valued goods and services.
20 Discount rates are used to adjust the raw costs for the time value of money; the present value of cost

savings is higher than the nominal value of those savings in prior years. Two different discount rates are used in the

table to render the costs comparable over the twenty-year period of the study. There is not a clear consensus on
the appropriate discount rate to use in a study like this; EPA guidance suggest using a lower rate of 2-3%,
representing the social rate of return on investments, and a sensitivity analysis using a higher rate of around 7%,
which tends to reflect returns to the private entities concerned (in this case, the firms paying waste management
costs). See USEPA, GuidelinesJor Preparing Economic Analyses, 2000, Chapter 6.
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Cost savings in treatment and disposal are determined by assessing the costs of treatment and
disposal for each waste stream for each year after the delisting became effective, under subtitle C
and under subtitle D. The analysis develops two scenarios: waste management in the baseline
scenario (with a delisting granted), and in a "without-delisting" scenario. Without delisting,
these wastes would have incurred the higher Subtitle C costs of treatment and disposal. The
difference between the costs in these two scenarios represent the cost savings in treatment and
disposal costs attributable to the delisting.

Waste Management Techniques

This requires first associating waste management techniques (treatment and disposal) under both
Subtitle D and Subtitle C. In many cases, these techniques were already specified in the delisting
petition or other records. In other cases (where not specified) customary practices under Subtitle
D were assumed for the waste streams. Unless other information was available, we assumed the
same disposal practice (e.g., surface impoundment, landfill, incineration) would be used pre- and
post-delisting.

Where not otherwise specified, required treatments under Subtitle C were assumed for pre-
delisting management. Land Disposal Restrictions (LDRs) typically required additional treatment
of wastes prior to land disposal, or encouraged a switch to an alternative technology. The
analysis takes the LDRs into account by assuming that treatment would be required prior to land
disposal once the relevant LDR took effect. If wastes were delisted prior to the effective date of
the relevant LDRs, we assumed (in the "without-delisting scenario") continuation of the existing
treatment up until that year, and then LDR requirements after that year. We identified the year
in which LDRs took effect based on the waste codes reported for each delisted waste stream The
earliest effective date was selected for wastes with multiple waste codes. For example, a waste that
included F005 in its list of waste codes was assigned an LDR effective date of 1986, even if other
waste codes reported for that waste stream had later LDR effective dates. In the absence of a
delisting, management under LDR standards was assumed to begin the year after the effective date
of the relevant LDR (e.g., the savings of avoided LDR management for a waste delisted in 1986
that includes F005 as a waste code were assumed to begin in 1987.)21

Unit costs

Each type of waste treatment is likely to either increase the quantity of waste (e.g., waste
stabilization), decrease the quantity of waste (e.g., incineration), or have no appreciable effect
21The analysis assumes that cost savings begin the year after a delisting takes effect. For one-time delistings,
cost savings occur only in the year after the delisting takes effect. Because the delistings actually took effect earlier
than the following year, this assumption tends to understate the cost savings.

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(e.g., neutralization). The residual factors shown in Table 1 indicate the residual quantity that
remains to be disposed of after treatment.22

Estimates of the unit costs of different treatment and disposal technologies are taken mostly from
EPA's recent analysis of the proposed HWIR rule, and are reproduced in Table 5.23
Table 5:
Quantity-Based Industrial Hazardous Waste Treatment and Disposal Unit Costs
Item
1
2
3
4
5
6
7
8
9
10
11
Waste Treatment
or Disposal
Method
Deactivation
Liquid
Incineration
Neutralization
HTMR
Mercury Retort
Stabilization
Vitrification
Underground
Injection
Acid
Regeneration/
Recycling
Subtitle C
Disposal
Subtitle D
Disposal
Residual
Factor
0.01
0.25
1.01
0.0
1.0
1.5
1.5

'. s'47o* • • •;
tons/year
$820
$301
$270
$191
$856
$200
$230
$0
$0
$130
$50
• s 4,700
tons/year
$820
$301
$34
$191
$856
$150
$230
$0
$0
$130
$50
s 47,000
tons/year
$200
$301
$4.48
$191
$446
$50
$230
$0
$0
$130
$50
n 470,000
tons/year
$200
$301
$0.73
$191
$194
$23
$230
$0
$0
$57
$50
(1999$ average cost per ton, depending on annual quantity treated by facility)
Source: U.S. EPA Office of Solid Waste, Economics, Methods, & Risk Assessment Division, Economic
Assessment of the USEPA's 1999 Proposed Hazardous Waste Identification Rule (HWIR), 29 October 1999
Exhibit IV-14.
22For example, stabilization results in an increase in the waste quantity to be disposed by a factor of 1.5.

23U.S. EPA Office of Solid Waste, Economics, Methods, & Risk Assessment Division, Economic Assessment of the USETA's

1999 Troposed Hazardous Waste Identification Rule (HWIR), 29 October 1999.
19;
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Other unit cost figures include:

Incineration24:

Liquids (comparable fuels) $70/ton
Liquids (highly contaminated) $301/ton
Sludges (less contaminated) $320/ton
Sludges (highly contaminated) $630/ton
Solids (less contaminated) $683/ton
Solids (highly contaminated) $128I/ton

Upgrading from surface impoundments (Subtitle D) to Subtitle C storage tanks25: $0.40 /ton

These unit costs largely derive from 1999 estimates. Although the unit costs are adjusted for
inflation for each year in which they are applied, this formula does assume that unit costs remain
approximately the same over the twenty-year period of the study. Anecdotal evidence suggests
that costs of hazardous waste management techniques have actually fallen at a more rapid pace
than inflation. Waste management costs from the 1980's were actually higher than current
prices, even in real terms. These inflation-adjusted cost savings are therefore probably an
underestimate.

Assessment of Total Cost Savings

Using the aforementioned data and assumptions, each waste stream is assigned a cost of
management post-delisting under Subtitle D (as actually required) and under Subtitle C (as
would have been required in the absence of the delisting). Cost savings (the difference between
the actual scenario and the hypothetical without-delisting scenario) were then calculated for each
post-delisting year through 2000 (the first delistings took effect in 1985).26
24Unit costs for incineration taken from from Exhibit 3-lof Assessment of the Potential Costs, Benefits, S^Other
Impacts of the Hazardous Waste Combustion MACT Standards, USEPA, Office of Solid Waste, July 1999.

25 Unit cost for storage tanks based on estimate of costs (capital costs plus annual operation and
maintenance) for high volumes of waste, assuming 30-day storage period. Source: Regulatory Impact Analysis:
Application of Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes; USEPA, Office of Solid
Waste, April 30, 1998. Exhibit F-14.

26It is generally the practice to convert all prices to 1999 dollars, to account for lower prices in earlier

years. This practice works with the general assumption that prices of the particular commodity follow general
trends of inflation. However, our data suggests that prices of hazardous waste treatment do not follow the general
trend of inflation; in fact, prices are lower (even in nominal terms) than they were in earlier years. Therefore, we
have assumed 1999 prices for all years of the evaluation. In practice, this probably means that we are understating
the cost savings.

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Table 6 presents cost savings for each
year, as well as aggregate cost savings.
The cost savings that accrue in 2000
- $105.4 million — will continue to
accrue every year — even if no
further wastes are ever delisted27.
Additional delistings will increase the
total cost savings. From the inception
of the delisting program through the
year 2000, cumulative gross cost
savings attributable to the delisting
program range between $1.36 billion
and $2.49 billion™

These cost savings are probably
underestimated, because of cost
savings not included. Besides savings
in treatment and disposal costs, there
are other costs which may also be
saved. Specifically, we have not
accounted for

•> Potential savings in
transportation costs. This
omission tends to
underestimate the cost
savings. Not only is
transportation of non-
hazardous wastes less
expensive per mile, but it is
likely that these wastes would
be transported shorter
distances, inasmuch as
industrial waste disposal
facilities are more widespread
than permitted Subtitle C
disposal facilities.
Table 6
Cost Savings per Year
(individual years, not cumulative)
Year Cost Savings , ,
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
Cumulative Net
Present Value
at 7% discount rate
$749,040
$5,096,626
$19,492,938
$22
$42
$51
$69
$73
$78
$78
$78
$96
,126,162
,180,857
,866,658
,882,661
,683,088
,043,510
,592,062
,817,442
,974,128
$164,566,547
$98
$98
,126,193
,126,193
$105,400,863
$2,490,052,373

"Based on the assumptions of continuous generation of equal volume of the waste.

28All cumulative costs in this analysis are presented in real terms, using year 2000 dollars.
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•> Potential savings in administrative costs, such as compliance with manifest requirements.
For some facilities, delisting may have reduced or eliminated the burden of Subtitle C
permitting requirements; the cost savings in those cases are significant. We did not
collect data which would enable us to quantify these savings.

2.2.3 Net Cost Impacts

Section 2.2.1 discussed the costs of administering the program, while section 2.2.2 discussed the
cost savings resulting from the program. The cost impacts of the delisting program are presented
in Table 7. The cost savings in treatment and disposal costs overwhelm the administrative costs
of conducting the program by an order of magnitude. In summary, over the twenty-year period
examined, the delisting program has resulted in a net cost savings to society in the range of
$1.17 billion to $2.38 billion.
Table 7
CUMULATIVE COSTS, COST SAVINGS, AND NET COST SAVINGS
(millions of dollars)
Discount
Rate

7%
2%
Admin. Costs,
Low-End

$112.93
$107.05
Admin.
Costs, High-
End
$225.86
$189.56
Treatment
& Disposal
Cost Savings
$2,490.05
$1,357.57
Net Cost
Savings,
Low-End
$2,264.19
$1,168.01
Net Cost Savings,
High-End

$2,377.12
$1,250.52
2.3 ENVIRONMENTAL IMPACTS OF THE DELISTING PROGRAM

A program evaluation should provide information that is useful to help manage the program; even
a retrospective evaluation (such as this one) can help guide the program into the future. EPA
staff who work on delisting were consistently interested in exploring the environmental
consequences of the delisting program.

A basic premise of the delisting program (see the process objectives in the program logic model) is
that delisted wastes do not pose any significant threat to human health or the environment, even
when not managed under the strict guidelines of RCRA Subtitle C. This goal is accomplished
through chemical analysis and fate and transport modeling of wastes, prior to granting a delisting.
In order to be delisted, this analysis must demonstrate that the waste:

•> Does not meet the criteria for which it was originally listed.
•> Does not exhibit any of the hazardous waste characteristics.
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•> Does not exhibit any other factors (including additional constituents) which might cause
the waste to be hazardous.

A delisting determination is based on reasonable worst-case scenarios, to ensure that there is no
reason that the waste should remain under RCRA Subtitle C regulation.

Are there delisted wastes that nevertheless might pose environmental problems? Unfortunately,
an environmental assessment of previously delisted wastes was beyond the scope of this program
evaluation. We are able, however, to provide some qualitative assessment of the environmental;
impacts of the delisting program.

2.3.1 Environmental Releases

In 1997, a delisting had to be revoked when EPA discovered that our risk assessment assumptions
did not fully capture the risk possibilities of a waste stream.29 The waste which had its delisting
revoked posed a greater threat of release of constituents than EPA originally estimated. This re-
assessment occurred because the waste was managed in a more alkaline environment than the
landfill transport models anticipated, resulting in a different release profile. EPA has already
reviewed previously delistings to determine if this alkaline environment could be a similar problem
with other waste streams, and concluded that this was a problem unique to the chemical
characteristics of this waste stream.

What is the likelihood that other delisted wastes are producing environmental releases of
concern? The fate and transport models that have been used in the program use very protective
assumptions in projecting exposure to constituents. It would seem that the opportunities for
damage are probably limited to

* Significant changes in the waste characterization (volume, constituents,
constituent concentrations) from that reported in the original petition. Waste
generators are supposed to notify EPA if such changes occur; EPA efforts to check
up on previously delisted wastes have been minimal, but have not discovered such
changes.
* Situations, like the revoked delisting, where there is some undiscovered flaw in the
waste and risk assessment methodology.

The Agency is taking steps to limit the possibilities for harmful environmental releases in the
future, and to facilitate review of the consequences of disposal of delisted waste streams. In July,
1998, EPA established a conditional delisting policy, to ensure that delisted wastes are managed in a
manner consistent with the risk evaluation that supports the delisting decision. At the same time,
the Agency established a delistingreopener mechanism, for immediate response to new
29The exclusion for this waste stream, number ARD0063S4161, was repealed on December 1, 1997. For
information on the action, see the Federal Register notice at 62FR Number 147, July 31,1997.

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information or data indicating conditions exist that may alter the Agency's position on the
approval of a delisting.

Although improving environmental quality is not the primary rationale for the delisting program,
it may provide some improvement in environmental quality, as well. There is anecdotal evidence
that some facilities have engaged in extra treatment of their wastes (beyond what is legally
required) in order to reduce the toxicity of their wastes in order to become eligible for delisting.
This additional treatment would provide some additional protection against release of
constituents to the environment.

Delisting may provide other environmental benefits, as well. In their review of the delisting
process, EPA's Inspector General noted that some companies function with an "environmental
programs budget." When the costs of waste management decline, these companies have
redirected these funds into other environmental projects.

In summary, EPA does not have evidence of releases or lack of releases from delisted waste
streams. However, given a strict risk assessment process (which has been made progressively
more accurate), the Agency has little reason to believe that these streams are causing
environmental problems. The Agency has also put additional measures in place to reduce the
likelihood of releases.

2.3.2 Recycling

Delisting wastes may have an impact on recycling quantities. Although such impacts are not
relevant to the delisting decision itself - which is exclusively risk-based - it is worthwhile
examining how delisting has affected recycling.

To some extent, the high cost of hazardous waste treatment and disposal under Subtitle C has
provided an incentive for firms to recycle wastes and to recover resources from wastes.
Intuitively, therefore, it would seem that delisting - which reduces the cost of treatment and
disposal - might have a negative impact on hazardous waste recycling. One particular delisting
may have been very significant in inhibiting recycling. That delisting, granted in 1995,
exempted 306,000 tons of chemically-stabilized electric arc furnace (EAF) dust. According to an
industry study30, over 85% of the EAF dust generated in the US had been recycled, primarily for
zinc recovery. Such recovery accounted for approximately 30% of domestic zinc production,
before the delisting action. This study suggested that the delisting would divert those wastes from
resource recovery into chemical stabilization followed by disposal in Subtitle D landfills. As of yet,
EPA has not formally assessed the impact of this delisting on zinc recovery from EAF dust wastes.
Although the current database contains information on pre-delisting and (planned) post-delisting
waste management, there is no clear indication of other wastes that have been diverted from
recycling to waste disposal.
"Arthur D. Little, Inc., "Electric Arc Furnace Dust - 1993 Overview" (Cambridge, July 1993).

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On the other hand, many waste generators have told EPA that the "stigma" associated with
hazardous wastes impedes recycling, since treaters and recyclers are often unwilling to acquire the
liabilities associated with handling hazardous waste. Delisting wastes, therefore, may increase
quantities recycled. We have information on one case where delisting apparently promoted
waste recycling. The delisting allowed the facility to convert a 12,000 ton waste stream of lagoon
sludges to be used as fertilizer. Prior to the delisting, the wastes were being incinerated.

2.3.3 Opportunity Costs to EPA

Another way of looking at the cost of the delisting program is through the concept of
"opportunity cost", i.e., alternative uses for the resources consumed in running the delisting
program. In this sense, the cost of staff time spent on delisting is to view it as "other regulatory
work" that is forgone in order to work on delistings. If EPA could have used those resources for
an environmental protection program, what additional protection could they buy?

Administrative costs of the program over 20 years range between 107-226 million dollars. EPA's
expenditures probably represent no more than 15-30% of that total, or 16 to 68 million dollars. If
spent on other hazardous waste programs, that could have represented a certain number of facility
investigations, enforcement actions, permits, or other regulatory actions. Assuming those actions
would have led to some degree of improvement in environmental quality, EPA has forgone such
improvements. Those improvements, of course, could only come at the expense of the billions of
dollars in social costs that delisting has saved, but it is worthwhile to be aware of the budgetary
tradeoffs made.

2.4 DISTRIBUTION OF IMPACTS

In addition to looking at the aggregate cost savings attributable to the delisting program, we can
also examine the distribution of those impacts. What are the economic impacts on specific
industries or areas of the country?

2.4.1 Geography

Geographically, the most federal delistings have been granted in in the southeast and
midwest (28 delistings granted in each of EPA Regions 4 and 5). The states most affected are
Ohio (10)
New York (9)
* Tennessee (9)
* Indiana (8)
•> Pennsylvania (8)
» Alabama (7)
» Arkansas (7)
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This represents only the distribution of EPA-granted delistings; 18 states have been
authorized to grant delistings on their own.31

2.4.2 Small Businesses

It has been suggested that smaller business are prevented from obtaining delistings because of the
the high cost of preparing a petition.32 This report has shown, however, that the savings in waste
management costs readily make up for the administrative costs of preparing a petition. At least
10% (12 of the 115) of the generators who have received delistings are Small Quantity
Generators (or less). Although this is not a perfect proxy for business size, larger firms tend to be
larger quantity generators.

2.4.3 Industries Affected

We also reviewed the extent to which different industries have been impacted by the delisting
program. The following industries are of particular interest:

Plating and Metal Polishing/Coating: This industry has been a major beneficiary of
delisting, as F006 and F019 waste codes are the most common wastes to be delisted.

Chloralkali: This is a small industry, which only numbered about 20 firms overall in the
late 1980's. 12 wastestreams associated with this industry were delisted, related to 8 firms.

Blast Furnaces and Steel Mills: There were 12 delistings associated with this industry. At
least 1.5 million tons of K061 have been delisted, deriving from steel production at mills
using electric arc furnaces.

Pharmaceutical: Of the 45 million tons of waste delisted, 32 million tons are attributable
to one waste stream at a single pharmaceutical facility in the midwest. This waste,
consisting of scrubber effluents, is generated at a rate of nearly Smillion tons per year.

Aluminum plating is another industry which received several delistings.

In general, the larger volume generators of hazardous wastes (e.g., chemical industry, metals) are
well represented in the set of delistings. One exception to this correlation, however, is the
petroleum industry; although a large generator of wastes, only 3 refineries got delistings. It is not
31 The list of states fully or partially authorized to delist wastes is: New Jersey, Delaware, Kentucky, North

Carolina, Mississippi, Alabama, Georgia, Michigan, Illinois, Louisiana, Nebraska, North Dakota, South Dakota,
Wyoming, Utah, Colorado, Oregon, and Idaho.

32See USEPA, Office of Inspector General, RCRA Hazardous Waste: RCRA Delisting of Hazardous Waste,
Report #E1DSB7-11-002108700001, June 1998.

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clear if there is a specific reason why this industry has not made more use of delistings. One
possibility is that there is either less variation among wastes in refineries, or the listing description
more precisely captures the hazardous nature of their wastes.
:27;
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CHAPTER THREE:
RECOMMENDATIONS AND CONCLUSIONS
3.1 RECOMMENDATIONS

3.1.1 Regulatory Impacts Analysis

In reviewing Federal Register notices for delistings, we did not find any RIAs associated with these
regulatory actions. Often, these notices indicate that since the rules don't meet the criteria of
Executive Order 12866 (or predecessor applicable Executive Orders) as "significant regulatory
action", then "no assessment of costs and benefits is necessary."

Although such an assessment is not required by the Executive Order, it is often a good idea to
undertake such an assessment. It is always a good practice in making public policy to be aware of
the impacts of a regulatory action, whether required by Executive Order, or statute, or not at all.
This evaluation has demonstrated that such an analysis is particularly helpful for delistings, to
help understand the value of the program overall. As RCRA program management continues to
"fine tune" hazardous waste management requirements, assessing the impacts of delistings can be
valuable in the Agency's overall effort to better match risks with regulatory requirements.

3.1.2 Evaluation of the Listing Program

Delisting exists because our listing methodology captures a large category of wastes, and some
wastes are caught in the net which are not necessarily risky. The earliest EPA listings involved
risk assessment methodology which tended to be far more cautious than methodologies used
today. Therefore, it would seem, these early listings were more likely to have captured low-risk
wastes than the later listings, which used more precise and refined risk assessment methodology.
(Later risk assessments may been more conservative in some respects, especially in evaluating
indirect effects and ecological risks.) The methodology and results of this evaluation could be
very helpful in undertaking an evaluation of the hazardous waste listing program.

3.2 CONCLUSIONS

The environmental impacts are not as clear, although EPA does not have reason to suspect that
delisted wastes are causing environmental problems.
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As one of the first program evaluations undertaken by the RCRA program in response to GPRA,
there is also clear value to this evaluation study itself. Not only has it helped the RCRA program
understand the process of program evaluation, it has also helped us understand the nature of the
"value" of a program. This evaluation have demonstrated that benefits can take many forms, not
just risk reduction. A program like delisting demonstrates its value in terms of reduction in
economic losses, and concomitant improvement in human welfare.

The delisting program has also helped refine standards for the RCRA hazardous waste
management program itself, by providing information and feedback on our listing descriptions.
Information received in delisting petitions has helped the Agency refine the "listing description",
that is, the characterization of the hazardous nature of a class of industrial wastes.
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