### RE: Hazardous waste generator standards

Tom Baker [tom.baker@veoliaes.com]

Sent: Tuesday, August 27, 2013 12:22 PM

To: David Metz

David

– here are some brief answers to your ques Ɵ ons. Feel free to call me if you need addi Ɵ onal insight.

1. Low end cost es Ɵ mate would be just a few dollars for a generator to buy new labels to use from a vendor (i.e.

JJ Keller or Label Master) and s Ɵ ck them on their drums. Alterna Ɵ vely, they may wish to simply write the

required informa Ɵ on directly on the container to sa Ɵ sfy the marking requirement. So these costs are quite

low and would just require some Ɵ me to put the proper marks on the container. Maybe $100 per small

generator?

2. Typically incinera Ɵ on costs are based on a per pound basis that take into account the handling and treatment

costs speci fi c to the waste. Larger volumes in bulk quan Ɵ ty may be priced lower per pound than smaller

quan ƟƟ es due to the ease of handling one large container vs many smaller containers. Discounts may be

applied for larger generators that provide substan Ɵ al quan ƟƟ es of wastes but those discounts vary widely

based on the types and volumes of wastes.

Hope this helps.

Tom Baker

Director, Environment & Transporta Ɵ on

Veolia ES Technical Solu Ɵ ons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691

‐ 7330 o ffi ce

(908) 303

‐ 1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e

‐ mail message from Veolia ES Technical Solu Ɵ ons, L.L.C. is for the sole use of the intended recipient(s) and may contain con fi den Ɵ al and privileged

informa Ɵ on. Any unauthorized review, use, disclosure or distribu Ɵ on is prohibited. If you are not the intended recipient, please communicate with the sender by

reply e

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From: David Metz [mailt o:DMetz@indecon.com]

Sent: Tuesday, August 27, 2013 10:53 AM

To: Tom Baker

Subject: RE: Hazardous waste generator standards

Hi Tom,

I hope you are doing well. As you know, we’ve been compiling informa Ɵ on for the last few months to inform

an economic analysis of EPA’s requirements for hazardous waste generators. I had one follow

‐ up ques Ɵ on to

our previous conversa Ɵ on and one new ques Ɵ on where you may have some insight.

1) For large quan Ɵ ty generators, with an exis Ɵ ng computerized labeling process (either their own or

through an environmental services company), you suggested a high

‐ end cost of $25,000 for

programming and building out the tracking database. What might be the low

‐ end of this range? Do

you have a sense of what the average addi Ɵ onal cost per facility might be for adding to exis Ɵ ng labels

two items: (a) the hazards of a container’s contents (e.g., ignitable, toxic, reac Ɵ ve), and (b) other

words iden Ɵ fying the contents (e.g., paint solvent waste). RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

1 of 8 6/18/2015 7:08 PM2) Are you aware if large quan Ɵ ty generators managing their hazardous waste through incinera Ɵ on

receive bulk quan Ɵ ty “discounts” rela Ɵ ve to very small quan Ɵ ty generators (on a per ton or per drum

basis)? Can you es Ɵ mate the percentage di ff erence between what large generators pay versus what

very small generators pay for incinera Ɵ on?

Thanks again for your help.

Best Regards,

David

David Metz

Associate

Industrial Economics, Incorporated (IEc)

2067 Massachusetts Ave.

Cambridge, MA 02140

617.354.0074

www.indecon.com

From: Tom Baker [mailto:to m.baker@veoliaes.com]

Sent: Thursday, June 27, 2013 4:46 PM

To: David Metz

Cc: Kristen Taft

Subject: RE: Hazardous waste generator standards

Not an easy ques Ɵ on to respond to in par Ɵ cular due to the fact that you haven’t indicated what addi Ɵ onal

data elements will need to be placed on an enhanced label.

Assuming this is readily accessible informa Ɵ on to place on the label....on the low end a generator with only a

few satellite accumula Ɵ on containers each year could simply buy a roll of labels from a supplier for say $30

and then handwrite on them the required informa Ɵ on. Provided this is readily available informa Ɵ on the Ɵ me

to complete the label will be only a few minutes per label (less 5 minutes) so the overall costs to the generator

will be only a few hundred dollars a year at most (taking into considera Ɵ on the added labor costs).

On the high end, a generator or environmental services company with an exis Ɵ ng sophis Ɵ cated computerized

container labeling process would need to make programming changes to accommodate a new label format.

One ‐Ɵ me programming and tes Ɵ ng costs could be as high as $25,000 if the addi Ɵ onal data elements do not

already exist in a company’s waste tracking database and therefore need to be created.

I hope this helps.

Tom Baker

Director, Environment & Transporta Ɵ on

Veolia ES Technical Solu Ɵ ons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691

‐ 7330 o ffi ce

(908) 303

‐ 1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always. RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

2 of 8 6/18/2015 7:08 PMThis e

‐ mail message from Veolia ES Technical Solu Ɵ ons, L.L.C. is for the sole use of the intended recipient(s) and may contain con fi den Ɵ al and

privileged informa Ɵ on. Any unauthorized review, use, disclosure or distribu Ɵ on is prohibited. If you are not the intended recipient, please communicate

with the sender by reply e

‐ mail and destroy all copies of the original message and delete same from all computers.

From: David Metz [ mailto:DMetz@indecon.com ]

Sent: Thursday, June 27, 2013 10:00 AM

To: Tom Baker

Cc: Kristen Taft

Subject: RE: Hazardous waste generator standards

Tom,

Thank you again. We’ll certainly contemplate these costs (and any poten Ɵ al bene fi ts) in our

discussions with EPA. Without asking you to disclose any propriety informa Ɵ on, would you be able to

es Ɵ mate very broadly how much the computer labeling costs may vary between generators with

minimal data elements and one with more enhanced labels (either on a per facility per year basis, or

per drum basis)? This would help us have a sense of the dollar amount associated with compliance

with enhanced labeling requirements, notwithstanding the issue of training you men Ɵ oned.

David

From: Tom Baker [ mailto:tom.bake r@veoliaes.com ]

Sent: Thursday, June 27, 2013 9:35 AM

To: David Metz

Cc: Kristen Taft

Subject: RE: Hazardous waste generator standards

David,

In general, enhancing the labeling requirements would increase costs only slightly for most generators

in that labels could be easily purchased from a supplier (JJ Keller, Label Master etc) at rela Ɵ vely low

cost and then be hand wri Ʃ en with the required data. For some companies with exis Ɵ ng labeling

programs in place (like Veolia) programming changes would need to be made to allow the new

required labels to be printed. Veolia has a current database for crea Ɵ ng accumula Ɵ on and shipping

labels for our customers wastes. Actual costs to prepare the new labels from our computer systems

would vary greatly depending upon what data elements would be required on a new label. Another

cost not to be overlooked is the cost of compliance

– that is training employees of the generator to

complete and use the new labels in compliance with the regula Ɵ on. And of course, with any new

regula Ɵ on, generators would be subject to addi Ɵ onal poten Ɵ al penal Ɵ es for non

‐ compliance with

these rules if they are not adhered to properly. From industries perspec Ɵ ve, any new labeling

requirements would need to provide some measureable bene fi ts in improved protec Ɵ on of the

environment or the public’s health to jus Ɵ fy the addi Ɵ onal costs.

Tom Baker

Director, Environment & Transporta Ɵ on

Veolia ES Technical Solu Ɵ ons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691

‐ 7330 o ffi ce

(908) 303

‐ 1635 cell RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

3 of 8 6/18/2015 7:08 PMtom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e

‐ mail message from Veolia ES Technical Solu Ɵ ons, L.L.C. is for the sole use of the intended recipient(s) and may contain con fi den Ɵ al

and privileged informa Ɵ on. Any unauthorized review, use, disclosure or distribu Ɵ on is prohibited. If you are not the intended recipient,

please communicate with the sender by reply e

‐ mail and destroy all copies of the original message and delete same from all computers.

From: David Metz [ mailto:DMetz@indecon.com ]

Sent: Wednesday, June 26, 2013 5:16 PM

To: Tom Baker

Cc: Kristen Taft

Subject: RE: Hazardous waste generator standards

Tom,

Great, thanks again for the detailed explana Ɵ on. Do you have any sense of how the cost of

“an enhanced labeling system” would di ff er from the cost of a basic, minimum markings

system? Is it just a ma Ʃ er of the extra Ɵ me (and possibly ink) to provide the addi Ɵ onal

informa Ɵ on or would the generator also have to purchase larger or more complex labels to

include the addi Ɵ onal informa Ɵ on? Is this a very small cost per drum/accumula Ɵ on area or

poten Ɵ ally a larger cost?

Regards,

David

From: Tom Baker [ mailto:tom.bake r@veoliaes.com ]

Sent: Wednesday, June 26, 2013 4:35 PM

To: David Metz

Cc: Kristen Taft

Subject: RE: Hazardous waste generator standards

David,

Generators typically use a satellite accumula Ɵ on container that is sized appropriately for the

amount of waste they expect to produce in a set period of Ɵ me. For example, in a laboratory

se ƫ ng, a satellite accumula Ɵ on container will tend to be smaller (e.g. 5 gallon pail, one gallon

bo Ʃ le, etc) then what you’d fi nd in a manufacturing se ƫ ng (typically a 55 gallon drum is

used). Another factor that may impact the size of the container selected is how dangerous

the waste is. Reac Ɵ ve wastes and highly toxic wastes may tend to be accumulated in smaller

quan ƟƟ es to address worker safety or release risk issues. But in general, the 55 gallon drum is

the most common we encounter. Unfortunately we really have no way to accurately

determine the frequency of the size of satellite accumula Ɵ on containers used by our

customers.

As for container markings, many customers will mark satellite containers with the minimum

markings established by EPA (and the states)

– that is, the words “hazardous waste” or other

iden Ɵ fying words such as “waste solvents”. It is not a requirement to mark a satellite

container with a start accumula Ɵ on date. A start accumula Ɵ on date is only required for RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

4 of 8 6/18/2015 7:08 PMcontainers when fi rst placed in a 90

‐ day storage accumula Ɵ on area (or 180

‐ day area for a

small quan Ɵ ty generator). The only obliga Ɵ on to date a container in a satellite area is to do so

when the container is full (or 55 gallons of the waste has been reached). Once that satellite

accumula Ɵ on container is dated the generator has 3 days to either move the container to a

90

‐ day accumula Ɵ on area or ship it o ff‐ site for disposal. Many generators will use an

enhanced labeling system to aid in tracking or iden Ɵ fying a satellite accumula Ɵ on container

while on

‐ site. Labels may include addi Ɵ onal loca Ɵ on informa Ɵ on, hazard informa Ɵ on, etc. It

really depends upon the sophis Ɵ ca Ɵ on of the generator’s waste management program.

Feel free to call me if you’d like to discuss this further. Take care.

Tom Baker

Director, Environment & Transporta Ɵ on

Veolia ES Technical Solu Ɵ ons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691

‐ 7330 o ffi ce

(908) 303

‐ 1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e

‐ mail message from Veolia ES Technical Solu Ɵ ons, L.L.C. is for the sole use of the intended recipient(s) and may contain

con fi den Ɵ al and privileged informa Ɵ on. Any unauthorized review, use, disclosure or distribu Ɵ on is prohibited. If you are not the

intended recipient, please communicate with the sender by reply e

‐ mail and destroy all copies of the original message and delete

same from all computers.

From: David Metz [ mailto:DMetz@indecon.com ]

Sent: Wednesday, June 26, 2013 3:35 PM

To: Tom Baker

Cc: Kristen Taft

Subject: RE: Hazardous waste generator standards

Hi Tom,

I wanted to thank you for your input on hazardous waste determina Ɵ ons when we

spoke last in March. In the last few months, we’ve been moving forward with our

analysis of generator requirements for EPA and we have a few ques Ɵ ons regarding

satellite accumula Ɵ on areas where we thought you may have some insights.

Speci fi cally, we are trying to understand:

1) What is the average (or most common) container size being used by

generators in satellite accumula Ɵ on areas? (Alterna Ɵ vely, could you es Ɵ mate

the percentage of generators you work with using, say, 55

‐ gallon drums?

Other common sizes?)

2) What informa Ɵ on appears on container labels in satellite accumula Ɵ on

areas? (We understand from EPA, at a minimum, the label should include the

words “hazardous waste” and the start date of accumula Ɵ on. Would

generators have to take addi Ɵ onal steps to iden Ɵ fy (a) the contents and (b)

the hazardous waste characteris Ɵ cs (i.e., ignitable, corrosive, reac Ɵ ve, toxic) RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

5 of 8 6/18/2015 7:08 PMof containers or do some generators already do this? Could this informa Ɵ on

easily be added to the exis Ɵ ng container labels?)

We are available to schedule a quick call this week or next to discuss, or if our

ques Ɵ ons are straight

‐ forward, an email response would be fi ne. Again, we greatly

appreciate any input you can provide to help us understand how generators manage

their satellite accumula Ɵ on areas.

Best Regards,

David

David Metz

Associate

Industrial Economics, Incorporated (IEc)

2067 Massachusetts Ave.

Cambridge, MA 02140

617.354.0074

www.indecon.com

From: Tom Baker [ mailto:tom.bake r@veoliaes.com ]

Sent: Thursday, March 21, 2013 1:58 PM

To: David Metz

Subject: RE: Hazardous waste generator standards

Please call me at 10AM tomorrow as I will be in the o ffi ce and we can discuss. Thank

you.

Tom Baker

Director, Environment & Transporta Ɵ on

Veolia ES Technical Solu Ɵ ons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691

‐ 7330 o ffi ce

(908) 303

‐ 1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e

‐ mail message from Veolia ES Technical Solu Ɵ ons, L.L.C. is for the sole use of the intended recipient(s) and may

contain con fi den Ɵ al and privileged informa Ɵ on. Any unauthorized review, use, disclosure or distribu Ɵ on is prohibited.

If you are not the intended recipient, please communicate with the sender by reply e

‐ mail and destroy all copies of

the original message and delete same from all computers.

From: David Metz [ mailto:DMetz@indecon.com ]

Sent: Thursday, March 21, 2013 11:50 AM

To: Tom Baker

Subject: RE: Hazardous waste generator standards RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

6 of 8 6/18/2015 7:08 PMGreat, thanks for your help. Would any of the following Ɵ mes work for you:

‐ 10AM

‐ 2PM

‐ 3PM

David

From: Tom Baker [ mailto:tom.bake r@veoliaes.com ]

Sent: Thursday, March 21, 2013 11:43 AM

To: David Metz

Subject: RE: Hazardous waste generator standards

Yes, just ge ƫ ng back to the o ffi ce a Ō er a week of travel. I would have some

Ɵ me tomorrow to discuss. Let me know what Ɵ me you would be available.

Thanks.

Tom Baker

Director, Environment & Transporta Ɵ on

Veolia ES Technical Solu Ɵ ons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691

‐ 7330 o ffi ce

(908) 303

‐ 1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e

‐ mail message from Veolia ES Technical Solu Ɵ ons, L.L.C. is for the sole use of the intended

recipient(s) and may contain con fi den Ɵ al and privileged informa Ɵ on. Any unauthorized review, use,

disclosure or distribu Ɵ on is prohibited. If you are not the intended recipient, please communicate with the

sender by reply e

‐ mail and destroy all copies of the original message and delete same from all computers.

From: David Metz [ mailto:DMetz@indecon.com ]

Sent: Thursday, March 21, 2013 9:56 AM

To: Tom Baker

Subject: RE: Hazardous waste generator standards

Mr. Baker,

I just wanted to follow up to see if you would be able to speak with us brie fl y.

We would greatly appreciate any informa Ɵ on you can provide.

Regards,

David

From: David Metz

Sent: Monday, March 18, 2013 4:54 PM

To: 'tom.baker@veoliaes.com' RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

7 of 8 6/18/2015 7:08 PMCc: Jason Price; Oleary.jim@Epa.gov

Subject: Hazardous waste generator standards

Hi Mr. Baker,

I’m an Associate at Industrial Economics, an environmental and economic

consul Ɵ ng fi rm in Cambridge, MA. We are currently working with EPA’s O ffi ce

of Resource Conserva Ɵ on and Recovery (ORCR) on issues related to

hazardous waste generator standards, and I was referred to you by Jim

O’Leary of EPA/ORCR. As part of this e ff ort, we are trying to understand both

how facili Ɵ es make hazardous waste determina Ɵ ons and the percentage of

waste streams that are determined to be non

‐ RCRA hazardous waste (i.e.,

nega Ɵ ve determina Ɵ on). Considering Veolia’s signi fi cant experience assis Ɵ ng

generators with determina Ɵ ons, I was wondering if I could speak with you

about any informa Ɵ on or insights Veolia has on waste determina Ɵ ons that

might inform our analysis for EPA. We would greatly appreciate any help you

can provide.

Best Regards,

David

David Metz

Associate

Industrial Economics, Incorporated (IEc)

2067 Massachusetts Ave.

Cambridge, MA 02140

617.354.0074

www.indecon.com RE: Hazardous waste generator standards https://exma il.indecon.com/owa/?ae=Item &t=IPM.Note&id=AMB.Rg...

8 of 8 6/18/2015 7:08 PM