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 quesƟons.  Feel free to call me if you need addiƟonal insight.

1. Low end cost esƟmate 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 sƟck them on their drums.  AlternaƟvely, they may wish to simply write the

required informaƟon directly on the container to saƟsfy the marking requirement.  So these costs are quite

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

generator?

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

costs  specific to the waste.  Larger volumes in bulk quanƟty may be priced lower per pound than smaller

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

applied for larger generators that provide substanƟal quanƟƟes of wastes but those discounts vary widely

based on the types and volumes of wastes.

Hope this helps.

Tom Baker

Director, Environment & TransportaƟon

Veolia ES Technical SoluƟons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691‐7330 office

(908) 303‐1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e‐mail message from Veolia ES  Technical SoluƟons, L.L.C. is for the sole use of the intended recipient(s) and may contain confidenƟal and privileged

informaƟon. Any unauthorized review, use, disclosure or distribuƟon 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: 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 informaƟon for the last few months to inform

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

our previous conversaƟon and one new quesƟon where you may have some insight.

1) For large quanƟty generators, with an exisƟng 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 addiƟonal cost per facility might be for adding to exisƟng labels

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

words idenƟfying the contents (e.g., paint solvent waste).

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2) Are you aware if large quanƟty generators managing their hazardous waste through incineraƟon

receive bulk quanƟty “discounts” relaƟve to very small quanƟty generators (on a per ton or per drum

basis)? Can you esƟmate the percentage difference between what large generators pay versus what

very small generators pay for incineraƟon?

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:tom.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 quesƟon to respond to in parƟcular due to the fact that you haven’t indicated what addiƟonal

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

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

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

and then handwrite on them the required informaƟon.  Provided this is readily available informaƟon the Ɵme

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 consideraƟon the added labor costs).

On the high end, a generator or environmental services company with an exisƟng sophisƟcated computerized

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

One‐Ɵme programming and tesƟng costs could be as high as $25,000 if the addiƟonal 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 & TransportaƟon

Veolia ES Technical SoluƟons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691‐7330 office

(908) 303‐1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

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This e‐mail message from Veolia ES  Technical SoluƟons, L.L.C. is for the sole use of the intended recipient(s) and may contain confidenƟal and

privileged informaƟon. Any unauthorized review, use, disclosure or distribuƟon 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 potenƟal benefits) in our

discussions with EPA. Without asking you to disclose any propriety informaƟon, would you be able to

esƟmate 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 menƟoned.

David

From: Tom Baker [mailto:tom.baker@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 relaƟvely low

cost and then be hand wriƩen with the required data.  For some companies with exisƟng 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 creaƟng accumulaƟon 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 regulaƟon.  And of course, with any new

regulaƟon, generators would be subject to addiƟonal potenƟal penalƟes for non‐compliance with

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

requirements would need to provide some measureable benefits in improved protecƟon of the

environment or the public’s health to jusƟfy the addiƟonal costs.

Tom Baker

Director, Environment & TransportaƟon

Veolia ES Technical SoluƟons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691‐7330 office

(908) 303‐1635 cell

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tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e‐mail message from Veolia ES  Technical SoluƟons, L.L.C. is for the sole use of the intended recipient(s) and may contain confidenƟal

and privileged informaƟon. Any unauthorized review, use, disclosure or distribuƟon 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 explanaƟon. Do you have any sense of how the cost of

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

system? Is it just a maƩer of the extra Ɵme (and possibly ink) to provide the addiƟonal

informaƟon or would the generator also have to purchase larger or more complex labels to

include the addiƟonal informaƟon? Is this a very small cost per drum/accumulaƟon area or

potenƟally a larger cost?

Regards,

David

From: Tom Baker [mailto:tom.baker@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 accumulaƟon container that is sized appropriately for the

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

seƫng, a satellite accumulaƟon container will tend to be smaller (e.g. 5 gallon pail, one gallon

boƩle, etc) then what you’d find in a manufacturing seƫng (typically a 55 gallon drum is

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

the waste is.   ReacƟve wastes and highly toxic wastes may tend to be accumulated in smaller

quanƟƟes 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 accumulaƟon 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

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

container with a start accumulaƟon date.  A start accumulaƟon date is only required for

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containers when first placed in a 90‐day storage accumulaƟon area (or 180‐day area for a

small quanƟty generator).  The only obligaƟon 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

accumulaƟon container is dated the generator has 3 days to either move the container to a

90‐day accumulaƟon area or ship it off‐site for disposal.   Many generators will use an

enhanced labeling system to aid in tracking or idenƟfying a satellite accumulaƟon container

while on‐site.  Labels may include addiƟonal locaƟon informaƟon, hazard informaƟon, etc.  It

really depends upon the sophisƟcaƟon 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 & TransportaƟon

Veolia ES Technical SoluƟons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691‐7330 office

(908) 303‐1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

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

confidenƟal and privileged informaƟon. Any unauthorized review, use, disclosure or distribuƟon 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 determinaƟons 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 quesƟons regarding

satellite accumulaƟon areas where we thought you may have some insights.

Specifically, we are trying to understand:

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

generators in satellite accumulaƟon areas? (AlternaƟvely, could you esƟmate

the percentage of generators you work with using, say, 55‐gallon drums?

Other common sizes?)

2) What informaƟon appears on container labels in satellite accumulaƟon

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

words “hazardous waste” and the start date of accumulaƟon. Would

generators have to take addiƟonal steps to idenƟfy (a) the contents and (b)

the hazardous waste characterisƟcs (i.e., ignitable, corrosive, reacƟve, toxic)

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of containers or do some generators already do this? Could this informaƟon

easily be added to the exisƟng container labels?)

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

quesƟons are straight‐forward, an email response would be fine. Again, we greatly

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

their satellite accumulaƟon 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.baker@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 office and we can discuss.  Thank

you.

Tom Baker

Director, Environment & TransportaƟon

Veolia ES Technical SoluƟons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691‐7330 office

(908) 303‐1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

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

contain confidenƟal and privileged informaƟon. Any unauthorized review, use, disclosure or distribuƟon 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

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Great, thanks for your help. Would any of the following Ɵmes work for you:

‐ 10AM

‐ 2PM

‐ 3PM

David

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

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

To: David Metz

Subject: RE: Hazardous waste generator standards

Yes, just geƫng back to the office aŌer a week of travel.  I would have some

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

Thanks.

Tom Baker

Director, Environment & TransportaƟon

Veolia ES Technical SoluƟons, L.L.C.

1 Eden Lane, Flanders, NJ 07836

(973) 691‐7330 office

(908) 303‐1635 cell

tom.baker@veoliaes.com

www.VeoliaES.com

Service First. Safety Always.

This e‐mail message from Veolia ES  Technical SoluƟons, L.L.C. is for the sole use of the intended

recipient(s) and may contain confidenƟal and privileged informaƟon. Any unauthorized review, use,

disclosure or distribuƟon 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 briefly.

We would greatly appreciate any informaƟon 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://exmail.indecon.com/owa/?ae=Item&t=IPM.Note&id=AMB.Rg...

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Cc: 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

consulƟng firm in Cambridge, MA. We are currently working with EPA’s Office

of Resource ConservaƟon 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 effort, we are trying to understand both

how faciliƟes make hazardous waste determinaƟons and the percentage of

waste streams that are determined to be non‐RCRA hazardous waste (i.e.,

negaƟve determinaƟon). Considering Veolia’s significant experience assisƟng

generators with determinaƟons, I was wondering if I could speak with you

about any informaƟon or insights Veolia has on waste determinaƟons 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://exmail.indecon.com/owa/?ae=Item&t=IPM.Note&id=AMB.Rg...

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