Regulatory Impact Analysis for

Conditional Exclusions from

Solid Waste and Hazardous Waste

for Solvent-Contaminated Wipes

Final Rule

Office of Resource Conservation and Recovery

U.S. Environmental Protection Agency

June 21, 2013
Acknowledgements

This document was prepared by the U.S. Environmental Protection Agency (EPA’s) Office of 

Resource Conservation and Recovery (ORCR) with support from ICF International under EPA 

Contract EP-W-10-056, Task Order 0043. 
i

Table of Contents

Executive Summary.................................................................................................................................... 1

ES.1 Introduction.................................................................................................................................. 1

ES.2 Characterization of Generators and Handlers of Solvent-Contaminated Wipes ........................1

ES.3 Existing Regulatory Environment and the Affected Universe .....................................................2

ES.4 Estimated Costs and Savings of the Final Rule.......................................................................... 3

ES.5 Other Expected Benefits of the Final Rule.................................................................................. 4

ES.6 Comparison of Benefits to Costs................................................................................................. 5

1. Introduction........................................................................................................................................... 9

1.1. Need for Regulatory Action......................................................................................................... 9

1.2. Summary of Current Regulations................................................................................................ 9

1.3. Summary of Regulatory Changes in Final Rule........................................................................10

1.3.1. Solvent-Contaminated Reusable Wipes ......................................................................12

1.3.2. Solvent-Contaminated Disposable Wipes....................................................................12

1.4. Alternatives Considered by EPA...............................................................................................13

1.4.1. Modifications to Conditions for RCRA Exclusions .......................................................13

1.4.1.1. Conditions for Initial Storage and Accumulation .............................................13

1.4.1.2. Conditions for Containers Used for Transportation ........................................14

1.4.1.3. Labeling Condition for Containers Used To Transport

Solvent-Contaminated Wipes .........................................................................15

1.4.1.4. Condition for Transportation to Laundry, Dry Cleaner, or Handler .................16

1.4.1.5. Condition for Transportation to a Municipal or Other

Non-Hazardous Landfill...................................................................................16

1.4.1.6. Condition for Transportation to Non-Land Disposal Facilities.........................17

1.4.1.7. Conditions for Intra-Company Transfers.........................................................17

1.4.2. Exclusion from the Definition of Hazardous Waste for Reusable and

Solvent-Contaminated Disposable Wipes....................................................................18

1.4.3. Exclusion from the Definition of Hazardous Waste for All Disposable

Solvent-Contaminated Wipes under a Single Set of Conditions..................................19

2. Characterization of Generators and Handlers of Solvent-Contaminated Wipes .........................20

2.1. Industries That Generate or Handle Solvent-Contaminated Wipes..........................................22

2.2. Generation of Solvent-Contaminated Wipes.............................................................................26

2.2.1. Number of Generators of Solvent-Contaminated Wipes .............................................26

2.2.2. Annual Number of Solvent-Contaminated Wipes ........................................................30
Table of Contents (continued)

ii

2.3. Handling of Solvent-Contaminated Wipes ................................................................................33

2.3.1. Number of Handlers of Solvent-Contaminated Reusable Wipes.................................33

2.3.2. Number of Handlers of Solvent-Contaminated Disposable Wipes ..............................33

3. Existing Regulatory Environment and the Affected Universe .......................................................34

3.1. Existing Regulations Applicable to Solvent-Contaminated Wipes ............................................34

3.1.1. Federal Regulations Applicable to Generators and Handlers of

Solvent-Contaminated Wipes.......................................................................................34

3.1.2. State Policies Applicable to Generators and Handlers of

Solvent-Contaminated Wipes.......................................................................................35

3.1.2.1. State Policies on Solvent-Contaminated Reusable Wipes .............................35

3.1.2.2. State Policies on Solvent-Contaminated Disposable Wipes...........................36

3.2. Regulatory Baseline ..................................................................................................................36

4. Estimated Costs and Savings of the Final Rule ..............................................................................41

4.1. Summary of Costs and Savings................................................................................................41

4.2. Costs and Savings by Type of Facility ......................................................................................42

4.3. Derivation of Cost and Savings Elements.................................................................................48

4.3.1. Reading the Final Rule.................................................................................................49

4.3.2. Familiarizing Employees with the Final Rule Requirements and

Implementation Procedures/Practices .........................................................................50

4.3.3. Purchase of Containers................................................................................................51

4.3.4. Purchase of Labels ......................................................................................................54

4.3.5. Affixing Labels to Containers .......................................................................................55

4.3.6. Removing “Free Liquids” from Containers ...................................................................56

4.3.7. Management of “Free Liquids” Removed Containers..................................................58

4.3.8. Avoided Hazardous Waste Manifest Costs..................................................................59

4.3.9. Avoided Disposal Costs ...............................................................................................61

4.3.10. Complying with Recordkeeping Requirements under the Final Rule ..........................66

4.3.11. Demonstrating Compliance with Final Rule Conditions...............................................67

4.3.12. Avoided RCRA Information Collection Requirement Costs for SQGs

that May Become CESQGs .........................................................................................69

4.3.13. Avoided State Waste Fees and Taxes.........................................................................70
Table of Contents (continued)

iii

5. Other Expected Benefits of the Final Rule.......................................................................................73

5.1. Summary of Other Expected Benefits.......................................................................................73

5.2. Expected Pollution Prevention and Waste Minimization Benefits.............................................74

5.3. Expected Fire Safety Benefits...................................................................................................76

5.4. Expected Benefits to Industrial Laundries from Excluding Solvent-Contaminated Reusable 

Wipes from the Definition of Solid Waste..................................................................................78

6. Comparison of Benefits to Costs......................................................................................................81

6.1. Net Benefits of the Final Rule ...................................................................................................81

6.2. Sensitivity Analysis....................................................................................................................82

7. Supplemental Analyses Required by Congressional Statutes or White House

Executive Orders ................................................................................................................................85

7.1. Regulatory Flexibility Act (RFA), as Amended by the Small Business

Regulatory Enforcement Fairness Act (SBREFA) ....................................................................85

7.2. Executive Order 12630: Regulatory Takings Analysis.............................................................97

7.3. Executive Order 12988: Civil Justice Reform ..........................................................................97

7.4. Executive Order 12898: Federal Actions to Address Environmental Justice

in Minority Populations and Low-Income Populations ..............................................................97

7.5. Executive Order 13045: Protection of Children from Environmental Health Risks

and Safety Risks .......................................................................................................................99

7.6. Unfunded Mandate Reform Act (UMRA) ..................................................................................99

7.7. Executive Order 13132: Federalism ......................................................................................101

7.8. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments ....101

7.9. Executive Order 13211: Actions That Significantly Affect Energy Supply,

Distribution, or Use..................................................................................................................102

7.10. Executive Order 13352: Facilitation of Cooperative Conservation ........................................102

Appendices

Appendix A Description of North American Industry Classification System (NAICS) Codes 

Associated with Industries that May Be Affected by the Final Rule

Appendix B Information on State Waste Fees and Taxes

Appendix C Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry
iv

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1

Executive Summary

ES.1 Introduction

This regulatory impact analysis (RIA) analyzes the economic effects of the U.S. Environmental 

Protection Agency’s (EPA’s) final rule on the conditional exclusions of solvent-contaminated 

wipes from the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations. 

EPA is modifying its hazardous waste management regulations to:

• Conditionally exclude from the definition of solid waste wipes that are contaminated with 

hazardous solvents and are sent to an industrial laundry or to a dry cleaner for cleaning

and reuse (hereinafter referred to as “solvent-contaminated reusable wipes”); and 

• Conditionally exclude from the definition of hazardous waste wipes that are 

contaminated with hazardous solvents and are sent for disposal to a landfill or

combustor (hereinafter referred to as “solvent-contaminated disposable wipes”).

The conditional exclusions will apply to wipes that, after use or after cleaning up a spill, either: 

(1) contain one or more of the F001 through F005 solvents listed in 40 CFR 261.31 or the 

corresponding P- or U-listed solvents found in 40 CFR 261.33; (2) exhibit a hazardous 

characteristic found in 40 CFR Part 261, Subpart C when that characteristic results from a 

solvent listed in 40 CFR Part 261; and/or (3) exhibit only the hazardous waste characteristic of 

ignitability found in 40 CFR 261.21 due to the presence of one or more solvents that are not 

listed in 40 CFR Part 261. Solvent-contaminated wipes that contain listed hazardous waste 

other than solvents or exhibit the characteristic of toxicity, corrosivity, or reactivity due to 

contaminants other than solvents are not eligible for the exclusions at 40 CFR 261.4(a)(26) and 

40 CFR 261.4(b)(18).

The final rule will clarify the existing Federal hazardous waste requirements associated with 

solvent-contaminated wipes and provide regulatory relief as long as certain conditions are met. 

EPA’s current policy with respect to the regulatory status of solvent-contaminated wipes is to 

defer the determination of whether solvent-contaminated wipes must be managed as a solid or 

hazardous waste to the EPA Regional Offices and state agencies. However, current rules and 

policies at the EPA Regional Office- and state-level are inconsistent. Furthermore, EPA has 

determined that wipes can be managed appropriately with the less restrictive regulation 

established in this rulemaking, while maintaining protection of human health and the 

environment. 

ES.2 Characterization of Generators and Handlers of SolventContaminated Wipes

Entities that may be affected by the final rule include the following (Chapter 2 of this document 

describes them in more detail):

• Generators of solvent-contaminated wipes. These include facilities that use reusable 

and/or disposable wipes in conjunction with hazardous solvents. EPA identified 113 

industries (based on five- or six-digit North American Industry Classification System 
2

(NAICS) codes1) with facilities that generate solvent-contaminated wipes and, therefore, 

may be affected by the final rule (see Exhibit 2-2 in Chapter 2). In particular, EPA 

estimates that, each year, 90,549 facilities generate solvent-contaminated wipes. This 

estimate includes 576 large quantity generators (LQGs)2 and 89,973 small quantity 

generators (SQGs)3

. Collectively, these LQGs and SQGs generate 2.2 billion solventcontaminated wipes each year (see Section 2.2). Conditionally exempt small quantity 

generators (CESQGs) are not affected by the final rule.4

 

• Handlers of solvent-contaminated wipes. These include industrial laundries and dry 

cleaners that clean solvent-contaminated reusable wipes, and solid waste management 

facilities that manage solvent-contaminated disposable wipes once they have been 

discarded (i.e., hazardous and non-hazardous landfills/combustors). EPA identified 

eight industries (based on five- or six-digit NAICS codes) with facilities that handle 

solvent-contaminated wipes and, therefore, may be affected by the final rule (see Exhibit 

2-2 in Chapter 2). In particular, EPA estimates that, each year, 4,089 facilities handle 

solvent-contaminated wipes. This estimate includes 359 industrial laundries and dry 

cleaners, and 3,730 solid waste management facilities (see Section 2.3). 

ES.3 Existing Regulatory Environment and the Affected Universe

As noted above, EPA’s existing policy on solvent-contaminated wipes has led to the application 

of different regulatory schemes for solvent-contaminated wipes across the country. The 

anticipated impact of the final rule will vary by state, depending on whether they have existing 

state policies addressing solvent-contaminated wipes. (See Chapter 3 for further discussion.)

The regulatory baseline used in this RIA is as follows:5

• Twenty-five percent of facilities will not be affected by the final rule, either because they 

are located in states that have exclusions similar to the exclusions included in this final 

rule, or because they are located in states that currently have no conditional exclusions 

for solvent-contaminated wipes. These states are expected to decide not to adopt 

EPA’s final rule.

 1

 NAICS is the standard used by Federal statistical agencies in classifying business establishments for the 

purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.

2

 LQGs are facilities that generate 1,000 kilograms (2,200 pounds or 1.10 tons) or more of hazardous waste 

in any single calendar month, or more than 1 kilogram (2.2 pounds or 0.001 ton) of acute hazardous waste in any 

single calendar month, or more than 100 kilograms (220 pounds or 0.11 ton) of acute hazardous waste spill clean-up 

material in any single calendar month. 

3

 SQGs are facilities that generate between 100 kilograms (220 pounds or 0.11 ton) and 1,000 kilograms 

(2,200 pounds or 1.10 tons) of hazardous waste in any single calendar month. 

4

 CESQGs are facilities that generate 100 kilograms (220 pounds or 0.11 ton) or less of hazardous waste in 

any single calendar month, or 1 kilogram (2.2 pounds or 0.001 ton) or less of acute hazardous waste in any single 

calendar month, or 100 kilograms (220 pounds or 0.11 ton) or less of acute hazardous waste spill clean-up material in 

any single calendar month. CESQGs are exempt from 40 CFR Parts 262 through 270 if they comply with the 

requirements at 40 CFR 261.5.

5

 These assumptions are consistent with the assumptions under the “State Policy Baseline” in the economic 

background document originally developed for the proposed rule. U.S. Environmental Protection Agency. 

Economics Background Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent 

Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p.53.
3

• Seventy-five percent of facilities will be affected by the final rule because they are 

located in states that have conditional exclusions for solvent-contaminated wipes 

different from the exclusions in the final rule. These states are expected to adopt EPA’s 

final rule. 

Based on the above rationale, this analysis assumes that 75 percent of the LQGs and SQGs 

that generate solvent-contaminated wipes are located in states that are expected to adopt the 

final rule, and consequently these LQGs and SQGs will incur incremental costs or savings as a 

result of the final rule. All wipes generated by these LQGs and SQGs will enter the nonhazardous waste stream. To simplify the analysis, states that have conditional exclusions all 

are assumed to have similar conditions for their exclusions. These conditions require 

laundering and reuse of the solvent-contaminated wipes, and that the wipes contain “no free 

liquids.” 

ES.4 Estimated Costs and Savings of the Final Rule

EPA estimates that the total one-time cost of the final rule across all facilities is approximately 

$1.2 million in the first-year after promulgation of the final rule. EPA also estimates total annual

costs of approximately $6.3 million and total annual savings of approximately $24.4 million 

across all affected entities. EPA evaluated these costs and savings over a 10-year period.6

 

(See Chapter 4 for further discussion of costs and savings.) 

For purposes of this RIA, one-time costs include:

• Reading the final rule.

Annual costs include:

• Becoming familiar with the final rule requirements and implementation 

procedures/practices.

• Purchase of containers.

• Purchase of labels.

• Affixing labels to containers.

• Removing "free liquids" from containers.

• Recordkeeping requirements under the final rule.

• Demonstrating compliance with final rule requirements.

Annual savings include:

• Management of “free liquids” removed from containers.

• Avoided hazardous waste manifest costs.

• Avoided disposal costs.

• Avoided RCRA information collection requirement costs to SQGs that may become 

CESQGs.

 6

 Under the final rule, the only one-time cost element is reading the regulations. All other cost and savings 

elements are estimated on an annual basis. The analysis evaluates costs and savings over a 10-year period in order 

to avoid understating the impacts associated with the one-time costs.
4

• Avoided state waste fees and taxes.

As summarized in Exhibit ES-1, EPA estimates that the final rule will result in annual net 

savings of approximately $18.0 million (2011 dollars), at each of the three real discount rates 

used in the analysis (i.e., 7 percent, 3 percent, and 0 percent). 

Exhibit ES-1

Annual Economic Impacts of the Final Rule, 2011 Dollars a

Types of Impact 7%

Discount Rate

3%

Discount Rate

0%

Discount Rate

Annualized One-Time Cost $163,630 $139,961 $122,971 

Annual Costs b $6,261,270 $6,261,270 $6,261,270 

Annual Savings $24,375,585 $24,375,585 $24,375,585

Net Savings c $17,950,686 $17,974,354 $17,991,344

a Costs and savings are evaluated over a 10-year period.

b

 Annual costs do not include annualized one-time costs. 

c Net savings = [Annual Savings] – ([One-Time Costs] + [Annual Costs]).

ES.5 Other Expected Benefits of the Final Rule

The primary benefit of the final rule is the annual savings associated with avoided RCRA 

regulatory compliance. However, EPA also expects that the final rule will result in other 

expected benefits: (1) pollution prevention and waste minimization benefits, (2) fire safety 

benefits, and (3) potential benefits to industrial laundries by excluding solvent-contaminated

reusable wipes from the definition of solid waste—that is, removing the “waste” label. 

Exhibit ES-2 summarizes the annual values for these other expected benefits of the final rule, 

which are further discussed in Chapter 5. As shown in the exhibit, at all three discount rates 

(i.e., 7 percent, 3 percent, and 0 percent), the other expected benefits of the final rule are 

estimated at between $3.7 million and $9.9 million per year (2011 dollars).
5

Exhibit ES-2

Other Annual Expected Benefits of the Final Rule, 2011 Dollars a, b

(At All Three Discount Rates Used in the Analysis)

Types of Impact Benefits

(2011 Dollars)

Annual Pollution Prevention and Waste Minimization Benefits $212,358 to 

$960,593

Annual Fire Safety Benefits $230,922 to

$2,309,219

Annual Benefits to Industrial Laundries by excluding solvent-contaminated 

reusable wipes from the definition of solid waste

$3,293,366 to 

$6,586,733

Total Other Annual Expected Benefits c $3,736,647 to

$9,856,546

a Other expected benefits are evaluated over a 10-year period.

b

 Because the value of the expected benefits is the same for each year under evaluation, the annual benefits are the same at all 

three discount rates used in the analysis. 

c

 Total Other Expected Benefits = [Annual Pollution Prevention and Waste Minimization Benefits] + [Annual Fire Safety Benefits] + 

[Annual Benefits to Industrial Laundries by excluding solvent-contaminated reusable wipes from the definition of solid waste].

ES.6 Comparison of Benefits to Costs

Exhibit ES-3 presents the annual estimates for the costs and benefits of the final rule. As 

shown in the exhibit, the annual net benefits of the final rule are estimated at between $21.7

million and $27.8 million, regardless of discount rate (2011 dollars). Therefore, EPA can certify 

that the final rule is not an “economically significant regulatory action” under Section 3(f)(1) of 

Executive Order 12866 (Regulatory Planning and Review).7

 7

 Under Section 3(f)(1) of Executive Order 12866, Regulatory Planning and Review, a "significant regulatory 

action" means any regulatory action that is likely to result in a rule that may have an annual effect on the economy of 

$100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, 

competition, jobs, the environment, public health or safety, or state, local, or tribal governments or communities.
6

Exhibit ES-3

Comparison of Benefits to Costs under the Final Rule, 2011 Dollars a

Types of Impact

7% 3% 0%

Discount Rate Discount Rate Discount Rate

Benefits

Annual Regulatory Compliance Savings

(i.e., avoided costs) $24,375,585 $24,375,585 $24,375,585

Other Annual Expected Benefits $3,736,647 to

$9,856,546

$3,736,647 to

$9,856,546

$3,736,647 to

$9,856,546

Total Benefits $28,112,232 to

$34,232,131

$28,112,232 to

$34,232,131

$28,112,232 to

$34,232,131

Costs

Annual Regulatory Compliance Costs b $6,424,899 $6,401,231 $6,384,241

Total Costs $6,424,899 $6,401,231 $6,384,241

Net Benefits

Net Benefits c $21,687,333 to

$27,807,231

$21,711,001 to

$27,830,900

$21,727,991 to

$27,847,890

a

 Costs and benefits are evaluated over a 10-year period.

b Annual regulatory compliance costs include annualized one-time costs as well as annual costs.

c Net Benefits = [Total Benefits] - [Total Costs].

EPA also conducted a sensitivity analysis in order to determine whether, and to what extent, the 

results of the analysis are sensitive to changes in key assumptions and numeric inputs (see 

Section 6.2 for further discussion of the sensitivity analysis.) The sensitivity analysis estimates 

economic impacts according to the three alternative sets of parameters shown in Exhibit 6-2:

Exhibit ES-4

Assumptions Associated with Key Parameters Used

in Sensitivity Analysis of Economic Impact Estimation

Cost Element Lower 

Bound 

Most 

Likely

Upper 

Bound

Affected

Universe Percent of states that will adopt the final rule 50% 75% 100%

Containers

for SolventContaminated

Wipes

Percent of wipes not currently accumulated, stored, and 

transported in closed containers 25% 50% 80%

Management of 

"Free Liquids"

Percent of solvent-contaminated wipes 

with "free liquids"

Printers 90% 100% 100%

Non-Printers 40% 50% 60%

The results of the sensitivity analysis are reflected in the following Office of Management and 

Budget (OMB) A-4 Accounting Statement. 
7

OMB A-4 ACCOUNTING STATEMENT

(2011 $Millions)

OMB #: [Insert No.] Agency/Program Office: EPA/Office of Resource Conservation and Recovery

Rule Title: Conditional Exclusions from Solid Waste and Hazardous Waste for Solvent-Contaminated 

Wipes

RIN#: [Insert No.] Date: [Insert Date]

Category Primary 

Estimate

Minimum 

Estimate

Maximum 

Estimate

Source Citation

(RIA, Preamble, etc.)

BENEFITS

Monetized Benefits $28.1 to $34.2 $19.8 to $24.9 $36.4 to $43.5 RIA

Annualized quantified, but nonmonetized, benefits None N/A N/A RIA

Unquantified Benefits None N/A N/A RIA

COSTS

Annualized monetized costs

(discount rate in parenthesis)a

$6.4 (7%) $4.2 (7%) $8.8 (7%)

$6.4 (3%) $4.2 (3%) $8.8 (3%) RIA

$6.4 (0%) $4.2 (0%) $8.7 (0%)

Annualized quantified, but nonmonetized, costs None N/A N/A RIA

Qualitative (unquantified) costs None N/A N/A RIA

TRANSFERS

Annualized monetized transfers: “on budget” None N/A N/A RIA

Annualized monetized transfers: “off-budget” None N/A N/A RIA

MISCELLANEOUS ANALYSES

Effects on State, local, and/or tribal governments None RIA

Effects on small businesses None RIA

Effects on wages None RIA

Effects on growth None RIA
8

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9

1. Introduction

This RIA analyzes the economic effects of EPA’s final rule on the conditional exclusions of 

solvent-contaminated wipes from the RCRA hazardous waste regulations. EPA is modifying its 

hazardous waste management regulations under RCRA for certain solvent-contaminated 

materials, such as shop towels, rags, pad, and swabs (hereinafter referred to as “wipes”). The 

affected universe for this final rule encompasses wipes that facilities use to clean surfaces, 

parts, accessories, and equipment in conjunction with solvents that when spent are hazardous 

wastes. Once wipes are used and are no longer suitable for their intended purpose, they 

become solid wastes and may need to be managed as hazardous wastes, depending upon the 

kind of solvent used with the wipes. EPA’s concern surrounding the use of wipes is based on 

the hazardous solvent contained in the used wipes, not the wipes themselves. Many solvents 

used by industry can pose unacceptable risks to human health and the environment if 

improperly managed. EPA estimates that, each year, 90,549 facilities generate 2.2 billion 

solvent-contaminated wipes, and that 4,089 facilities handle these wipes. 

1.1. Need for Regulatory Action

The final rule will clarify existing Federal hazardous waste requirements associated with solventcontaminated wipes and provide regulatory relief as long as certain conditions are met. EPA’s 

current policy with respect to the regulatory status of solvent-contaminated wipes is to defer the 

determination of whether solvent-contaminated wipes must be managed as a solid or hazardous 

waste to the EPA Regional Offices and state agencies. However, current rules and policies at 

the EPA Regional Office- and state-level are inconsistent. Furthermore, EPA has determined 

that wipes can be managed appropriately with less restrictive regulation while maintaining

protection of human health and the environment. 

EPA’s intent in promulgating the final rule is to resolve, at the Federal level, long-standing 

issues associated with the management of solvent-contaminated wipes by providing 

consistency in the regulations governing solvent-contaminated wipes across the U.S. This rule 

maintains protection of human health and the environment, while creating flexibility and 

reducing compliance costs for generators of solvent-contaminated wipes.

1.2. Summary of Current Regulations

Under the Federal RCRA program, solvent-contaminated wipes meet the definition of 

hazardous waste if they:

• Exhibit one or more of the characteristics of hazardous waste identified in 40 CFR 

Part 261, Subpart C;

• Are listed as a hazardous waste under 40 CFR Part 261, Subpart D;

8

• Are a mixture of a solid waste and a hazardous waste that is listed in 40 CFR Part 261, 

Subpart D; or

 8

 Under the Federal RCRA regulations, wipes contaminated with listed hazardous waste solvents (i.e., EPA 

hazardous waste codes F001-F005) are considered to be listed hazardous wastes.
10

• Are a mixture of a solid waste and a characteristic hazardous waste, and the resultant 

mixture exhibits one or more hazardous waste characteristics.

However, it has long been EPA’s policy to defer the determination of whether solventcontaminated wipes must be managed as a solid or hazardous waste to the EPA Regional 

Offices and state agencies due to case-specific circumstances (e.g., type of solvent used, 

degree of hazard, when a spent solvent is generated, and whether the hazardous waste mixture 

rule applies to a particular waste). 

The majority of the states have developed their own policies governing the management of

solvent-contaminated wipes. However, a few states have deferred regulatory decisions 

regarding the management of solvent-contaminated wipes to their respective EPA Regional 

Offices. Thus, EPA’s policy on solvent-contaminated wipes led to the application of different 

regulatory schemes for solvent-contaminated wipes across the country. 

1.3. Summary of Regulatory Changes in Final Rule

EPA is modifying its hazardous waste management regulations under RCRA to:

• Solvent-Contaminated Reusable Wipes. Conditionally exclude from the definition of 

solid waste wipes that are contaminated with hazardous solvents and are sent to an 

industrial laundry or to a dry cleaner for cleaning and reuse (hereinafter referred to as 

“solvent-contaminated reusable wipes”); and 

• Solvent-Contaminated Disposable Wipes. Conditionally exclude from the definition of 

hazardous waste wipes that are contaminated with hazardous solvents and are sent for 

disposal to a landfill or combustor (hereinafter referred to as “solvent-contaminated 

disposable wipes”).

The conditional exclusions will apply to wipes that, after use or after cleaning up a spill, either: 

(1) contain one or more of the F001 through F005 solvents listed in 40 CFR 261.31 or the 

corresponding P- or U-listed solvents found in 40 CFR 261.33; (2) exhibit a hazardous 

characteristic found in 40 CFR Part 261, Subpart C when that characteristic results from a 

solvent listed in 40 CFR Part 261; and/or (3) exhibit only the hazardous waste characteristic of 

ignitability found in 40 CFR 261.21 due to the presence of one or more solvents that are not 

listed in 40 CFR Part 261. Solvent-contaminated wipes that contain listed hazardous waste 

other than solvents or exhibit the characteristic of toxicity, corrosivity, or reactivity due to 

contaminants other than solvents are not eligible for the exclusions at 40 CFR 261.4(a)(26) and 

40 CFR 261.4(b)(18). Exhibit 1-1 identifies the Federal hazardous waste codes associated with 

solvent-contaminated wipes. 

The exclusions are applicable only when specified conditions are met. These conditions are 

briefly discussed in the following sections.
11

Exhibit 1-1

Federal Hazardous Waste Codes Associated with Solvent-Contaminated Wipes

Federal

Waste Codes Federal Waste Code Descriptions

Characteristic or D-Listed Wastes. A “characteristic waste” is any solid waste that exhibits one or more of the following 

characteristics: ignitability, corrosivity, reactivity, or toxicity. Additional information about each of the hazardous waste

characteristics may be reviewed at 40 CFR 261.21 through 261.24.

D001 Ignitable waste.

F-Listed Wastes. This list, at 40 CFR 261.31, includes wastes from certain common manufacturing and industrial processes. 

Because they are not specific to one type of industry, they are called wastes from non-specific sources.

F001

The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, 

methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent 

mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or 

more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms 

from the recovery of these spent solvents and spent solvent mixtures.

F002

The following spent halogenated solvents: tetrachloroethylene, methylene chloride, trichloroethylene, 

1,1,1 trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene, 

trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a 

total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in 

F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F002

The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, 

methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends 

containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends 

containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more 

(by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the 

recovery of these spent solvents and spent solvent mixtures.

F004

The following spent non-halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent solvent 

mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above 

non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery 

of these spent solvents and spent solvent mixtures.

F005

The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, 

pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before 

use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those 

solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent 

solvent mixtures.

P-and U-Listed Wastes. These two lists, at 40 CFR 261.33, designate certain commercial chemical products as hazardous 

when disposed of unused. The primary difference between P-listed and U-listed wastes is that, when discarded, P-listed wastes 

are considered “acutely hazardous,” while U-listed wastes are considered "hazardous." Thus, U-listed wastes are regulated in a 

somewhat less stringent manner than P-listed wastes.

P022 Carbon disulfide.

U019 Benzene.

U037 Chlorobenzene.

U052 Cresol (Cresylic acid).

U070 o-Dichlorobenzene

U080 Methylene chloride.

U159 Methyl ethyl ketone (MEK).

U169 Nitrobenzene.

U171 2-Nitropropane.

U196 Pyridine.

U210 Tetrachloroethylene.

U211 Carbon tetrachloride.

U220 Toluene.

U226 1,1,1-Trichloroethane.

U227 1,1,2-Trichloroethane.

U228 Trichloroethylene.
12

1.3.1. Solvent-Contaminated Reusable Wipes

For solvent-contaminated reusable wipes to be eligible for the exclusion from the definition of 

solid waste, they must: (1) be accumulated, stored, and transported in non-leaking, closed 

containers9 that are labeled “Excluded Solvent-Contaminated Wipes;” (2) be accumulated by 

the generator for no more than 180 days from the start date of accumulation for each container 

prior to being sent for cleaning; and (3) contain “no free liquids” at the point of being sent for 

cleaning on-site or at the point of being transported off-site for cleaning as determined by the 

Paint Filter Liquids Test (EPA Methods Test 9095B). Free liquids removed from the solventcontaminated wipes or from the container holding the wipes must be managed according to the 

applicable regulations found in 40 CFR Parts 260 through 273. Generators must maintain at 

their site documentation that they are managing the solvent-contaminated wipes under the 

conditional exclusion, including documentation on where the wipes are being sent for cleaning, 

how they are meeting the 180-day accumulation time limit, and how they are meeting the “no 

free liquids” standard.

Solvent-contaminated reusable wipes must be sent to an industrial laundry or dry cleaner whose 

discharge, if any, is regulated under Sections 301 and 402 or Section 307 of the Clean Water 

Act (e.g., National Pollutant Discharge Elimination System (NPDES), discharge to a publicly 

owned treatment work (POTW)).

1.3.2. Solvent-Contaminated Disposable Wipes

For solvent-contaminated disposable wipes to be eligible for the conditional exclusion from the 

definition of hazardous waste, they must not be hazardous for trichloroethylene. In addition, the 

solvent-contaminated disposable wipes must: (1) be accumulated, stored, and transported in 

non-leaking, closed containers10 that are labeled “Excluded Solvent-Contaminated Wipes;” (2) 

be accumulated by the generator for no more than 180 days from the start date of accumulation 

for each container prior to being sent for disposal; and (3) contain “no free liquids” at the point of 

being transported for disposal as determined by the Paint Filter Liquids Test (EPA Methods Test 

9095B). Free liquids removed from the solvent-contaminated wipes or from the container 

holding the wipes must be managed according to the applicable regulations found in 40 CFR 

Parts 260 through 273. Generators must maintain at their site documentation that they are 

managing the solvent-contaminated wipes under the conditional exclusion, including 

documentation on where the wipes are being sent for disposal, how they are meeting the 180-

day accumulation time limit, and how they are meeting the “no free liquids” standard.

Solvent-contaminated disposable wipes may be sent for disposal to a municipal solid waste 

landfill regulated under 40 CFR Part 258, including 40 CFR 258.40, or to a hazardous waste 

landfill regulated under 40 CFR Part 264 or 265. In addition, solvent-contaminated disposable 

wipes may be sent for disposal to a municipal solid waste combustor or other combustion facility 

regulated under Section 129 of the Clean Air Act, or to a hazardous waste combustor, boiler, or 

industrial furnace regulated under 40 CFR Part 264; 265; or 266, Subpart H. 

 9

 The containers must be able to contain free liquids, should free liquids occur. During accumulation, a 

container is considered closed when there is complete contact between the fitted lid and the rim, except when it is 

necessary to add or remove solvent-contaminated wipes. When the container is full, or when the solventcontaminated wipes are no longer being accumulated, or when the container is being transported, the container must 

be sealed with all lids properly and securely affixed to the container and all openings tightly bound or closed 

sufficiently to prevent leaks and emissions.

10 Ibid.
13

1.4. Alternatives Considered by EPA

EPA selected the final regulatory approach after considering several alternative options and 

approaches, including alternatives that are both more and less stringent than the final regulatory 

action. In the following paragraphs, EPA briefly summarizes its evaluation of the alternatives 

considered as part of this final rulemaking effort.11 

1.4.1. Modifications to Conditions for RCRA Exclusions

This section briefly describes the alternative options considered and evaluated by EPA in 

establishing conditions for the exclusion from the regulatory definition of solid waste for reusable 

wipes and the exclusion from the regulatory definition of hazardous waste for disposable wipes. 

For each of the conditions, EPA presents the proposed condition and the corresponding 

alternative option(s).12, 13 

1.4.1.1. Conditions for Initial Storage and Accumulation

Proposed Rule

In the 2003 proposed rule, EPA included a condition for the on-site accumulation and storage of 

solvent-contaminated wipes that would require the use of non-leaking, covered containers. 

Generators would be required to accumulate and store solvent-contaminated wipes in covered 

containers that do not allow solvent to be released from the container. The container must not 

leak liquids and must protect against fugitive air releases of solvents when not in use. As part of 

this condition, there would be no time limit for accumulation of solvent-contaminated wipes, if 

the specified type of container is used.

Alternative Option - Accumulation Time Limit

In the preamble to the proposed rule, EPA indicated that it was considering including a condition 

that would establish a time limit for accumulation of solvent-contaminated disposable wipes at a

generator facility, so they could not be kept on site indefinitely without management. As part of 

this condition, solvent-contaminated disposable wipes being accumulated at the generator,

under the specified conditions, would also have to follow the accumulation time limits in 40 CFR

262.34: 90 days for large quantity generators (LQGs) and 180 days for small quantity 

generators (SQGs). In addition to the accumulation time limits, generators would have to mark

any container in which solvent-contaminated disposable wipes were being accumulated with a

label stating that it holds excluded wipes and the date accumulation started.

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided to include a 180-day accumulation time limit condition for both reusable and 

 11 This document only analyzes the option chosen for the final rule in detail and the analysis starts in 

Chapter 2.

12 U.S. Government Printing Office. Federal Register. “Hazardous Waste Management System: 

Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for 

Solvent- Contaminated Industrial Wipes.” 68 FR 65586. November 20, 2003.

13 This section does not present a description of all conditions proposed in 2003. It only describes those 

conditions for which EPA considered and evaluated for the final rulemaking stage.
14

disposable wipes. This condition ensures that free liquids are removed from the wipes and the 

container within a specified time frame and thus cannot be stored indefinitely in lieu of being 

disposed or laundered. 

Alternative Option - No RCRA-Specific Condition

In the preamble to the proposed rule, EPA also indicated that it was considering not to establish 

a specific accumulation condition, but relying on other regulatory statutes, such as the

Occupational Safety and Health Act. The Occupational Safety and Health Administration’s 

(OSHA’s) occupational health and safety standards, specified in 29 CFR Part 1910, provide

both general and specific requirements for containers used to accumulate and store certain 

types of materials. Subpart H of Part 1910 may be applicable for the storage of wipes prior to

solvent removal or recovery. Section 1910.106 contains standards for the management of 

hazardous materials, including requirements for the management of flammable14 and

combustible liquids15; facilities which either generate or launder solvent-contaminated wipes 

may be subject to these standards. Section 1910.106 also specifies standards for the areas

where containers holding flammable liquids are to be kept. In addition, storage of solventcontaminated wipes that contain a negligible amount of solvents may be addressed under 

OSHA’s regulations at 29 CFR 1910.106(e)(9)(iii), which describe general housekeeping 

measures for ‘‘combustible waste material and residues’’ and residues of flammable liquids, 

combustible waste material, and residues in a building or unit operating area.

Based on further analysis, EPA determined that the OSHA regulations may not cover every

workplace covered by the RCRA regulations. As a result, there might be gaps in regulatory 

coverage if EPA relied strictly on deferring to OSHA regulations. For example, the OSHA 

container standards may not apply to solvent-contaminated wipes with no free-flowing liquids or 

when wipes are contaminated with non-flammable solvents. Additionally, state and local 

government workers are excluded from federal coverage under OSHA. Therefore, EPA decided 

not to pursue this alternative option.

Alternative Option - Closed Containers

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided to require the use of non-leaking, closed containers for the initial storage and 

accumulation of solvent-contaminated wipes. EPA determined that wipes managed in closed 

containers that are able to contain liquids reduce the risk of adverse impacts to human health 

and the environment resulting from release of solvents. 

1.4.1.2. Conditions for Containers Used for Transportation

Proposed Rule

In the 2003 proposed rule, EPA included a container condition for generators who transport 

solvent-contaminated wipes off-site under the conditional exclusions. This condition would 

 14 Flammable liquids are defined as any liquid having a flash point below 100° F (37.8° C) or higher, the 

total of which make up 99 percent or more of the total volume of the mixture. Several solvents that are either listed or 

characteristic hazardous wastes and are used in conjunction with wipes also meet the definition of a flammable liquid 

(such as acetone, ethyl acetate, ethyl benzene, methyl ethyl ketone, petroleum naphtha).

15 Combustible liquids are any liquids having a flash point at or above 100° F (37.8° C).
15

ensure that transporting the wipes without full RCRA hazardous waste requirements would still 

protect against risks posed by these materials to human health and the environment. Under the

proposal, generators must transport wipes in containers that are designed, constructed and

managed to minimize loss to the environment. In proposing this condition, EPA envisioned

containers that do not leak liquids and that provide for control of air emissions. EPA would 

consider hazardous solvents that are spilled or leaked during transportation to be disposed. 

Therefore, the party managing the wipes at the time the spill occurred would be responsible for 

cleaning up the spill and managing those materials appropriately.

Alternative Option - Closed Containers

In the preamble to the proposed rule, EPA indicated that it was considering an alternative option 

of requiring all generators of solvent-contaminated wipes to transport them in impermeable 

closed containers. By closed containers, EPA specifically meant containers with a lid that 

screws on to the top and must be sealed to be considered closed. 

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided to require the use of non-leaking, closed containers for the transport of solventcontaminated wipes. EPA determined that wipes managed in closed containers that are able to 

contain liquids reduce the risk of adverse impacts to human health and the environment 

resulting from release of solvents. 

1.4.1.3. Labeling Condition for Containers Used To Transport SolventContaminated Wipes

Proposed Rule

In the 2003 proposed rule, EPA included a labeling requirement that would require the use of 

specific language or a pre-made label, such as “Excluded Solvent-Contaminated Wipes,” to be 

applied to each container used to accumulate and/or store solvent-contaminated wipes, unless 

the wipes are being recycled. 

Alternative Option - No RCRA-Specific Labeling Condition

In the preamble to the proposed rule, EPA indicated that it was considering not to impose a 

specific labeling condition. Under this alternative option, designation of the disposable wipes as 

hazardous materials under the U.S. Department of Transportation (DOT) regulations might still 

require placarding or other marking for transportation of some fraction of these materials. 

However, EPA did not expect that the DOT provisions would apply to all solvent-contaminated

wipes covered by the rule.

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA determined that the labeling requirement is necessary in order to allow identification of 

container contents by emergency response personnel, motor carrier inspectors, downstream 

transporters, and handlers. Therefore, EPA decided not to include this condition in the final 

rule.
16

1.4.1.4. Condition for Transportation to Laundry, Dry Cleaner, or Handler

Proposed Rule

In the 2003 proposed rule, EPA required generators meet the ‘‘no free liquids’’ condition prior to 

solvent-contaminated reusable wipes being transported off-site to be cleaned for re-use or being 

laundered on site.

Alternative Option – “No Free Liquids when Wrung”

In the preamble to the proposed rule, EPA indicated that it was considering a ‘‘no free liquids

when wrung’’ condition, instead of the ‘‘no free liquids’’ condition. This approach differs from the 

proposed approach in that it would require that each wipe could not drip solvent when hand 

wrung. 

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided not to include the “no free liquids when wrung” condition in the final rule because it 

carries the perception of increased worker exposure due to hand wringing. Additionally, this 

standard is subjective because of the variability associated with the people doing the wringing. 

1.4.1.5. Condition for Transportation to a Municipal or Other Non-Hazardous 

Landfill

Proposed Rule

In the 2003 proposed rule, EPA included two conditions for allowing generators to transport 

certain solvent-contaminated disposable wipes to municipal or other non-hazardous waste

landfills that meet the standards under 40 CFR Part 257, Subpart B, when the conditions of the 

exclusion are met. These conditions include: (1) the wipes must meet the “dry” condition (i.e., 

contain no more than five grams of solvent) and (2) the wipes must not be contaminated with 

any of 11 solvents identified by EPA. 

Alternative Option – “No Free Liquids”

Based on comments received on the proposed rule and further analysis conducted by EPA,

EPA considered and evaluated the “no free liquids” standard as a condition for the 

transportation of solvent-contaminated wipes to a landfill. For purposes of the final rule, EPA 

defines “no free liquids” in terms of the EPA Methods Test 9095B- Paint Filter Liquids Test. 

EPA decided to include this condition in the final rule because this standard is currently used by 

many states. Moreover, the 40 CFR Part 258 municipal waste landfill regulations have liquid 

restrictions that also use the language “no free liquids.” Therefore, the “no free liquids” standard 

should be relatively familiar to the regulated industry and easy to implement.

Alternative Option – List of Solvents Not Allowed in Non-Hazardous Waste Landfills

Based on comments received on the risk screening analysis conducted for the proposed rule, 

EPA conducted a risk analysis in 2009 for residual solvents on disposable wipes. This risk 

analysis uses updated science and assumptions that reflect current waste management 

practices. In finalizing the rule, EPA decided to defer to the results of the 2009 risk analysis and 

allow toxicity characteristic (TC) solvents that pass the wipes risk assessment to be eligible for 
17

the hazardous waste exclusion for disposable wipes, even when the TC level is exceeded. As a 

result, trichloroethylene will be the only solvent not allowed in non-hazardous waste landfills, 

based on the fact that it exceeds the risk threshold. 

Alternative Option – Specify Type of Non-Hazardous Waste Landfill 

The 2009 risk analysis evaluated disposal in lined landfills and disposal in unlined landfills. 

Based on the results of the risk analysis, EPA considered three non-hazardous waste landfill 

options in finalizing the rule: (1) allow disposal of solvent-contaminated wipes only in a 

municipal solid waste landfill that meets 40 CFR Part 258 standards, (2) allow disposal of 

solvent-contaminated wipes in 40 CFR Part 257 non-hazardous waste landfills that have 

composite liners, and (3) allow disposal of solvent-contaminated wipes that do not exceed the 

risk criteria for an unlined landfill to go to 40 CFR Part 257 non-hazardous waste landfills 

without liners. After carefully reviewing each option, EPA decided to allow disposal of solventcontaminated wipes only in a municipal solid waste landfill that meets Part 258 standards 

(i.e., Option 1). EPA determined that this option is protective of human health and the 

environment for all scenarios evaluated in the risk analysis, can be implemented through 

normal municipal waste service contracts, and eliminates the need for the generator (and state 

enforcement) to independently verify that the correct type of wipes are being sent to the 

appropriate type of landfills.

1.4.1.6. Condition for Transportation to Non-Land Disposal Facilities

Proposed Rule

In the 2003 proposed rule, EPA included a “no free liquids” condition for solvent-contaminated 

wipes sent for disposal at a non-land disposal unit such as a municipal waste combustor (MWC) 

or other combustion unit, including use as a fuel. This condition also will apply to solventcontaminated wipes sent to an intermediate handler for further processing to meet the “dry” 

condition before disposal in a municipal or other non-hazardous waste landfill. 

Alternative Option – “No Free Liquids when Wrung”

In the preamble to the proposed rule, EPA indicated that it was considering a ‘‘no free liquids

when wrung’’ condition instead of the ‘‘no free liquids’’ condition. This approach differs from the 

proposed approach in that it would require that each wipe could not drip solvent when hand 

wrung. 

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided not to include the “no free liquids when wrung” condition in the final rule, because 

it carries the perception of increased worker exposure due to hand wringing. Additionally, this 

standard is subjective because of the variability associated with the people doing the wringing. 

1.4.1.7. Conditions for Intra-Company Transfers 

Proposed Rule

To encourage recovery and recycling of the solvents in the wipes, EPA proposed to allow 

generators to continue to qualify for the exclusion from the definition of hazardous waste if they 

transfer solvent-contaminated wipes containing “free liquids” between their own facilities and if 
18

the receiving facility has a solvent extraction and/or recovery process that will remove sufficient 

solvent to ensure the wipes meet either the “dry” condition or the “no free liquids” condition 

before being sent off-site. 

Alternative Option – Additional Recordkeeping and Container Conditions

In the preamble to the proposed rule, EPA indicated that it was considering adding conditions to 

this provision. Specifically, EPA considered: (1) requiring a one-time notification to the state to 

alert the state that the generator is taking advantage of the intra-company transport allowed 

under this exclusion; (2) maintenance of appropriate business records that identify where the

wipes are being managed and where the recovered solvent is being sent; (3) compliance with 

RCRA’s employee training and emergency response requirements in 40 CFR Part 262; and

(4) transfer of the wipes with free liquids in closed (i.e., sealed) containers. 

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided to prohibit intra-company transfers of solvent-contaminated wipes. This ensures 

consistency with the existing hazardous waste regulations. Currently, EPA is not allowing liquid 

solvent to be sent off-site without a manifest and to a facility without a RCRA permit.

1.4.2. Exclusion from the Definition of Hazardous Waste for Reusable and 

Solvent-Contaminated Disposable Wipes

In the preamble to the proposed rule16, EPA indicated that it was considering an alternative 

approach that would exclude reusable wipes from the regulatory definition of hazardous waste 

rather than exclude them from the regulatory definition of solid waste, using the same conditions

as those specified in the proposed rule. This approach would not differentiate the regulatory 

status of solvent-contaminated wipes whether they are being sent for recycling or for disposal. 

Under this approach, the provisions of the rule concerning solvent-contaminated disposable 

wipes would remain the same as in the proposed option. For solvent-contaminated reusable 

wipes, the conditions for complying with the rule would be the same as in the proposed option, 

but the solvent-contaminated reusable wipes would remain solid wastes (though not hazardous 

wastes) when the conditions were met.

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided not to move forward with this approach. EPA decided that solvent-contaminated 

reusable wipes are commodity-like and not being discarded. EPA decided that the conditions 

for the exclusion from solid waste are appropriate because they ensure that the manner in 

which generators and laundries manage these materials is consistent with how companies 

would manage a commodity.

 16 U.S. Government Printing Office. Federal Register. “Hazardous Waste Management System: 

Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for 

Solvent- Contaminated Industrial Wipes.” 68 FR 65586. November 20, 2003.
19

1.4.3. Exclusion from the Definition of Hazardous Waste for All SolventContaminated Disposable Wipes under a Single Set of Conditions

In the preamble to the proposed rule17, EPA indicated that an additional approach considered

was providing an exclusion from the definition of hazardous waste for all disposable wipes 

under a single set of conditions. The option affected only the exclusion from the definition of

hazardous waste; all provisions for solvent-contaminated reusable wipes would remain the 

same. Under this approach, EPA would not differentiate between wipes managed in municipal 

and other non-hazardous waste landfills or non-landfill facilities—the conditions necessary for 

wipes to obtain an exclusion from hazardous waste regulations would be the same for both

types of management. 

Based on comments received on the proposed rule and further analysis conducted by EPA, 

EPA decided not to move forward with this approach. EPA decided that additional conditions

should be included for the land disposal of solvent-contaminated wipes (e.g., landfills must be 

regulated under 40 CFR Part 258, including 40 CFR 258.40) in order to provide adequate 

protection to human health and the environment.

 17 U.S. Government Printing Office. Federal Register. “Hazardous Waste Management System: 

Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for 

Solvent- Contaminated Industrial Wipes.” 68 FR 65586. November 20, 2003.
20

2. Characterization of Generators and Handlers of SolventContaminated Wipes

This chapter characterizes the entities that may be affected by the final rule. These entities 

include:

• Generators of solvent-contaminated wipes. These include facilities that use reusable 

and/or disposable wipes in conjunction with hazardous solvents. For solventcontaminated wipes to be eligible for the conditional exclusions under the final rule, 

generators are required to: (1) accumulate, store, and transport the solventcontaminated wipes in non-leaking, closed containers18 that are labeled “Excluded 

Solvent-Contaminated Wipes;” (2) accumulate the solvent-contaminated wipes for up to 

180 days from the start date of accumulation for each container prior to being sent for 

cleaning or disposal; and (3) ensure that the solvent-contaminated wipes contain “no 

free liquids” at the point of being sent for cleaning on-site, at the point of being 

transported off-site for cleaning or at the point of being transported for disposal. Free 

liquids removed from the solvent-contaminated wipes or from the container holding the 

wipes must be managed in accordance with the applicable regulations found in 40 CFR 

Parts 260 through 273. Generators also must comply with a few recordkeeping 

requirements.

• Handlers of solvent-contaminated wipes. These include industrial laundries and dry 

cleaners that clean solvent-contaminated reusable wipes, and solid waste management 

facilities that manage solvent-contaminated disposable wipes once they have been 

discarded (i.e., hazardous and non-hazardous landfills/combustors). Under the final 

rule, handlers are required to manage the solvent-contaminated wipes in non-leaking, 

closed containers that are labeled “Excluded Solvent-Contaminated Wipes.” Free liquids 

removed from the solvent-contaminated wipes or from the container holding the wipes 

must be managed in accordance with the applicable regulations found in 40 CFR Parts 

260 through 273. 

The remainder of this chapter is organized into three sections. Section 2.1 identifies the 

industries that may be affected by the final rule. Section 2.2 estimates the number of facilities 

that generate solvent-contaminated wipes, and the number of solvent-contaminated wipes 

generated each year. Section 2.3 estimates the number of facilities that handle solventcontaminated wipes.

Exhibit 2-1 illustrates the flow of wipes between generators and handlers of solventcontaminated reusable and disposable wipes pre- and post-final rule.

 18 The containers must be able to contain free liquids, should free liquids occur. During accumulation, a 

container is considered closed when there is complete contact between the fitted lid and the rim, except when it is 

necessary to add or remove solvent-contaminated wipes. When the container is full, or when the solventcontaminated wipes are no longer being accumulated, or when the container is being transported, the container must 

be sealed with all lids properly and securely affixed to the container and all openings tightly bound or closed 

sufficiently to prevent leaks and emissions.
21

Generators of

Solvent-Contaminated

Reusable

Wipes

Generators of

SolventContaminated

Reusable AND 

Disposable 

Wipes

Generators of

Solvent-Contaminated

Disposable

Wipes

Hazardous

Waste Management

Facilities

(Landfills and 

Combustors)

Industrial Laundries

and Dry Cleaners

Soiled,

Reusable Wipes Clean,

Reusable Wipes

Soiled, Reusable Wipes

at End of Lifespan

Soiled, Discarded Wipes

Generators of

Solvent-Contaminated

Reusable

Wipes

Generators of

SolventContaminated

Reusable AND 

Disposable

Wipes

Generators of

Solvent-Contaminated

Disposable

Wipes

Hazardous

Waste Management

Facilities

(Landfills and 

Combustors)

Industrial Laundries

and Dry Cleaners

Soiled,

Reusable Wipes Clean,

Reusable Wipes

Soiled, Reusable Wipes

at End of Lifespan

Soiled, Discarded Wipes

Pre-Rule Post-Rule

Non-Hazardous

Waste Management

Facilities

(Landfills and 

Combustors)

Exhibit 2-1

Flow of Wipes between Generators and Handlers

of Solvent-Contaminated Wipes Pre- and Post-Final Rule a

a

 Exhibit is a general representation of the flow of wipes between generators and handlers of solvent-contaminated wipes pre- and 

post-final rule. The exhibit is not meant to illustrate all possible scenarios. 
22

2.1. Industries That Generate or Handle Solvent-Contaminated Wipes

EPA identified 121 industries (based on five- or six-digit North American Industry Classification 

System (NAICS) codes19) that may generate or handle solvent-contaminated wipes and, 

therefore, may be affected by the final rule. In identifying these industries, EPA used 

information derived through a literature search and discussions with key stakeholders and 

industry contacts. Another important source of information was EPA’s Office of Enforcement 

and Compliance Assistance (OECA) Industry Sector Notebooks, which identified potential 

generators of solvent-contaminated wipes by industry.20 This source also identified industry, 

Regional EPA, and state contacts who further assisted in describing the universe of generators 

of solvent-contaminated wipes.

21, 22

Exhibit 2-2 identifies the NAICS codes associated with the 121 industries that generate or 

handle solvent-contaminated wipes. A description of each of these NAICS codes is provided in 

Appendix A. In order to facilitate subsequent discussions, the 121 industries that generate or 

handle solvent-contaminated wipes are grouped into 15 economic sub-sectors (based on threedigit NAICS code), as identified in the exhibit. 

 19 NAICS is the standard used by Federal statistical agencies in classifying business establishments for the 

purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.

20 OECA’s Industry Sector Notebooks is a set of profiles that integrate processes, applicable regulations,

and other relevant environment information for specific industries. For additional information on this data source, 

refer to EPA’s “Sector Notebook” Web page at 

http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/, last accessed on October 19, 

2011.

21 U.S. Environmental Protection Agency. Technical Background Document - Proposed Exclusions from 

the Definition of Hazardous Waste and Solid Waste for Solvent-Contaminated Industrial Wipes. August 20, 2003. 

pp. 25-26.

22 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. pp. 62-65.
23

Exhibit 2-2

Industries that Generate or Handle Solvent-Contaminated Wipes

Economic Sub-Sectors

(3-Digit NAICS Codes)

Industries that Generate or Handle

Solvent-Contaminated Wipes

(5- or 6-Digit NAICS Code) a

Industry 

Count

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Printer

Printing 323110, 323111, 323112, 323113, 323114, 323115, 

323116, 323117, 323118, 323119, 323121, 323122 12

Publishing (printed matter) 51111, 51112, 51113, 51114, 51119 5

Business services (copy shops) 561439 1

Non-Printer

Chemical and Allied Products 211112, 32511, 32512, 325131, 325132, 325181, 

325182, 325188, 325191, 325192, 325193, 325199, 

325998, 331311

14

Plastics and Rubber 31332, 315299, 315999, 325991, 326113, 326121, 

32613, 32614, 32615, 32616, 326199, 326191, 326192, 

326211, 32622, 326291, 326299, 337215 b, 339113, 

339932, 339991

21

Fabricated Metal Products 332812, 332813, 339911, 339912, 339914 5

Industrial Machinery and Equipment 314999, 332323, 33241, 332991, 333111, 33312, 

33322, 333295, 333298, 333319, 333414, 333511, 

333512, 333513, 333514, 333515, 333518, 333911, 

333923, 333999, 33651

21

Furniture and Fixtures 337110, 337121, 337122, 337124, 337127, 337211, 

337212, 337215 b 8

Auto Dealers (retail trade) 44111, 44112 2

Military Bases 92812 1

Electronics and Computers 334411, 334412, 334413 3

Transportation Equipment 332912, 336111, 336112, 336211, 33633, 33634, 

336399, 336312, 336411, 336412, 336414, 336415, 

336419, 336612, 336992, 48839, 54171, 81149

18

Auto Repair and Maintenance 811111, 811112 2

Subtotal 113

Economic Sub-Sectors with Handlers of Solvent-Contaminated Wipes

Solid Waste Management

Hazardous Wastes 562112, 562211 2

Non-Hazardous Wastes 562111, 562212, 562213, 562219, 56292 5

Linen Supply and Laundering 812332 1

Subtotal 8

Total 121

a

 A description of each of the NAICS codes is provided in Appendix A.

b

 NAICS code 337215 (i.e., showcase, partition, shelving, and locker manufacturing) is associated with two economic sub-sectors: “plastics 

and rubber” and “furniture and fixtures.”

Source: U.S. Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact for Conditional 

Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. pp. 62-65.
24

This analysis characterizes each of the economic sub-sectors with generators or handlers of 

solvent-contaminated wipes by compiling information on the number of firms (or companies), 

number of establishments (or facilities), employment, and estimated receipts (or revenues). 

This information is summarized in Exhibit 2-3. Unless otherwise noted, the information in the 

exhibit comes from 2007 Statistics of U.S. Businesses (SUSB) data developed by the U.S. 

Census Bureau.23 

Note that Exhibit 2-3 presents information for the entire economic sub-sectors. However, not all 

facilities within a sub-sector generate or handle solvent-contaminated wipes. The information in 

Exhibit 2-3 is used in Sections 2.2 and 2.3 to estimate the number of generators and handlers of 

solvent-contaminated wipes.

 23 U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six-Digit NAICS 

Code. Available at: http://www.census.gov/econ/susb/data/susb2007.html, last accessed on December 6, 2011.
25

Exhibit 2-3

Economic Characteristics of Sub-Sectors with

Generators or Handlers of Solvent-Contaminated Wipes, 2007 a

Economic Sub-Sectors

Number of

Firms

(Companies)

Number of

Establishments

(Facilities)

Employment

Estimated

Receipts

($1,000) g

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Printers

Printing 31,895 33,281 631,771 $108,140,889

Publishing (printed matter) 17,039 23,082 688,034 $155,742,994

Business services (copy shops) 3,075 5,696 73,324 $8,561,922

Subtotal 52,009 62,059 1,393,129 $272,445,805

Non-Printers

Chemical and Allied Products 2,792 4,121 181,711 $284,974,674

Plastics and Rubber b 15,746 18,508 1,003,327 $259,532,444

Fabricated Metal Products 7,496 7,865 148,747 $31,827,568

Industrial Machinery and Equipment 20,686 21,736 700,954 $218,290,937

Furniture and Fixtures b 18,557 18,985 413,180 $63,926,562

Auto Dealers (retail trade) 46,623 51,236 1,273,660 $800,765,408

Military Bases 5 c 280 d 1,126,866 e, f $0

Electronics and Computers 1,601 1,761 186,734 $83,953,489

Transportation Equipment 27,618 32,552 1,568,893 $662,279,245

Auto Repair and Maintenance 79,988 83,380 348,239 $42,278,290

Subtotal 221,112 240,424 6,952,311 $2,447,828,617

Total 273,121 302,483 8,345,440 $2,720,274,421

Economic Sub-Sectors with Handlers of Solvent-Contaminated Wipes

Solid Waste Management Hazardous Wastes 823 1,331 33,304 $7,528,103

Non-Hazardous Wastes 8,464 11,315 215,248 $51,601,549

Linen Supply and Laundering 503 2,857 107,732 $10,113,579

Total 9,790 15,503 356,284 $69,243,230

Grand Total 282,911 317,986 8,701,724 $2,789,517,651

a

 Unless otherwise noted, information presented in the exhibit is based on data contained in the following data source: U.S. Census Bureau. “Statistics of U.S. 

Businesses (SUSB);” 2007 Annual Data; U.S., Six-Digit NAICS Code. Available at http://www.census.gov/econ/susb/data/susb2007.html, last accessed on 

December 6, 2011.

b

 NAICS code 337215 (i.e., showcase, partition, shelving, and locker manufacturing) is associated with two economic sub-sectors: “plastics and rubber” and 

“furniture and fixtures.” For purposes of this analysis, SUSB data for NAICS code 337215 were divided among these two economic sub-sectors.

c

 Number of military base “firms” consists of the five branches of the U.S. Armed Forces: (1) Army, (2) Navy, (3) Air Force, (4) Marine Corps, and (5) Coast 

Guard.

d

 MilitaryBases.com. “Military Base Directory.” Available at http://militarybases.com/, last accessed on October 19, 2011. Number includes domestic locations 

only. 

e

 Employment data for Army, Navy, Air Force, and Marine Corps obtained from the following data source: U.S. Department of Defense, Defense Manpower Data 

Center, Statistical Information Analysis Division. “Active Duty Military Personnel Strengths by Regional Area and by Country (309A).” June 30, 2011. Available 

at http://siadapp.dmdc.osd.mil/personnel/MILITARY/miltop.htm, last accessed on October 19, 2011. Number includes domestic locations only.

f

 Employment data for Coast Guard obtained from the following data source: U.S. Department of Defense, Defense Manpower Data Center, Statistical 

Information Analysis Division. “Armed Forces Strength Figures for August 31, 2011.” Available at http://siadapp.dmdc.osd.mil/personnel/MILITARY/miltop.htm, 

last accessed on October 19, 2011.

g

 Estimated receipts were updated from 2007 to 2011 dollars using the following data source: U.S. Department of Commerce, Bureau of Economic Analysis. 

“Table 1.1.9. Implicit Price Deflators for Gross Domestic Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, last accessed on November 16, 2011. Year

2007, Quarter IV = 106.958 and Year 2011, Quarter III = 113.823.
26

2.2. Generation of Solvent-Contaminated Wipes

This analysis estimates that, each year, 90,549 facilities generate solvent-contaminated wipes. 

Collectively, these facilities generate 2.2 billion solvent-contaminated wipes each year. The 

remainder of this section describes how these estimates were derived.

2.2.1. Number of Generators of Solvent-Contaminated Wipes

In estimating the number of generators of solvent-contaminated wipes, this analysis employs 

the following assumptions used in the economic background document originally developed for 

the proposed rule.24 These assumptions were used in the derivation of the landfill loading 

estimates that serve as the basis for the risk analysis developed in support of the final rule.25

• 100 percent of printer facilities and 30.4 percent of non-printer facilities generate solventcontaminated wipes.

26, 27, 28 

• Sixty-seven percent of the facilities that generate solvent-contaminated wipes are either 

large quantity generators (LQGs) or small quantity generators (SQGs).29, 30, 31

 24 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. pp. 92-93. 

25 SAIC. Landfill Loadings Calculations For Solvent-Contaminated Wipes. Prepared for the U.S. 

Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17-19. 

26 The economic background document originally developed for the proposed rule assumes that 100 

percent of printers and 35 percent of printers generate solvent-contaminated wipes. These were ORCR’s “best 

estimates” of the percent of facilities that generate solvent-contaminated wipes, based on information supplied by 

industry contacts familiar with wipe usage, industrial site visits, EPA industrial inspectors, and Uniform and Textile 

Services Association (UTSA) “Customer Profile Analysis for 1996.” U.S. Environmental Protection Agency. 

Economics Background Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent 

Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 69. 

27 Based on overall average values from the economic background document for the proposed rule, the 

landfill loading report assumes that 33.5 percent of printer and non-printer facilities generate solvent-contaminated 

wipes in states that are expected to adopt the final rule. If the state adoption assumption (i.e., 75 percent of facilities 

are located in states that are expected to adopt the final rule) is not taken into account, 44.7 percent of printer and 

non-printer facilities generate solvent-contaminated wipes. SAIC. Landfill Loadings Calculations For SolventContaminated Wipes. Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and 

Recovery. July 2010. pp. 17-19. 

28 To be consistent with the assumptions used in the landfill loading report, an adjustment was made to the 

percent of non-printers that generate solvent-contaminated wipes. For purposes of this analysis, it is assumed that 

30.4 percent of non-printers generate solvent-contaminated wipes. 

29 This assumption was obtained from the landfill loading report, and is based on overall average values 

from the economic background document for the proposed rule. In particular, the landfill loading report divides the 

number of LQGs and SQGs that generate solvent-contaminated wipes by the total number of generators of solventcontaminated wipes. SAIC. Landfill Loadings Calculations For Solvent-Contaminated Wipes. Prepared for the U.S. 

Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17-19. U.S. 

Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact for 

Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 93. 

30 LQGs are facilities that generate 1,000 kilograms (2,200 pounds or 1.10 tons) or more of hazardous 

waste in any single calendar month, or more than 1 kilogram (2.2 pounds or 0.001 ton) of acute hazardous waste in 

any single calendar month, or more than 100 kilograms (220 pounds or 0.11 ton) of acute hazardous waste spill 

clean-up material in any single calendar month. 
27

Based on the above assumptions and the data presented in Exhibit 2-3, 135,148 facilities 

(62,059 printers and 73,089 non-printers) generated solvent-contaminated wipes in 2007.32 Of 

these facilities, 90,549 were either LQGs or SQGs and may be subject to the requirements of 

the final rule. 

Because the regulations that apply to hazardous waste generators depend on their generator 

status (e.g., LQG or SQG), generators of solvent-contaminated wipes were divided into LQGs or 

SQGs. To identify LQGs that generated solvent-contaminated wipes in 2007, the analysis relied 

on data from the 2007 Hazardous Waste Report (also known as the Biennial Report or BR).33, 34 

BR data were queried to identify hazardous waste streams for which the waste description 

contained the following key words: “rags,” “wipe,” “cloth,” and/or “towel.” In addition, the 

hazardous waste stream had to be either: (1) a listed F001-F005 hazardous waste solvent, 

(2) contain a corresponding P- or U- listed solvent, or (3) exhibit only the hazardous waste 

characteristic of ignitability (i.e., be reported as a “D001” waste). Exhibit 1-1 lists the Federal 

hazardous waste codes associated with solvent-contaminated wipes. Based on the query 

criteria, a total of 576 LQGs in the identified economic sub-sectors generated solventcontaminated wipes in 2007. As part of this query, information was obtained on the distribution 

of these 576 LQGs among the identified economic sub-sectors. By subtracting the number of 

LQGs from the total number of LQGs and SQGs, EPA determined that a total of 89,973 SQGs

generated solvent-contaminated wipes in 2007.

The analysis then assumes that 92 percent of the generators of solvent-contaminated wipes use 

primarily reusable wipes and eight percent use primarily disposable wipes.

35, 36 Exhibit 2-4 

illustrates the steps taken in the derivation of the number of generators of solvent-contaminated 

wipes.

 31 SQGs are facilities that generate between 100 kilograms (220 pounds or 0.11 ton) and 1,000 kilograms 

(2,200 pounds or 1.10 tons) of hazardous waste in any single calendar month. 

32 Overall, 44.7 percent of the printer and non-printer facilities (i.e., 135,148 /302,482) generated solventcontaminated wipes.

33 The BR must be submitted by LQGs every two years (e.g., 2005, 2007, 2009). As part of this 

submission, LQGs provide detailed data on the types and quantities of hazardous waste they generated during the 

reporting year. 

34 U.S. Environmental Protection Agency. RCRA Info/Biennial Report, Generation and Management (GM) 

Forms (Section 1). Data current as of February 17-21, 2011.

35 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. pp. 92-93. 

36 This assumption was obtained from the landfill loadings report, and is based on overall average values 

from the economic background document for the proposed rule. In particular, the landfill loadings report divides the 

number of generators of solvent-contaminated reusable or disposable wipes by the total number of generators of 

solvent-contaminated wipes. SAIC. Landfill Loadings Calculations For Solvent-Contaminated Wipes. Prepared for 

the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17-19. 

U.S. Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact 

for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 93. 
28

Exhibit 2-4

Derivation of the Number of Generators of Solvent-Contaminated Wipes

Number Establishments (Facilities) in Economic Sub-Sectors 

with Generators of Solvent-Contaminated Wipes

(U.S. Census Bureau, 2007 SUSB Data)

302,483

Printers

62,059

Non-Printers

240,424

Generators SolventContaminated Wipes

62,059

Generators SolventContaminated Wipes

73,089

100% 30.4%

67%

Legend

All Generators of Solvent-Contaminated Wipes 

LQGs (2007 BR)

576

SQGs

89,973

Use

Primarily 

Reusable

Wipes

530

Use

Primarily 

Disposable

Wipes

46

92% 8%

Use

Primarily 

Reusable

Wipes

82,775

Use

Primarily 

Disposable

Wipes

7,198

92% 8%

All Generators of SolventContaminated Wipes 

Printers and Non-Printers)

135,148

LQGs and SQGs

90,549
29

Exhibit 2-5 shows the number of generators of solvent-contaminated wipes for each of the 

identified economic sub-sectors.

Exhibit 2-5

Number of Generators of Solvent-Contaminated Wipes

in Identified Economic Sub-Sectors

Economic

Sub-Sectors

LQGs SQGs Total (LQGs and SQGs)

Use

Primarily

Reusable

Wipes

Use

Primarily

Disposable

Wipes

Subtotal

Use

Primarily

Reusable

Wipes

Use

Primarily

Disposable

Wipes

Subtotal

Use

Primarily

Reusable

Wipes

Use

Primarily

Disposable

Wipes

Total

Printers

Printing 39 3 42 20,475 1,781 22,256 20,514 1,784 22,298

Publishing

(printed matter) 1 0 1 14,227 1,237 15,464 14,228 1,237 15,465

Business services

(copy shops) 2 0 2 3,509 305 3,814 3,511 305 3,816

Subtotal 42 3 45 38,211 3,323 41,534 38,253 3,326 41,579

Non-Printers

Chemical and

Allied Products 51 4 55 722 63 784 772 67 839

Plastics and Rubber 100 10 110 3,367 293 3,660 3,467 303 3,770

Fabricated

Metal Products 74 6 80 1,400 122 1,522 1,474 128 1,602

Industrial Machinery

and Equipment 29 3 32 4,044 352 4,395 4,073 354 4,427

Furniture and

Fixtures 24 2 26 3,534 307 3,841 3,558 309 3,867

Auto Dealers

(retail trade) 1 0 1 9,600 835 10,435 9,601 835 10,436

Military Bases 0 0 0 52 5 57 52 5 57

Electronics

and Computers 65 6 71 265 23 288 330 29 359

Transportation

Equipment 143 12 155 5,957 518 6,475 6,100 530 6,630

Auto Repair and

Maintenance 1 0 1 15,623 1,359 16,982 15,624 1,359 16,983

Subtotal 488 43 531 44,564 3,875 48,439 45,051 3,919 48,970

Total 530 46 576 82,776 7,198 89,973 83,303 7,245 90,549
30

2.2.2. Annual Number of Solvent-Contaminated Wipes

To estimate the number of solvent-contaminated wipes generated each year, the analysis first 

estimates the annual number of solvent-contaminated reusable and disposable wipes generated 

per facility. The analysis, then, excludes disposable wipes used in conjunction with 

trichloroethylene because these wipes are not eligible for the conditional exclusion under the 

final rule.37 The following paragraphs describe the derivation of these estimates.

Exhibit 2-6 presents EPA’s best estimates of the average annual number of solventcontaminated wipes generated by a single facility in the identified economic sub-sectors. These 

estimates are based on overall average values from the economic background document 

originally developed for the proposed.38

Exhibit 2-6

Average Annual Number of Solvent-Contaminated Wipes Generated per Facility

Economic Sub-Sectors

LQGs SQGs

Reusable

Wipes

Disposable

Wipes

Reusable

Wipes

Disposable

Wipes

Printers

Printing 186,100 74,200 19,800 7,900

Publishing (printed matter) 166,600 66,800 17,700 7,100

Business services (copy shops) 160,300 64,500 17,000 6,800

Chemical and Allied Products 112,000 173,600 27,700 42,900

Plastics and Rubber 113,900 176,500 28,100 43,700

Fabricated Metal Products 109,700 169,900 27,100 42,000

Industrial Machinery and Equipment 141,000 219,400 34,800 54,000

Furniture and Fixtures 111,300 172,900 27,500 42,600

Auto Dealers (retail trade) 105,500 163,700 26,100 40,400

Military Bases 126,000 171,000 31,800 46,700

Electronics and Computers 268,000 416,100 66,200 102,500

Transportation Equipment 104,000 161,500 25,700 39,900

Auto Repair and Maintenance 100,000 185,000 25,200 39,000

Source: U.S. Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact 

for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003.

The average annual number of solvent-contaminated wipes generated per facility (Exhibit 2-6) 

was multiplied by the corresponding number of facilities (Exhibit 2-5) in order to come up with 

the total annual number of solvent-contaminated wipes generated by facilities in the identified 

economic sub-sectors.

 37 The analysis does include reusable wipes used in conjunction with trichloroethylene because these wipes 

are eligible for the conditional exclusion under the final rule. 

38 In particular, the analysis uses the “annual number of RCRA solvent waste industrial wipes generated per 

applicable establishment.” These estimates were rounded to the nearest hundred. U.S. Environmental Protection 

Agency. Economics Background Document - Estimate of National Economic Impact for Conditional Exclusion of 

Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 94. 
31

Note, however, that disposable wipes used in conjunction with trichloroethylene are not eligible 

for the conditional exclusion under the final rule. Based on review of several data sources on 

chemical content in wipes, EPA estimated that, on average, 1.8 percent of disposable wipes 

generated by the identified economic sub-sectors contain trichloroethylene.39 Therefore, the 

number of eligible solvent-contaminated disposable wipes is determined by taking the total 

number of solvent-contaminated disposable wipes minus the number of wipes contaminated 

with trichloroethylene.

Exhibit 2-7 shows the total annual number of solvent-contaminated wipes generated by each of 

the identified economic sub-sectors.

 39 This assumption was obtained from the landfill loading report, and is based on information from several 

data sources, including the 2003 BR; industrial cleaning solvents development data; and 2004 Toxics Release 

Inventory (TRI) and a similar Massachusetts program, the 2004 Toxics Use Reduction Act (TURA). SAIC. Landfill 

Loadings Calculations For Solvent-Contaminated Wipes. Prepared for the U.S. Environmental Protection Agency, 

Office of Resource Conservation and Recovery. July 2010. p. 16.
32

Exhibit 2-7

Total Annual Number of Solvent-Contaminated Wipes Generated

by Facilities in the Identified Economic Sub-Sector (in Millions)

Economic

Sub-Sectors

LQGs SQGs Total (LQGs and SQGs)

Reusable

Wipes

Disposable

Wipes Subtotal ReusableWipes

Disposable

Wipes Subtotal ReusableWipes

Disposable

Wipes Total

Printer

Printing 7.19 0.24 7.44 405.41 13.81 419.22 412.60 14.06 426.66

Publishing

(printed matter) 0.15 0.01 0.16 251.81 8.63 260.44 251.97 8.63 260.60

Business services

(copy shops) 0.29 0.01 0.31 59.66 2.04 61.69 59.95 2.05 62.00

Subtotal 7.64 0.26 7.90 716.88 24.48 741.36 724.52 24.74 749.26

Non-Printer

Chemical and

Allied Products 5.67 0.75 6.42 19.99 2.64 22.63 25.66 3.39 29.05

Plastics and Rubber 11.39 1.73 13.12 94.61 12.56 107.17 106.00 14.30 120.30

Fabricated

Metal Products 8.07 1.07 9.14 37.95 5.02 42.97 46.02 6.09 52.11

Industrial Machinery

and Equipment 4.15 0.55 4.70 140.72 18.65 159.36 144.87 19.20 164.06

Furniture and

Fixtures 2.66 0.35 3.02 97.17 12.85 110.03 99.84 13.21 113.04

Auto Dealers

(retail trade) 0.10 0.01 0.11 250.56 33.12 283.68 250.66 33.13 283.79

Military Bases 0.00 0.00 0.00 1.67 0.21 1.88 1.67 0.21 1.88

Electronics

and Computers 17.51 2.32 19.83 17.52 2.32 19.84 35.03 4.64 39.66

Transportation

Equipment 14.83 1.97 16.80 153.10 20.30 173.40 167.93 22.26 190.19

Auto Repair and

Maintenance 0.09 0.01 0.11 393.71 52.03 445.74 393.80 52.04 445.84

Subtotal 64.47 8.77 73.24 1,206.99 159.70 1,366.69 1,271.46 168.47 1,439.93

Total 72.11 9.03 81.14 1,923.87 184.17 2,108.05 1,995.98 193.21 2,189.19
33

2.3. Handling of Solvent-Contaminated Wipes

This analysis estimates that 359 industrial laundries/dry cleaners and 3,730 solid waste 

management facilities handle solvent-contaminated wipes each year. The remainder of this 

section describes the derivation of these estimates.

2.3.1. Number of Handlers of Solvent-Contaminated Reusable Wipes

Based on data submitted to EPA in response to the October 27, 2009, Notice of Data 

Availability (NODA)40, EPA estimates that, on average, a single industrial laundry or dry cleaner 

processes 509,498 pounds of reusable wipes each year (i.e., 196,605 pounds of printer towels 

and 312,893 pounds of shop towels).41 EPA also estimates that, on average, the weight of a 

solvent-contaminated wipe generated by a printer facility is 0.11 pounds (50 grams) and that the 

weight of a solvent-contaminated wipe generated by a non-printer facility is 0.08 pounds (37.5 

grams). 42 Thus, based on a weighted average, the weight of a solvent-contaminated wipe is 

estimated at 0.0917 pounds.

Based on the above assumptions, this analysis estimates that, collectively, industrial laundries 

and dry cleaners process a total of 183,031,338 pounds of solvent-contaminated reusable wipes 

each year (i.e., 2.0 billion reusable wipes (Exhibit 2-7) x 0.0917 pounds per wipe). 

To estimate the number of industrial laundries and dry cleaners that may be affected by the final 

rule, EPA takes the total annual pounds of solvent-contaminated reusable wipes processed by 

all industrial laundries/dry cleaners and divides this number by 509,498, i.e., the pounds of 

solvent-contaminated reusable wipes processed per industrial laundry/dry cleaner each year. 

Based on this calculation, EPA estimates the number of industrial laundries/dry cleaners that 

may be affected by the final rule to be 359 (i.e., 183,031,338 / 509,498).

2.3.2. Number of Handlers of Solvent-Contaminated Disposable Wipes

This analysis estimates a total of 3,730 solid waste management facilities may be affected by 

the final rule. This estimate includes 1,331 hazardous waste management facilities (Exhibit 2-3) 

and 2,399 non-hazardous waste management facilities. The number of non-hazardous waste 

management facilities is based on data from the Waste Business Journal’s “Directory & Atlas of

Non-Hazardous Waste Sites 2007,” and only includes active municipal solid waste landfills

(2,264 facilities) and active solid waste combustion/incineration facilities (135 facilities), as of 

2007.

 40 U.S. Government Printing Office. Federal Register. “Hazardous Waste Management System: 

Identification and Listing of Hazardous Waste: Conditional Exclusion From Hazardous Waste and Solid Waste for 

Solvent-Contaminated Industrial Wipes,” Notice of Data Availability (NODA). 74 FR 55163. October 27, 2009.

41 This estimate was obtained from the landfill loading report developed for the final rule, and is based on 

survey data submitted by the Textile Rental Services Association of America (TRSA). SAIC. Landfill Loadings 

Calculations For Solvent-Contaminated Wipes. Prepared for the U.S. Environmental Protection Agency, Office of 

Resource Conservation and Recovery. July 2010. p. 34.

42 These assumptions were obtained from the technical background document for the proposed rule, and 

are based on data collected from EPA site visits. U.S. Environmental Protection Agency. Technical Background 

Document - Proposed Exclusions from the Definition of Hazardous Waste and Solid Waste for Solvent-Contaminated 

Industrial Wipes. August 20, 2003. p. 102.
34

3. Existing Regulatory Environment and the Affected Universe 

This chapter provides an overview of the existing regulations applicable to the generation and 

management of solvent-contaminated wipes. In addition, it establishes the regulatory baseline 

of the analysis, and identifies the affected universe. This information is used in Chapters 4 and 

5 to estimate the costs and benefits of the final rule.

3.1. Existing Regulations Applicable to Solvent-Contaminated Wipes

3.1.1. Federal Regulations Applicable to Generators and Handlers of 

Solvent-Contaminated Wipes 

Although there are currently no national guidelines for the management of solvent-contaminated 

wipes, numerous regulations established under the authority of RCRA do currently apply to 

generators and handlers of solvent-contaminated wipes if they are considered to be hazardous 

wastes. 

The most stringent interpretation of the Federal regulations under RCRA would subject all the 

following solvent-contaminated wipes to the hazardous waste regulations: (1) solventcontaminated wipes that are listed as a hazardous waste under 40 CFR Part 261, Subpart D; 

(2) solvent-contaminated wipes that exhibit one or more of the characteristics of hazardous 

waste identified in 40 CFR Part 261, Subpart C; (3) solvent-contaminated wipes that are a 

mixture of a solid waste and a listed hazardous waste; and (4) solvent-contaminated wipes that 

are a mixture of a solid waste and a characteristic hazardous waste, and the resultant mixture 

exhibits one or more of the characteristics of hazardous waste.

Under the Federal RCRA regulations, wipes contaminated with listed hazardous waste solvents 

(i.e., EPA hazardous waste codes F001-F005)43 are considered to be listed hazardous wastes, 

and they are required to be managed in accordance with all applicable hazardous waste

management requirements (e.g., storage standards, recordkeeping, and hazardous waste 

manifest). In addition, wipes contaminated with spent solvents that are hazardous wastes 

because they exhibit one or more of the characteristics of hazardous waste also are considered 

hazardous wastes. As hazardous wastes, these solvent-contaminated wipes are required to be 

managed in accordance with all applicable RCRA hazardous waste management requirements 

as well.

EPA’s current policy with respect to the regulatory status of solvent-contaminated wipes is to 

defer the determination of whether solvent-contaminated wipes must be managed as a solid or 

hazardous waste to the EPA Regional Offices and state agencies due to case-specific 

circumstances (e.g., type of solvent used, degree of hazard, when a spent solvent is generated, 

and whether the hazardous waste mixture rule applies to a particular waste). 

The majority of the states have developed their own policies governing the management of

solvent-contaminated wipes. However, a few states have deferred regulatory decisions 

regarding the management of solvent-contaminated wipes to their respective EPA Regional 

Offices. Thus, different regulatory schemes for solvent-contaminated wipes apply in different 

states. 

 43 Refer to Exhibit 1-1 for a description of EPA hazardous waste codes F001 through F005.
35

3.1.2. State Policies Applicable to Generators and Handlers of 

Solvent-Contaminated Wipes

Most states have developed policies that provide conditional relief for solvent-contaminated 

reusable wipes either from solid waste or hazardous waste regulations, or set management 

standards for handlers of solvent-contaminated wipes.44 An overview of existing state policies 

is provided below.

3.1.2.1. State Policies on Solvent-Contaminated Reusable Wipes

Forty-five states have implemented policies stating that reusable wipes contaminated with listed 

or characteristic hazardous waste solvents that are managed at industrial laundries or dry 

cleaners need not be managed as a hazardous waste, as long as specific conditions are met. 

The remaining five states (Arkansas, Idaho, Maine, South Dakota, and West Virginia) regulate 

reusable wipes as hazardous waste if they contain a listed hazardous waste or exhibit a 

hazardous waste characteristic, even when they are being laundered.

Many states that provide regulatory relief for solvent-contaminated reusable wipes consider 

laundering to be a form of recycling and thus, exclude solvent-contaminated reusable wipes 

from RCRA regulation based on the state’s interpretation of the definition of solid waste. Other 

states consider solvent-contaminated reusable wipes a solid waste, but provide conditional 

exclusions from the hazardous waste regulations. In either case, to meet the exclusion, the 

solvent-contaminated reusable wipes typically must meet at least the following criteria:

• The wipes contain “no free liquids;” and

• The industrial laundry handling the wipes must manage its wastewater discharges in 

accordance with applicable wastewater discharge requirements (i.e., the laundry must 

discharge its wastewaters to a POTW with an approved pretreatment program or have a 

wastewater discharge permit).

States have different policies on what constitutes “no free liquids” and how to make this 

determination. However, the majority of states use the Paint Filter Liquids Test (SW-846 

Method 9095) to make such determinations. Other specified methods for making the “no free 

liquids” determination include: either physical or mechanical wringing until the wipe meets the 

“no drip” criterion, the Liquids Release Test (SW-846 Method 9096), and the toxicity 

characteristic leaching procedure (TCLP; SW-846 Method 1311). Only a few states consider 

wringing or solvent-extraction processes applied to solvent-contaminated wipes to remove “free 

liquids” as a form of treatment of a hazardous waste.

45 Several states specify that removing 

“free liquids” through evaporation or intentional drying is not allowed.

 44 U.S. Environmental Protection Agency. Technical Background Document - Proposed Exclusions from 

the Definition of Hazardous Waste and Solid Waste for Solvent-Contaminated Industrial Wipes. August 20, 2003. 

p. 39.

45 As defined at 40 CFR 260.10, “treatment” means any method, technique, or process, including 

neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous 

waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to 

render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for 

recovery, amenable for storage, or reduced in volume.
36

A few states require generators to extract solvent from reusable wipes prior to sending them 

off-site to ensure that “free liquids” are not transported offsite. Industrial laundries also often 

urge their customers to remove solvents from the wipes prior to being transported off-site to 

ensure compliance with DOT hazardous materials transportation requirements and pretreatment 

requirements from the local POTW.

In many states, the burden of determining whether a solvent-contaminated wipe should be 

managed as a hazardous waste is placed on the generator. However, some states specifically 

maintain that industrial laundries are obligated to accept only solvent-contaminated wipes that

meet specified criteria. Otherwise, the laundry is considered to be a hazardous waste

management facility and must comply with all applicable RCRA hazardous waste management 

requirements. A few states allow on-site laundering of solvent-contaminated wipes by 

generators, provided there is an agreement on file with the state that allows the facility to 

discharge to the sanitary sewer. In addition, some states require contractual agreements

between generators and industrial laundries for the generator to qualify for an exclusion from 

RCRA regulation.

While the majority of state policies governing the management of solvent-contaminated 

reusable wipes are similar, there are some states with variations.46 For purposes of this 

analysis, however, 45 states are assumed to have a conditional exclusion from the definition of 

solid waste for solvent-contaminated reusable wipes.

3.1.2.2. State Policies on Solvent-Contaminated Disposable Wipes

Currently, Massachusetts is the only state that has a conditional exclusion for solventcontaminated disposable wipes.

47 All other states regulate solvent-contaminated wipes as 

hazardous waste when they are contaminated with a listed solvent or exhibit a hazardous waste 

characteristic, and the wipes are destined for disposal.48

3.2. Regulatory Baseline

As noted above, EPA’s existing policy on solvent-contaminated wipes has led to the application 

of different regulatory schemes for solvent-contaminated wipes across the country. 

Consequently, the anticipated impact of the final rule will vary by state, depending on whether 

they have existing state policies addressing solvent-contaminated wipes.

Some significant state policies regarding the management of solvent-contaminated wipes are 

summarized below:

 46 For example, in Hawaii, solvent-contaminated reusable wipes must be managed as hazardous waste up 

until the point at which they are laundered. This implies that solvent-contaminated reusable wipes would have to be 

managed in accordance with all applicable hazardous waste management requirements (e.g., storage standards, 

recordkeeping, and hazardous waste manifest). However, this analysis does not distinguish Hawaii from other states 

that do not require the management of solvent-contaminated reusable wipes as hazardous waste. 

47 For additional information on Massachusetts’ policy for solvent-contaminated wipes, refer to 

Massachusetts Department of Environmental Protection’s Policy BWP-94-015, “Policy for Industrial Wipers 

Contaminated with Solvents,” dated February 16, 1994. Available at: 

http://www.mass.gov/dep/recycle/laws/solwiper.htm, last accessed on November 9, 2011. 

48 U.S. Environmental Protection Agency. Technical Background Document - Proposed Exclusions from 

the Definition of Hazardous Waste and Solid Waste for Solvent-Contaminated Industrial Wipes. August 20, 2003. 

p. 39.
37

• Forty-five states provide regulatory relief for solvent-contaminated reusable wipes, as 

long as certain basic conditions are met.

• Five states (Arkansas, Idaho, Maine, South Dakota, and West Virginia) regulate solventcontaminated reusable wipes as hazardous waste.

• Massachusetts is the only state that has a conditional exclusion for solventcontaminated disposable wipes.

49 All other states regulate solvent-contaminated wipes 

as hazardous waste when they are contaminated with a listed solvent or exhibit a 

hazardous waste characteristic, and the wipes are destined for disposal.50

Under the regulatory baseline used in this analysis, it is assumed that:

• Twenty-five percent of facilities will not be affected by the final rule, either because they 

are located in states that have exclusions similar to the ones in EPA’s final rule, or 

because they are located in states that currently have no conditional exclusions for 

solvent-contaminated wipes. These states are expected to decide not to adopt EPA’s 

final rule.

• Seventy-five percent of facilities will be affected by the final rule because they are 

located in states that currently have conditional exclusions for solvent-contaminated 

wipes different from the exclusions in the final rule. These states are expected to adopt 

EPA’s final rule. 

Based on the above, this analysis assumes that 75 percent of the LQGs and SQGs that 

generate solvent-contaminated wipes are located in states that are expected to adopt the final 

rule, and consequently these LQGs and SQGs will incur incremental costs or savings as a result 

of the final rule. All wipes generated by these LQGs and SQGs will enter the non-hazardous 

waste stream. These assumptions are consistent with the economic background document 

originally developed for the proposed51 rule and the landfill loadings report that serves as the 

basis for the risk analysis developed in support of the final rule.52

 49 For additional information on Massachusetts’ policy for solvent-contaminated wipes, refer to 

Massachusetts Department of Environmental Protection’s Policy BWP-94-015, “Policy for Industrial Wipers 

Contaminated with Solvents,” dated February 16, 1994. Available at: 

http://www.mass.gov/dep/recycle/laws/solwiper.htm, last accessed on November 9, 2011. 

50 U.S. Environmental Protection Agency. Technical Background Document - Proposed Exclusions from 

the Definition of Hazardous Waste and Solid Waste for Solvent-Contaminated Industrial Wipes. August 20, 2003. 

p. 39.

51 The economic background document developed for the proposed rule assumes that 75 percent of the 

facilities that generate solvent-contaminated wipes are located in states that are expected to adopt the final rule. This 

assumption was ORCR’s “best estimate” of the percent of facilities in states that are expected to adopt the final rule. 

U.S. Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact 

for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 34.

52 The landfill loading report developed for the final rule obtained the 75 percent state adoption assumption 

from the economic background document originally developed for the proposed rule. SAIC. Landfill Loadings 

Calculations For Solvent-Contaminated Wipes. Prepared for the U.S. Environmental Protection Agency, Office of 

Resource Conservation and Recovery. July 2010. p. 7.
38

In order to simplify the analysis, states that have conditional exclusions all are assumed to have 

similar conditions for their exclusions. These conditions require laundering and reuse of the 

solvent-contaminated wipes, and that the wipes contain “no free liquids.” 

 

Exhibits 3-1 and 3-2 show the number of generators and solvent-contaminated wipes in states 

that are expected to adopt the final rule. The estimates presented in these exhibits represent 75 

percent of the generators and solvent-contaminated wipes affected by the final rule (i.e., 75 

percent of the generators in Exhibit 2-5 and 75 percent of solvent-contaminated wipes in 

Exhibit 2-7). 
39

Exhibit 3-1

Number of Generators of Solvent-Contaminated Wipes

in States that Are Expected to Adopt the Final Rule

Economic

Sub-Sectors

LQGs SQGs Total (LQGs and SQGs)

Use

Primarily

Reusable

Wipes

Use

Primarily

Disposable

Wipes

Subtotal

Use

Primarily

Reusable

Wipes

Use

Primarily

Disposable

Wipes

Subtotal

Use

Primarily

Reusable 

Wipes

Use

Primarily

Disposable

Wipes

Total

Printers

Printing 29 3 32 15,356 1,335 16,692 15,385 1,338 16,723

Publishing

(printed matter) 1 0 1 10,670 928 11,598 10,671 928 11,599

Business services

(copy shops) 1 0 2 2,632 229 2,861 2,633 229 2,862

Subtotal 31 3 34 28,658 2,492 31,151 28,690 2,495 31,184

Non-Printers

Chemical and

Allied Products 38 3 41 541 47 588 579 50 630

Plastics and Rubber 75 8 83 2,525 220 2,745 2,600 227 2,827

Fabricated

Metal Products 55 5 60 1,050 91 1,141 1,105 96 1,201

Industrial Machinery

and Equipment 22 2 24 3,033 264 3,296 3,055 266 3,320

Furniture and

Fixtures 18 2 20 2,650 230 2,881 2,668 232 2,900

Auto Dealers

(retail trade) 1 0 1 7,200 626 7,826 7,201 626 7,827

Military Bases 0 0 0 39 3 43 39 3 43

Electronics

and Computers 49 4 53 198 17 216 247 22 269

Transportation

Equipment 107 9 116 4,468 389 4,856 4,575 398 4,973

Auto Repair and

Maintenance 1 0 1 11,717 1,019 12,736 11,718 1,019 12,737

Subtotal 365 33 398 33,423 2,906 36,329 33,788 2,939 36,727

Total 397 35 432 62,081 5,398 67,479 62,478 5,434 67,911
40

Exhibit 3-2

Total Annual Number of Solvent-Contaminated Wipes

in States that Are Expected to Adopt the Final Rule (in Millions)

Economic

Sub-Sectors

LQGs SQGs Total (LQGs and SQGs)

Reusable

Wipes

Disposable

Wipes Subtotal ReusableWipes

Disposable

Wipes Subtotal ReusableWipes

Disposable

Wipes Total

Printer

Printing 5.39 0.18 5.58 304.06 10.36 314.42 309.45 10.54 319.99

Publishing

(printed matter) 0.11 0.00 0.12 188.86 6.47 195.33 188.98 6.47 195.45

Business services

(copy shops) 0.22 0.01 0.23 44.74 1.53 46.27 44.96 1.54 46.50

Subtotal 5.73 0.20 5.92 537.66 18.36 556.02 543.39 18.55 561.94

Non-Printer

Chemical and

Allied Products 4.25 0.56 4.81 14.99 1.98 16.97 19.24 2.55 21.79

Plastics and Rubber 8.54 1.30 9.84 70.96 9.42 80.38 79.50 10.72 90.22

Fabricated

Metal Products 6.06 0.80 6.86 28.46 3.77 32.23 34.51 4.57 39.08

Industrial Machinery

and Equipment 3.11 0.41 3.53 105.54 13.98 119.52 108.65 14.40 123.05

Furniture and

Fixtures 2.00 0.26 2.26 72.88 9.64 82.52 74.88 9.91 84.78

Auto Dealers

(retail trade) 0.07 0.01 0.08 187.92 24.84 212.76 187.99 24.85 212.84

Military Bases 0.00 0.00 0.00 1.25 0.16 1.41 1.25 0.16 1.41

Electronics

and Computers 13.13 1.74 14.87 13.14 1.74 14.88 26.27 3.48 29.75

Transportation

Equipment 11.12 1.47 12.60 114.82 15.22 130.05 125.95 16.70 142.64

Auto Repair and

Maintenance 0.07 0.01 0.08 295.28 39.02 334.30 295.35 39.03 334.38

Subtotal 48.35 6.58 54.93 905.24 119.77 1,025.02 953.59 126.35 1,079.95

Total 54.08 6.77 60.85 1,442.90 138.13 1,581.03 1,496.98 144.90 1,641.89
41

4. Estimated Costs and Savings of the Final Rule

This chapter estimates the compliance costs and savings of the final rule. Section 4.1 

summarizes the annual costs and savings of the final rule. Section 4.2 reports on these costs 

and savings by type of facility. Section 4.3 describes the derivation of each of the cost elements 

that contribute to total costs and savings. 

4.1. Summary of Costs and Savings

EPA estimates the total one-time cost of the final rule across all facilities at approximately $1.2 

million (2011 dollars). EPA also estimates the total annual costs to be approximately $6.3

million and the total annual savings to be approximately $24.4 million across all affected 

facilities. EPA evaluated these costs and savings over a 10-year period53, using real discount 

rates of 7 percent, 3 percent, and 0 percent.54 

To estimate the annualized costs and savings, when payments are due at the beginning of each 

period, the analysis uses the following equation:

AC = PVC x

r x (1 + r)n-1

(1 + r)

n – 1

where AC is the annualized cost (payment) accrued at the beginning of each of n

periods; PVC is the present value of costs (payments); r is the discount rate per period

(e.g., 7 percent per year, 3 percent per year); and n is the annualization period (in this 

case, 10 years).

PVC is calculated by multiplying the value of the cost in each year by a time-dependent discount 

factor, d, and summing all of the discounted values as shown in the following equation: 

PVC = d0V0 + d1V1 + d2V2 + ... + dn–1Vn–1 + dnVn

where Vn is the value of the cost (payment) accrued at the beginning of each of n

periods. The discounting factor, dn, is defined as: 

dn = 1

(1 + r)n-1

 53 Under the final rule, the only one-time cost element is reading the regulations. All other cost and savings 

elements are estimated on an annual basis. The analysis evaluates costs and savings over a 10-year period in order 

to avoid understating the impacts associated with the one-time costs.

54 In annualizing the costs and benefits, the analysis uses a procedure consistent with EPA’s guidelines for 

discounting future costs and benefits. U.S. Environmental Protection Agency. Guidelines for Preparing Economic 

Analyses, “Chapter 6, Discounting Future Benefits and Costs.” December 17, 2010. Available at: 

http://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0568-50.pdf/$file/EE-0568-50.pdf, last accessed on December 8, 

2011.
42

where r is the discount rate, and n is the number of years in the annualization period (in 

this case, 10 years). 

The analysis then uses annualized one-time costs, annual costs, and annual savings to 

estimate the net savings of the final rule, as follows:

Net Savings = [Annual Savings] – ([Annualized One-Time Costs] + [Annual Costs])

Exhibit 4-1 shows the annual costs and savings of the final rule. As shown in the exhibit, at all 

three discount rates, the annual net savings of the final rule are estimated to be approximately 

$18.0 million (2011 dollars).

Exhibit 4-1

Annual Costs and Savings of the Final Rule, 2011 Dollars a

Type of Impacts 7%

Discount Rate

3%

Discount Rate

0%

Discount Rate

Annualized One-Time Cost b $163,630 $139,961 $122,971 

Annual Costs c $6,261,270 $6,261,270 $6,261,270 

Annual Savings d $24,375,585 $24,375,585 $24,375,585

Net Savings e $17,950,686 $17,974,354 $17,991,344

a Costs and savings are evaluated over a 10-year period.

b

 One-time costs include: reading the final rule. Total one-time costs for all affected facilities are presented in Exhibit 4-4 of this document.

c

 Annual costs include: (1) becoming familiar with the final rule requirements and implementation procedures/practices, (2) purchase of 

containers, (3) purchase of labels, (4) affixing labels to containers, (5) removing "free liquids" from containers, (6) recordkeeping 

requirements under the final rule, and (7) demonstrating compliance with final rule requirements. Total annual costs for all affected facilities 

are presented in Exhibit 4-4 of this document.

d

 Annual savings include: (1) management of “free liquids” removed from containers, (2) avoided hazardous waste manifest costs, (3) 

avoided disposal costs, (4) avoided RCRA information collection requirement costs to SQGs that may become CESQGs, and (5) avoided 

state waste fees and taxes. Total annual savings for all affected facilities are presented in Exhibit 4-4 of this document.

e Net savings = [Annual Savings] – ([Annualized One-Time Costs] + [Annual Costs])

4.2. Costs and Savings by Type of Facility

Exhibit 4-2 summarizes the break out of costs and savings for affected facilities based on type 

of facility (i.e., LQG, SQG, or handling facility) and type of wipe (i.e., reusable or disposable). 

The exhibit also shows the per-facility costs (savings) and number of affected facilities used to 

estimate total costs and savings.
43

Exhibit 4-2

Summary of Estimated Costs and Savings

of the Final Rule by Types of Facility, 2011 Dollars a

Type of Facilities Type of Wipes Per-Facility

Costs (Savings) f

Number of 

Affected 

Facilities g

Total

Costs (Savings)

for All Affected 

Facilities h

One-Time Costs b

LQGs

Reusable Wipes $39 530 $20,412 

Disposable Wipes $39 46 $1,772 

SQGs

Reusable Wipes $13 82,776 $1,062,634 

Disposable Wipes $13 7,198 $92,402 

Handling Facilities f Reusable Wipes $13 359 $4,612 

Disposable Wipes $13 3,730 $47,884 

Total One-Time Costs $1,229,715

Annual Costs c

LQGs

Reusable Wipes $366 397 $145,131 

Disposable Wipes $469 35 $16,629 

SQGs

Reusable Wipes $88 62,081 $5,470,066 

Disposable Wipes $95 5,398 $511,329 

Handling Facilities e Reusable Wipes $39 269 $10,376 

Disposable Wipes $39 2,798 $107,739 

Total Annual Costs $6,261,270

Annual Savings d

LQGs

Reusable Wipes $0 397 $0 

Disposable Wipes $30,489 35 $1,081,147

SQGs

Reusable Wipes $0 62,081 $0 

Disposable Wipes $4,207 5,398 $22,711,561

Handling Facilities e Reusable Wipes $0 269 $0 

Disposable Wipes $208 2,798 $582,877

Total Annual Savings $24,375,585

a

 Costs are rounded to the nearest whole number.

b

 One-time costs include: reading the final rule.

c

 Annual costs include: (1) becoming familiar with the final rule requirements and implementation procedures/practices, (2) purchase of containers, 

(3) purchase of labels, (4) affixing labels to containers, (5) removing "free liquids" from containers, (6) recordkeeping requirements under the final 

rule, and (7) demonstrating compliance with final rule requirements.

d

 Annual savings include: (1) management of “free liquids” removed from containers, (2) avoided hazardous waste manifest costs, (3) avoided 

disposal costs, (4) avoided RCRA information collection requirement costs to SQGs that may become CESQGs, and (5) avoided state waste fees 

and taxes.

e

 For solvent-contaminated disposable wipes, handling facilities include hazardous waste management facilities, municipal solid waste landfill 

facilities, and solid waste combustion facilities. For solvent-contaminated reusable wipes, handling facilities include industrial laundries and dry 

cleaners.

f

 Per-facility costs (savings) are summarized in Exhibit 4-3.

g

 For one-time costs, affected facilities include generators and handlers of solvent-contaminated wipes in all states (see Sections 2.2.1 and 2.3 of 

this document). For annual costs and savings, affected facilities include generators and handlers of solvent-contaminated wipes in states that are 

expected to adopt the final rule (see Section 3.2 of this document). 

h

 Total Costs (Savings) for All Affected Facilities = [Per-Facility Costs (Savings)] x [Number of Affected Facilities].
44

For purposes of this analysis, one-time costs include:

• Reading the final rule.

Annual costs include:

• Becoming familiar with the final rule requirements and implementation 

procedures/practices.

• Purchase of containers.

• Purchase of labels.

• Affixing labels to containers.

• Removing "free liquids" from containers.

• Recordkeeping requirements under the final rule.

• Demonstrating compliance with final rule requirements.

Annual savings include:

• Management of “free liquids” removed from containers.

• Avoided hazardous waste manifest costs.

• Avoided disposal costs.

• Avoided RCRA information collection requirement costs to SQGs that may become 

CESQGs.

• Avoided state waste fees and taxes.

Exhibit 4-3 summarizes the average per-facility costs (savings) associated with each of the 

various cost elements that contribute to the total costs and savings. Section 4.3 describes the 

derivation of the estimated average per-facility costs (savings) for each of these cost elements.
45

Exhibit 4-3

Average Per-Facility Costs and Savings of the Final Rule, 2011 Dollars a, b, c

Cost Elements

Reusable Wipes Disposable Wipes

LQGs SQGs Handling

Facilities LQGs SQGs HandlingFacilities

One-Time Costs

Familiarization 

with the

Final Rule

Reading the Final Rule $39 $13 $13 $39 $13 $13 

Annual Costs

Familiarization 

with the

Final Rule

Becoming Familiar with the Final Rule 

Requirements and Implementation 

Procedures/Practices

$116 $39 $39 $116 $39 $39 

Containers

for SolventContaminated 

Wipes

Purchase of Closed Containers $27 $5 Not

Applicable $25 $3 NotApplicable

Purchase of Labels $152 $26 Not

Applicable $140 $19 NotApplicable

Affixing Labels to Containers $63 $11 Not

Applicable $59 $8 NotApplicable

Management of 

"Free Liquids"

Removing "Free Liquids"

from Containers

Not

Applicable

Not

Applicable

Not

Applicable $121 $18 NotApplicable

Management of "Free Liquids" 

Removed from Containers

Not

Applicable

Not

Applicable

Not

Applicable ($75) ($23) NotApplicable

Off-Site 

Management

of SolventContaminated 

Wipes

Avoided Hazardous Waste

Manifest Costs

Not

Applicable

Not

Applicable

Not

Applicable ($597) ($77) ($208)

Avoided Disposal Costs Not

Applicable

Not

Applicable

Not

Applicable ($29,639) ($3,970) NotApplicable

Information 

Collection 

Requirements

Recordkeeping Requirements

under the Final Rule $8 $8 NotApplicable $8 $8 NotApplicable

Demonstrating Compliance with

Final Rule Requirements d $0 $0 Not

Applicable

Not

Applicable

Not

Applicable

Not

Applicable

Avoided RCRA Information Collection 

Requirement Costs for SQGs

that May Become CESQGs e

Not

Applicable

Not

Applicable

Not

Applicable

Not

Applicable ($113) NotApplicable

Avoided State Waste Fees and Taxes Not

Applicable

Not

Applicable

Not

Applicable ($178) ($24) NotApplicable

Total Annual Costs (Savings) $366 $88 $39 ($30,020) ($4,112) ($170)

a Values in parentheses denote cost savings. Costs in the exhibit are rounded to the nearest whole number.

b In the exhibit, “-“ means that the cost element is not applicable to the type of facility. 

c

 Information on the derivation of the average per-facility costs (savings) is presented in Section 4.3.

d

 The above exhibit presents "overall" cost per facility for demonstrating compliance with final rule requirements. These estimates were obtained by dividing the total 

costs for all facilities subject to inspection by the number of facilities in states that will adopt the final rule.

e

 The above exhibit presents "overall" cost per facility for avoided RCRA information collection requirements for SQGs that may become CESQGs. This estimate was 

obtained by dividing total costs for all SQGs that may become CESQGs by the number of SQGs in states that will adopt the final rule.
46

Exhibit 4-4 presents the same information for all affected facilities. Note that per-facility costs 

and savings vary depending on the frequency with which the activity is conducted, the type of 

wipe used in conjunction with the hazardous solvent (i.e., reusable wipe vs. disposable wipe), 

and the type of facility generating the solvent-contaminated wipe (i.e., LQG vs. SQG).

To estimate costs and savings for all affected facilities (e.g., the information presented in 

Exhibit 4-4), the average per-facility costs in Exhibit 4-3 are multiplied by the applicable number 

of affected facilities. For one-time costs, affected facilities include generators and handlers of 

solvent-contaminated wipes in all states (see Sections 2.2.1 and 2.3 of this document). For 

annual costs and savings, affected facilities include generators and handlers of solventcontaminated wipes in states that will adopt the final rule (see Section 3.2 of this document).
47

Exhibit 4-4

Total Costs and Savings of the Final Rule for All Affected Facilities, 2011 Dollars a, b

Cost Elements

Reusable Wipes Disposable Wipes

LQGs SQGs Handling

Facilities LQGs SQGs HandlingFacilities

One-Time Costs

Familiarization 

with the

Final Rule

Reading the Final Rule $20,412 $1,062,634 $4,612 $1,772 $92,402 $47,884 

Annual Costs

Familiarization 

with the

Final Rule

Becoming Familiar with the Final Rule 

Requirements and Implementation 

Procedures/Practices

$45,815 $2,390,897 $10,376 $4,097 $207,905 $107,739 

Containers

for SolventContaminated 

Wipes

Purchase of Closed Containers $10,730 $286,290 Not

Applicable $888 $18,120 NotApplicable

Purchase of Labels $60,091 $1,603,226 Not

Applicable $4,975 $101,469 NotApplicable

Affixing Labels to Containers $25,172 $671,582 Not

Applicable $2,084 $42,505 NotApplicable

Management of 

"Free Liquids"

Removing "Free Liquids"

from Containers

Not

Applicable

Not

Applicable

Not

Applicable $4,288 $96,307 NotApplicable

Management of "Free Liquids" 

Removed from Containers

Not

Applicable

Not

Applicable

Not

Applicable ($2,663) ($123,717) NotApplicable

Off-Site 

Management

of SolventContaminated 

Wipes

Avoided Hazardous Waste

Manifest Costs

Not

Applicable

Not

Applicable

Not

Applicable ($21,175) ($413,729) ($582,877)

Avoided Disposal Costs Not

Applicable

Not

Applicable

Not

Applicable ($1,051,011) ($21,434,208) NotApplicable

Information 

Collection 

Requirements

Recordkeeping Requirements

under the Final Rule $3,307 $517,756 NotApplicable $296 $45,023 NotApplicable

Demonstrating Compliance with

Final Rule Requirements $16 $315 NotApplicable

Not

Applicable

Not 

Applicable

Not

Applicable

Avoided RCRA Information Collection 

Requirement Costs for SQGs

that May Become CESQGs

Not

Applicable

Not

Applicable

Not

Applicable

Not

Applicable ($611,481) NotApplicable

Avoided State Waste Fees and Taxes Not

Applicable

Not

Applicable

Not

Applicable ($6,297) ($128,427) NotApplicable

Total Annual Costs (Savings) $145,131 $5,470,066 $10,376 ($1,064,518) ($22,200,232) ($475,138)

a Values in parentheses denote cost savings.

b In the exhibit, “-“ means that the cost element is not applicable to the type of facility. 
48

4.3. Derivation of Cost and Savings Elements

This section describes the derivation of the estimated per-facility costs (savings) for each of the 

cost elements that contribute to the total costs and savings.55 

In estimating the costs and savings, the analysis uses three hourly compensation rates that

include salary,

56 fringe benefits (e.g., paid leave and health benefits)57, and other overhead 

(e.g., payroll costs)58:

• An hourly compensation rate of $51.35 (2011 dollars) is used to estimate the costs 

associated with: (1) reading the final rule and (2) becoming familiar with the final rule 

requirements and implementation procedures/practices. This hourly rate is based on the 

average of the hourly compensation rates for the technical, managerial, and legal labor 

categories.59

• An hourly compensation rate of $17.49 (2011 dollars) is used to estimate the costs 

associated with: (1) affixing labels to containers and (2) removing “free liquids” from 

containers. This hourly rate is based on the hourly compensation rate for janitorial and 

cleaning staff.60 

 

 55 As noted throughout this section, in estimating the per-facility costs (savings), the analysis relies on 

assumptions used in the economic background document originally developed for the proposed rule. (U.S. 

Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact for 

Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003.) The 

analysis also addresses, as appropriate, public comments received on the economic background document for the 

proposed rule. 

56 The wage rates used in the derivation of the hourly compensation rates were obtained from the following 

data source: Bureau of Labor Statistics. "May 2010 National Occupational Employment and Wage Estimates, United 

States." Available at: http://www.bls.gov/oes/current/oes_nat.htm, last accessed on October 26, 2011. These 2010 

wage rates were updated to 2011 dollars based on the following data source: Bureau of Labor Statistics. 

Employment Cost Index - Historical Listing, June 2011; "Table 5. Employment Cost Index for total compensation, for 

private industry workers, by occupation and industry; Continuous occupational and industry series (not seasonally 

adjusted)." Available online at: http://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 26, 2011. Private 

Industry Workers, All Workers, June 2010=111.7 and June 2011=114.3.

57 The benefits multiplier used in the derivation of the hourly compensation rates was obtained from the 

following data source: Bureau of Labor Statistics. News Release, Employer Costs for Employee Compensation -

June 2010; “Table 5. Employer costs per hour worked for employee compensation and costs as a percent of total 

compensation: Private industry workers, by major occupational group and bargaining unit status, June 2010.” 

Available at: http://www.bls.gov/news.release/archives/ecec_09082010.pdf, last accessed on October 26, 2011. For 

all occupational categories, except “janitors and cleaners,” used data for the “Management, professional, and related” 

occupational group. For “janitors and cleaners,” used data for the “Natural resources, construction, and 

maintenance” occupational group.

58 The overhead multiplier used in the derivation of the hourly compensation rates was obtained from the 

economic background document originally developed for the proposed rule, and is based on the average of three 

case studies included in two EPA full accounting reports for solid/hazardous waste management. U.S. Environmental 

Protection Agency. Economics Background Document - Estimate of National Economic Impact for Conditional 

Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 138.

59 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. p. 138.

60 Ibid.
49

• An hourly compensation rate of $33.36 (2011 dollars) is used to estimate the costs 

associated with: (1) complying with the recordkeeping requirements of the final rule and 

(2) demonstrating compliance with the final rule requirements. This hourly rate is based 

on the average of the hourly compensation rates for technical and managerial staff. 

Exhibit 4-5 presents the hourly compensation rates for each of the labor categories mentioned 

above (e.g., technical, managerial, legal).

Exhibit 4-5

Hourly Compensation Rates, 2011 Dollars

Labor Categories Bureau of Labor Statistics 

Standard Occupational Codes a

Hourly

Compensation Rates

($/hour) e

Technical 51-9061 $25.59 

Managerial 51-1011 $41.13 

Legal 23-1011 $87.34 

Janitors and cleaners 37-2011 $17.59 

a

 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact for 

Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 138.

b

 2011 Hourly Compensation Rate = [2010 Median Wage Rate ($/hour)] x [Benefits Multiplier] x [Overhead Multiplier] x 

[Employment Cost Index Adjustment Factor]. The “2010 median wage rate” is $15.88 for technical staff, $25.53 for 

managerial staff, $54.21 for legal staff, and $10.68 for janitors and cleaners. The “benefits multiplier” is 1.292 for 

technical, managerial, and legal staff; and 1.321 for janitors and cleaners. The “overhead multiplier” is 1.219 for all labor 

categories. The “employment cost index adjustment factor” is 1.023 for all labor categories.

The remainder of this section describes the data and the assumptions used in the derivation of 

each of the per-facility costs (savings).

4.3.1. Reading the Final Rule

EPA anticipates that all generators and handlers of solvent-contaminated wipes61

(i.e., generators and handlers located in states that are expected to adopt the final rule and 

those that are not expected to adopt the final rule) will read the final rule, or a summary of the 

rule (e.g., trade journal newsletter article). By reading the regulations, these facilities will 

identify the final rule requirements applicable to them and/or be up-to-date in regards to the 

regulations applicable to the hazardous wastes they generate or manage. To estimate the 

costs associated with this activity, the analysis employs the following assumptions:

• On average, three people at a LQG facility, one person at an SQG facility, and one 

person at a handling facility will need to read the final rule.62

 61 Handlers of solvent-contaminated disposable wipes include hazardous waste management facilities, 

municipal solid waste landfill facilities, and solid waste combustion facilities. Handlers of solvent-contaminated 

reusable wipes include industrial laundries and dry cleaners.

62 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. pp. 139-140.
50

• Each designated person (i.e., a supervisory- level employee) needs about 15 minutes 

(or 0.25 hours) to read the final rule. This takes place only in the first year after the 

promulgation of the final rule.63

• The hourly compensation rate for the designated person is estimated to be $51.35 (2011 

dollars). 

Exhibit 4-6 shows the one-time cost per facility for reading the final rule, by type of facilities and 

type of solvent-contaminated wipes. 

Exhibit 4-6

One-Time Cost per Facility for Reading the Final Rule, 2011 Dollars

Type of

Facilities

Reusable

Wipes b, c

Disposable

Wipes b, c

LQGs $39 $39

SQGs $13 $13

Handling Facilities a $13 $13

a

 For solvent-contaminated disposable wipes, handling facilities include hazardous waste management 

facilities, municipal solid waste landfill facilities, and solid waste combustion facilities. For solventcontaminated reusable wipes, handling facilities include industrial laundries and dry cleaners.

b

 Cost per Facility = [Number of Designated Persons per Facility] x [0.25 hours/person] x [$51.35/hour]. 

The “number of designated persons per facility” is 3 for LQGs, 1 for SQGs, and 1 for handling facilities.

c

 Costs in the exhibit are rounded to the nearest whole number.

4.3.2. Familiarizing Employees with the Final Rule Requirements and 

Implementation Procedures/Practices

Generators and handlers of solvent-contaminated wipes64 will need to familiarize employees 

with the final rule requirements and implementation procedures/practices in order to meet the 

conditions of the exclusions. To estimate the costs associated with this activity, the analysis 

employs the following assumptions:

• On average, three people at a LQG facility, one person at an SQG facility, and one 

person at a handling facility will need to become familiar with the final rule requirements 

and implementation procedures/practices.65

• In states that wish to adopt the final rule, each designated person (i.e., a supervisorylevel employee) needs about 45 minutes (or 0.75 hours) to become familiar with the final 

rule requirements and implementation procedures/practices on a yearly basis.

66, 67 

 63 Ibid.

64 Handlers of solvent-contaminated disposable wipes include hazardous waste management facilities, 

municipal solid waste landfill facilities, and solid waste combustion facilities. Handlers of solvent-contaminated 

reusable wipes include industrial laundries and dry cleaners.

65 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. pp. 139-140.
51

• This activity will be conducted by a supervisory-level employee, making $51.35 per hour

(2011 dollars). 

Exhibit 4-7 shows the annual cost per facility for becoming familiar with the final rule 

requirements and implementation procedures/practices, by type of facilities and type of wipes. 

Exhibit 4-7

Annual Cost per Facility for Becoming Familiar with the Final Rule

Requirements and Implementation Procedures/Practices, 2011 Dollars

Type of

Facilities

Reusable

Wipes b, c

Disposable

Wipes b, c

LQGs $116 $116

SQGs $39 $39

Handling Facilities a $39 $39

a

 For solvent-contaminated disposable wipes, handling facilities include hazardous waste management 

facilities, municipal solid waste landfill facilities, and solid waste combustion facilities. For solventcontaminated reusable wipes, handling facilities include industrial laundries and dry cleaners.

b

 Cost per Facility = [Number of Designated Persons per Facility] x [0.75 hours/person] x [$51.35/hour]. The 

“number of designated persons per facility” is 3 for LQGs, 1 for SQGs, and 1 for handling facilities.

c

 Costs in the exhibit are rounded to the nearest whole number.

4.3.3. Purchase of Containers

To be eligible for the conditional exclusions, solvent-contaminated wipes must be accumulated, 

stored, and transported in non-leaking, closed containers.68 The containers must be able to 

contain liquids, should liquids occur. In order to satisfy this condition, facilities may need to 

purchase closed containers for solvent-contaminated wipes.

To estimate the costs associated with the purchase of closed containers for solventcontaminated wipes, the analysis employs the following assumptions:

• When considering the type of container to be used for accumulating, storing, and/or 

transporting solvent-contaminated wipes, facilities will opt for the least costly behavior, 

 66 Ibid.

67 The economic background document originally developed for the proposed rule assumes that each 

designated person will need 30 minutes (or 0.50 hours) to become familiar with the rule requirements. This analysis 

assumes that an additional 15 minutes (or 0.25 hours) per person will be required to become familiar with 

implementation procedures/practices needed to meet the conditions of the exclusions. 

68 The containers must be able to contain free liquids, should free liquids occur. During accumulation, a 

container is considered closed when there is complete contact between the fitted lid and the rim, except when it is 

necessary to add or remove solvent-contaminated wipes. When the container is full, or when the solventcontaminated wipes are no longer being accumulated, or when the container is being transported, the container must 

be sealed with all lids properly and securely affixed to the container and all openings tightly bound or closed 

sufficiently to prevent leaks and emissions.
52

which is the use of plastic bags.69 Currently, bags are used by facilities to accumulate, 

store, and transport hazardous waste.

70, 71

• On average, each LQG facility generates about 136,384 solvent-contaminated reusable 

wipes per year; each SQG facility generates about 23,242 solvent-contaminated 

reusable wipes per year.72 EPA estimates that, on average, each 34-gallon plastic bag 

has a loading capacity of 756 solvent-contaminated reusable wipes. 73, 74 To estimate 

the total annual number of containers needed at each facility, the analysis takes the 

average annual number of solvent-contaminated reusable wipes generated per facility 

and divided it by the loading capacity of a 34-gallon plastic bag. Based on this 

calculation, EPA estimates that each LQG facility will need a total of 180 containers per 

year (i.e., 136,384 wipes per year / 756 wipes per plastic bag); each SQG facility will 

need a total of 31 containers per year (i.e., 23,242 wipes per year / 756 wipes per plastic 

bag).

• On average, each LQG facility generates about 191,008 solvent-contaminated 

disposable wipes per year; each SQG facility generates about 25,587 solventcontaminated disposable wipes per year.75 EPA estimates that, on average, each 34-

gallon plastic bag has a loading capacity of 1,144 solvent-contaminated disposable 

wipes.76 To estimate the total annual number of containers needed at each facility, the 

 69 Per EPA guidance, a plastic bag is considered a “closed” container when it is “sealed to the extent 

necessary to keep the hazardous waste and associated air emissions inside the container” (e.g., the neck of the bag 

is tightly bound). U.S. Environmental Protection Agency. Memorandum from Robert Dellinger, Director of Materials 

Recovery and Waste Management Division, to RCRA Division Directors of Regions 1-10 on “Guidance on 40 CFR 

264.173(a) and 265.173(a): Closed Containers.” December 3, 2009. Available at: 

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/DC2AFFCA7960F08A8525795F00610E

E7/$file/14826.pdf, last accessed on December 15, 2011. 

70 U.S. Environmental Protection Agency. Memorandum from Robert Dellinger, Director of Materials 

Recovery and Waste Management Division, to RCRA Division Directors of Regions 1-10 on “Guidance on 40 CFR 

264.173(a) and 265.173(a): Closed Containers.” December 3, 2009. Available at: 

http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/DC2AFFCA7960F08A8525795F00610E

E7/$file/14826.pdf, last accessed on December 15, 2011

71 U.S. Government Printing Office. Federal Register. “Hazardous Waste Management System: 

Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for 

Solvent- Contaminated Industrial Wipes.” 68 FR 65586. November 20, 2003. p. 65596.

72 These estimates are based on the annual number of solvent-contaminated reusable wipes in Exhibit 3-2 

and the number of generators of solvent-contaminated reusable wipes in Exhibit 3-1 of this document. Note that, due 

to rounding error, the reader may not obtain the same estimates provided in this bullet.

73 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 145.

74 Based on data submitted to EPA in response to the October 27, 2009 Notice of Data Availability (NODA), 

the weight of a solvent-contaminated reusable wipe is estimated to be 0.0917 pounds. As a result of this revision, the 

loading capacity in the economic background document originally developed for the proposed rule has been revised 

from 554 wipes per container to 756 wipes per container.

75 These estimates are based on the annual number of solvent-contaminated disposable wipes in 

Exhibit 3-2 and the number of generators of solvent-contaminated disposable wipes in Exhibit 3-1 of this document. 

Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

76 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 
53

analysis takes the average annual number of solvent-contaminated disposable wipes 

generated per facility and divided it by the loading capacity of a 34-gallon plastic bag. 

Based on this calculation, EPA estimates that each LQG facility will need a total of 167 

containers per year (i.e., 191,008 wipes per year / 1,144 wipes per plastic bag); each 

SQG facility will need a total of 22 containers per year (i.e., 25,587 wipes per year / 

1,144 wipes per container).

• Currently, EPA estimates that 50 percent of solvent-contaminated reusable and 

disposable wipes are not accumulated, stored, and/or transported in closed containers.77 

Therefore, facilities will need to purchase 50 percent of the total number of closed 

containers needed for solvent-contaminated reusable and disposable wipes.

• Plastic bags are purchased and used once by generators to accumulate, store, and 

transport solvent-contaminated wipes.78 The same plastic bags are then used to 

manage the solvent-contaminated wipes at the handling facilities.

• The cost of a 34-gallon plastic bag is $0.30 (2011 dollars). This cost is based on the 

current market price for heavy duty clear trash bags (i.e., high resistant to punctures and 

tears; handles dry and wet loads up to 75 pounds), including shipping and handling, and 

sales tax.79, 80

Exhibit 4-8 shows the annual cost, per facility, to purchase containers, by type of facilities and 

type of wipes. 

 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 145.

77 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. pp. 144-148.

78 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. pp. 145-146.

79 Current market price for heavy duty clear trash bags (i.e., box of 125 bags at $32.95) was obtained at: 

http://www.2kstore.com/gragr/jwod/nsn2.htm, last accessed on October 26, 2011.

80 Container costs were estimated using the following equation: [Retail price] + [8% shipping and handling 

cost] + [6% sales tax] = [Retail price] x 1.14. This equation was obtained from the economic background document 

originally developed for the proposed rule.
54

 

Exhibit 4-8

Annual Cost, per Facility, to Purchase Containers, 2011 Dollars

Type of

Facilities

Reusable

Wipes a, b

Disposable

Wipes a, b

LQGs $27 $25

SQGs $5 $3

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [50% of the Total Annual Number of Containers per Facility (containers/facility)] x 

[$0.30/container]. The “total annual number of containers per facility” is 167 for LQGs-disposable wipes, 22 for 

SQGs-disposable wipes, 180 for LQGs-reusable wipes, and 31 for SQGs-reusable wipes. 

b

 Costs in the exhibit are rounded to the nearest whole number.

4.3.4. Purchase of Labels

To be eligible for the conditional exclusions, solvent-contaminated wipes must be accumulated, 

stored, and transported in non-leaking, closed containers that are labeled “Excluded SolventContaminated Wipes.” Therefore, under the final rule, generators will need to purchase labels 

for the closed containers.

To estimate the costs associated with the purchase of labels, the analysis employs the following 

assumptions:

• For solvent-contaminated reusable wipes, each LQG facility will need a total of 180 

containers per year; each SQG facility will need a total of 31 containers per year. 81

• For solvent-contaminated disposable wipes, each LQG facility will need a total of 167 

containers per year; each SQG facility will need a total of 22 containers per year.82

• Generators will affix one label to each container (i.e., plastic bag).83

• The cost of one pre-printed vinyl adhesive label is $0.84 (2011 dollars). This cost is 

based on the current market price of pre-printed vinyl adhesive labels, including shipping

and handling, and sales tax.84, 85

 81 Refer to Section 4.3.3 of this document for information on the derivation of the total annual number of 

containers needed for solvent-contaminated reusable wipes.

82 Refer to Section 4.3.3 of this document for information on the derivation of the total annual number of 

containers needed for solvent-contaminated disposable wipes.

83 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 149.

84 Current market price for one pre-printed 6 x 6 vinyl adhesive label (i.e., package of 25 labels at $18.50)

was obtained at: http://www.labsafety.com/lab-safety-supply-nonhazardous-waste-labels-vinyl-6h-x-6w-pkg-of25_s_131535V/#mainProductBottom, last accessed on October 16, 2011.

85 Label costs were estimated using the following equation: [Retail price] + [8% shipping and handling cost] 

+ [6% sales tax]. This equation was obtained from the economic background document originally developed for the 

proposed rule. U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 
55

Exhibit 4-9 shows the annual cost, per facility, to purchase labels, by type of facilities and type 

of wipes. 

 

Exhibit 4-9

Annual Cost, per Facility, to Purchase Labels, 2011 Dollars

Type of

Facilities

Reusable

Wipes a, b

Disposable

Wipes a, b

LQGs $152 $140

SQGs $26 $19

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = [Total Annual Number of Containers per Facility (containers/facility)] x [1 label/container] x 

[$0.84/label]. The “total annual number of containers per facility” is 167 for LQGs-disposable wipes, 22 for 

SQGs-disposable wipes, 180 for LQGs-reusable wipes, and 31 for SQGs-reusable wipes. 

b

 Costs in the exhibit are rounded to the nearest whole number.

4.3.5. Affixing Labels to Containers

To be eligible for the conditional exclusions, solvent-contaminated wipes must be accumulated, 

stored, and transported in non-leaking, closed containers that are labeled “Excluded SolventContaminated Wipes.” Therefore, under the final rule, generators will need to affix labels to 

closed containers.

To estimate the costs associated with affixing labels to containers, the analysis employs the 

following assumptions:

• For solvent-contaminated reusable wipes, each LQG facility will need a total of 180 

containers per year; each SQG facility will need a total of 31 containers per year. 86

• For solvent-contaminated disposable wipes, each LQG facility will need a total of 167 

containers per year; each SQG facility will need a total of 22 containers per year.87

• Generators will affix one label to each container (i.e., plastic bag).88

• Each designated person (i.e., janitorial or cleaning level employee) takes an estimated

one minute (or 0.02 hours) to affix a label to a closed container.89

 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. p. 142.

86 Refer to Section 4.3.3 of this document for information on the derivation of the total annual number of 

containers needed for solvent-contaminated reusable wipes.

87 Refer to Section 4.3.3 of this document for information on the derivation of the total annual number of 

containers needed for solvent-contaminated disposable wipes.

88 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 149.

89 Ibid.
56

• This activity is expected to be conducted by a janitorial/cleaning-level employee, making 

$17.59 per hour (2011 dollars). 

Exhibit 4-10 shows the annual cost, per facility, to affix labels to containers, by type of facilities 

and type of wipes. 

 

Exhibit 4-10

Annual Cost, per Facility, to Affix Labels to Containers, 2011 Dollars

Type of

Facilities

Reusable

Wipes a, b

Disposable

Wipes a, b

LQGs $63 $59

SQGs $11 $8

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = [Total Annual Number of Containers per Facility (containers/facility)] x [1 label/container] x 

[0.02 hours/container] x [$17.59/hour]. The “total annual number of containers per facility” is 167 for LQGsdisposable wipes, 22 for SQGs-disposable wipes, 180 for LQGs-reusable wipes, and 31 for SQGs-reusable wipes. 

b

 Costs in the exhibit are rounded to the nearest whole number.

4.3.6. Removing “Free Liquids” from Containers

Under the final rule, solvent-contaminated reusable wipes must contain “no free liquids” at the 

point of being sent for cleaning on-site or at the point of being transported off-site for cleaning. 

Similarly, solvent-contaminated disposable wipes must contain “no free liquids” at the point of 

being transported for disposal. Therefore, generators of solvent-contaminated reusable and 

disposable wipes must remove (i.e., decant) “free liquids” from containers in order for their 

wipes to be eligible for the conditional exclusions under the final rule.90, 91

This analysis assumes that generators and handlers in states that have exclusions for solventcontaminated reusable wipes are already in compliance with the “no free liquids” standard. 

Therefore, there are no incremental costs associated with the removal of “free liquids” from 

containers under the final rule for solvent-contaminated reusable wipes. In contrast, there are 

costs associated with the removal of “free liquids” from containers with solvent-contaminated 

disposable wipes.

 90 This analysis assumes that facilities will decant containers with solvent-contaminated wipes in order to 

capture excess solvents. The analysis also assumes that facilities that use solvent extraction technologies 

(e.g., centrifugation) may reuse the captured solvent, thereby realizing cost savings from avoided solvent extraction 

costs and avoided purchase of virgin solvent. Note, however, that facilities are assumed to use costlier solvent 

extraction technologies only to the extent that doing so is economically beneficial (and, therefore, that the costs of 

such technologies will be offset by associated savings).

91 Solvent-contaminated wipes can compress in transit and solvent can percolate through the wipes and 

collect at the bottom of the container. This means that, while there may not have been “free liquids” in the container 

at the generator site, some may be generated during transportation. However, if generators comply with the final rule 

as written, no “free liquids” would be received at the handling facilities. Therefore, the analysis does not estimate 

incremental costs to handling facilities for removal and management of “free liquids.”
57

To estimate costs associated with the removal of “free liquids” from containers, the analysis 

employs the following assumptions:

• On average, each LQG facility generates about 98,256 solvent-contaminated disposable 

wipes with “free liquids” per year; each SQG facility generates about 14,475 solventcontaminated disposable wipes with “free liquids” per year.92 EPA estimates that, on 

average, each 34-gallon plastic bag has a loading capacity of 1,144 solventcontaminated disposable wipes.93 To estimate the number of containers needed to 

comply with this requirement, the analysis takes the annual number of solventcontaminated disposable wipes with “free liquids” per facility and divided it by the loading 

capacity of a 34-gallon plastic bag. Based on this calculation, EPA estimates that each 

LQG facility will need 86 containers with “free liquids” per year (i.e., 98,256 wipes with 

“free liquids” per year / 1,144 wipes per container); each SQG facility will have 13 

containers with “free liquids” per year (i.e., 14,475 wipes with “free liquids” per year / 

1,144 wipes per container).

• Each designated person (i.e., janitorial or cleaning-level employee) is estimated to take 

about five minutes (or 0.08 hours) to remove “free liquids” from a container.

94

• This activity is expected to be conducted by a janitorial/cleaning-level employee, making 

$17.59 per hour (2011 dollars). 

Exhibit 4-11 shows the annual cost, per facility, to remove “free liquids” from containers, by type 

of facilities and type of wipes. 

 

 92 These estimates are based on the annual number of solvent-contaminated disposable wipes in 

Exhibit 3-2 and the number of generators of solvent-contaminated disposable wipes in Exhibit 3-1 of this document. 

The analysis assumes that 100 percent of solvent-contaminated wipes generated by printer facilities will have “free 

liquids” and that 50 percent of solvent-contaminated wipes generated by non-printer facilities will have “free liquids.” 

Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

93 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 145.

94 This assumption was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 152.
58

Exhibit 4-11

Annual Cost, per Facility, to Remove “Free Liquids” from Containers, 2011 Dollars

Type of

Facilities

Reusable

Wipes

Disposable

Wipes a, b

LQGs Not Applicable $121

SQGs Not Applicable $18

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = [Annual Number of Containers with “Free Liquids” per Facility (containers/facility)] x [0.08 

hours/container] x [$17.59/hour]. The “annual number of containers with ‘free liquids’ per facility” is 86 for LQGs 

and 13 for SQGs. 

b

 Costs in the exhibit are rounded to the nearest whole number.

4.3.7. Management of “Free Liquids” Removed From Containers

Under the final rule, any liquids removed from solvent-contaminated wipes must be managed 

according to the applicable hazardous waste regulations. This translates to cost savings from 

avoiding future purchases of virgin solvents if captured spent solvent “free liquids” are recycled.

The analysis assumes that generators and handlers in states that have exclusions for solventcontaminated reusable wipes are already in compliance with the “no free liquids” standard. 

Therefore, there are no cost savings associated with the management of “free liquids” removed 

from containers under the final rule for solvent-contaminated reusable wipes. In contrast, there 

are cost savings associated with the management of “free liquids” from containers with solventcontaminated disposable wipes.

To estimate the cost savings to manage “free liquids” removed from containers, the analysis 

employs the following assumptions:

• On average, each LQG facility will use about 86 containers of solvent-contaminated 

disposable wipes with “free liquids” per year; each SQG facility will use about 13 

containers of solvent-contaminated disposable wipes with “free liquids” per year.95

• On average, a LQG facility removes approximately 0.46 gallons of “free liquids” from 

each 34-gallon container of solvent-contaminated wipes; a SQG facility removes

approximately 0.96 gallons of “free liquids” from each 34-gallon container of solventcontaminated wipes.96

• When considering the method to be used for managing “free liquids” removed from 

containers, generators are expected to opt for the least costly behavior, which is the use 

of solvent recovery. 

 95 Refer to Section 4.3.6 of this document for information on the derivation of the total annual number of 

containers of solvent-contaminated disposable wipes with “free liquids.”

96 These estimates are based on the annual number of containers of solvent-contaminated disposable 

wipes with “free liquids.” The analysis assumes that, on average, printer facilities remove 3.09 gallons of “free 

liquids” from a 34-gallon container of solvent-contaminated wipes; non-printer facilities remove 0.31 gallons of “free 

liquids” from a 34-gallon container of solvent-contaminated wipes. Note that, due to rounding error, the reader may 

not obtain the same estimates provided in this bullet.
59

• The net cost to manage “free liquids” as hazardous waste through solvent recovery is 

estimated to be ($1.88) per gallon (2011 dollars). The economic background document 

derived this estimate by subtracting the unit price for solvent recovery from the unit price 

for virgin solvent in order to reflect the resale (reuse) net value of recycled solvent. The 

per-gallon cost estimate in the economic background document for the proposed rule97

has been updated to 2011 dollars using GDP deflators developed by the U.S. 

Department of Commerce. 98 

Exhibit 4-12 shows the annual cost, per facility, to manage “free liquids” from containers, by type 

of facilities and type of wipes. 

 

Exhibit 4-12

Annual Cost, per Facility, to Manage “Free Liquids” 

Removed from Containers, 2011 Dollars

Type of

Facilities

Reusable

Wipes

Disposable

Wipes a, b, c

LQGs Not Applicable ($75)

SQGs Not Applicable ($23)

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = [Annual Number of Containers with “Free Liquids” per Facility (containers/facility)] x 

[Gallons of “Free Liquids” Removed from a 34-Gallon Container (gallons/container)] x [($1.88)/gallon]. The 

“annual number of containers with ‘free liquids’ per facility” is 87 for LQGs and 13 for SQGs. The “gallons of 

‘free liquids’ removed from a 34-gallon container” is 0.46 for LQGs and 0.96 for SQGs.

b

 Costs in the exhibit are rounded to the nearest whole number.

c Values in parentheses denote cost savings.

4.3.8. Avoided Hazardous Waste Manifest Costs

Under the final rule, solvent-contaminated reusable and disposable wipes that meet the 

specified conditions will enter the non-hazardous waste stream and thus, will not be subject to 

the hazardous waste manifest requirements. These avoided costs (i.e., cost savings) will 

benefit all parties involved in the hazardous waste manifest process, including generators and 

handlers of solvent-contaminated wipes.

This analysis assumes that generators and handlers in states that currently have exclusions for 

solvent-contaminated reusable wipes are not subject to the hazardous waste manifest 

requirements. Therefore, there are no cost savings associated with hazardous waste manifest 

requirements for solvent-contaminated reusable wipes. In contrast, there are cost savings 

associated with hazardous waste manifest requirements for solvent-contaminated disposable 

wipes.

 97 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. p. 153.

98 U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for 

Gross Domestic Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 6, 2011. Year 2003, Quarter II = 93.815 and Year 2011, Quarter III = 113.823. 
60

To estimate the avoided hazardous waste manifest costs, the analysis employs the following 

assumptions:

• On average, each LQG facility will fill about 167 containers with solvent-contaminated 

disposable wipes each year; each SQG facility will fill about 22 containers with solventcontaminated disposable wipes each year.99

• The on-site RCRA accumulation time period for containers is 90 days (i.e., three 

months) for a LQG facility and 180 days (i.e., six months) for a SQG facility. 100

• The average number of containers that can be transported on a truck is 40.101

• EPA estimates that there will be about 998 hazardous waste management facilities that 

manage solvent-contaminated disposable wipes in states that are expected to adopt the 

final rule.

• The cost associated with a hazardous waste manifest is $143 for a LQG facility, $137 for 

a SQG facility, and $44 for a handing facility (2011 dollars).

102 These costs are based 

on total unit costs for the manifest process that EPA applied in a proposed rulemaking 

for the RCRA hazardous waste manifest system in 2001.

103, 104 The unit labor costs 

have been updated to 2011 dollars using employment cost data developed by the 

Bureau of Labor Statistics.105

Exhibit 4-13 shows the annual avoided hazardous waste manifest cost, per facility, by type of

facilities and type of wipes. 

 

 99 Refer to Section 4.3.3 of this document for information on the derivation of the total annual number of 

containers for solvent-contaminated disposable wipes.

100 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on the accumulation time limits at 40 CFR 262.34. U.S. Environmental Protection Agency. 

Economics Background Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent 

Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 150.

101 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 150.

102 These costs include the following components: (1) preparing the manifest; (2) transmitting the manifest 

between generator, transporter, and management facility; (3) manifest recordkeeping; (4) obtaining manifest forms; 

(5) submitting copies of final signed manifests to state agencies; and (6) employee training.

103 U.S. Environmental Protection Agency. Hazardous Waste Manifest Cost Benefit Analysis. October 

2000. Available at: http://www.epa.gov/osw/hazard/transportation/manifest/pdf/cba-rprt.pdf, last accessed on 

November 11, 2011. 

104 This data source also was used in the development of the economic background document originally 

developed for the proposed rule.

105 Bureau of Labor Statistics. Employment Cost Index - Historical Listing, June 2011; "Table 5. 

Employment Cost Index for total compensation, for private industry workers, by occupation and industry; Continuous 

occupational and industry series (not seasonally adjusted)." Available online at: 

http://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 26, 2011. Private Industry Workers, All Workers, 

September 2010=112.2 and June 2011=114.3.
61

Exhibit 4-13

Annual Avoided Hazardous Waste Manifest Cost per Facility, 2011 Dollars

Type of

Facilities

Reusable

Wipes

Disposable

Wipes b, c, d, e

LQGs Not Applicable ($597)

SQGs Not Applicable ($77)

Handling Facility a Not Applicable ($208)

a For solvent-contaminated disposable wipes, handling facilities include hazardous waste management 

facilities.

b

 Cost per LQG or SQG Facility = [Total Annual Number of Containers per Facility (containers/facility)] / [12 

months/year] x [On-Site RCRA Accumulation Time Period (months)] / [40 containers/truckload] x [Annual 

Conversion Factor] x [Manifest Cost]. The “total annual number of containers per facility” is 167 for LQGs and 

22 for SQGs-disposable wipes. The “on-site RCRA accumulation time period” is 3 months for LQGs and 6 

months for SQGs. The “annual conversion factor” is 4 for LQGs and 2 for SQGs. The “manifest cost” is $143 

for LQGs and $137 for SQGs.

c

 Cost per Handling Facility = ([Number of LQG Manifests] + [Number of SQG Manifests]) * [$44/manifest] / 

[998 Handling Facilities]

where:

[Number of LQG Manifests] = [167 containers/facility] / [12 months/year] x [3 months] / [40 

containers/truckload] x [4 months/year]. 

[Number of SQG Manifests] = [22 containers/facility] / [12 months/year] x [6 months] / [40 

containers/truckload] x [2 months/year]. 

d

 Costs in the exhibit are rounded to the nearest whole number.

e Values in parentheses denote cost savings.

4.3.9. Avoided Disposal Costs

Under the final rule, solvent-contaminated disposable wipes that meet the specified conditions 

will enter the non-hazardous waste stream. As a result, generators will be able to send their 

solvent-contaminated disposable wipes to municipal solid waste landfills and solid waste 

combustors. Disposing of the solvent-contaminated wipes at non-hazardous waste 

management facilities, rather than hazardous waste management facilities, will result in cost 

savings to generators.

To estimate the avoided disposal costs, the analysis employs the following assumptions:

• On average, each LQG facility generates about 191,008 solvent-contaminated 

disposable wipes per year; each SQG facility generates about 25,587 solventcontaminated disposable wipes per year.106 

• On average, each LQG facility will fill about 167 containers with solvent-contaminated 

disposable wipes each year; each SQG facility will fill about 22 containers with solventcontaminated disposable wipes each year.107

 106 These estimates are based on the annual number of solvent-contaminated disposable wipes in 

Exhibit 3-2 and the number of generators of solvent-contaminated disposable wipes in Exhibit 3-1 of this document. 

Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

107 Refer to Section 4.3.3 of this document for information on the derivation of the total annual number of 

containers for solvent-contaminated disposable wipes.
62

• Pursuant to 40 CFR 264.314, the placement of hazardous waste containing “free liquids” 

(whether or not sorbents have been added) in any landfill is prohibited. Without the “no 

free liquids” requirement in effect nationwide, there is no "guarantee" that any single 

container of solvent-contaminated disposable wipes contains "no free liquids.” 

Therefore, under the regulatory baseline, solvent-contaminated disposable wipes are not 

accepted at hazardous waste landfills because of the risk that the container also may 

contain "free liquids" that have percolated out of the wipes during transport to the landfill. 

All generators of solvent-contaminated disposable wipes send their wipes to hazardous 

waste incineration facilities.108

• Under the final rule, 50 percent of solvent-contaminated disposable wipes will be sent to 

municipal solid waste landfills and the other 50 percent of solvent-contaminated 

disposable wipes will be sent to solid waste combustors.109

• On average, the weight of a solvent-contaminated disposable wipe is 0.054 pounds

(i.e., 33,333 wipes per ton).110

• On average, the residual of the incineration process (i.e., incineration ash) is 10 percent 

of the weight.111

• Disposal costs are estimated as follows:

Type of Disposals

Estimated Cost

(2011 Dollars)

Hazardous waste incineration a $181 per container

Incineration ash at a hazardous waste landfill a $485 per ton

Municipal solid waste landfill b $4 per container

Solid waste combustion b $6 per container

Incineration ash at a municipal solid waste landfill b $37 per ton

a

 Cost estimate was obtained from the economic background document originally developed for the proposed rule112 and 

updated to 2011 dollars using GDP deflators developed by the U.S. Department of Commerce. 113

b

 Cost estimate was derived using data in Waste Business Journal’s “Directory & Atlas of Non-Hazardous Waste Sites 

2007.” Detailed information on these costs is presented in Exhibit 4-14. 

 108 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. p. 156.

109 Based on professional judgment.

110 Ibid.

111 Ibid.

112 Ibid.

113 U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for 

Gross Domestic Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 6, 2011. Year 2003, Quarter II = 93.815 and Year 2011, Quarter III = 113.823. 
63

Disposal costs presented in the above exhibit for municipal solid waste landfills and solid waste 

combustors are based on tipping fees for solid waste managed in non-hazardous waste facilities 

in the U.S. Exhibit 4-14 shows state tipping fees, as well as the estimated disposal costs at the 

national level.
64

Exhibit 4-14

Tipping Fees for Solid Waste Managed in

Non-Hazardous Waste Facilities in the United States, 2011 Dollars a

States

Municipal Solid Waste Landfill b Solid Waste Combustion b

Number of

Facilities

Minimum

Cost

($/ton)

Maximum

Cost

($/ton)

Average

Cost

($/ton)

Number of

Facilities

Minimum

Cost

($/ton)

Maximum

Cost

($/ton)

Average

Cost

($/ton)

Alabama 33 $9.58 $47.88 $31.40 1 $42.45 $42.45 $42.45

Alaska 18 $15.00 $191.52 $54.83 3 $148.96 $152.48 $150.13

Arizona 42 $10.64 $69.43 $34.54

Arkansas 34 $1.44 $53.20 $28.76 1 $26.60 $26.60 $26.60

California 136 $4.26 $95.76 $42.45 6 $9.04 $77.10 $46.68

Colorado 53 $6.38 $95.76 $23.36 1 $26.60 $26.60 $26.60

Connecticut 13 $31.92 $170.24 $83.02 7 $27.66 $80.86 $64.14

Delaware 4 $65.44 $65.44 $65.44

Florida 55 $14.62 $90.44 $47.05 13 $29.79 $148.96 $70.55

Georgia 76 $7.98 $69.16 $34.52 1 $63.84 $63.84 $63.84

Hawaii 8 $37.24 $86.47 $54.96 1 $86.47 $86.47 $86.47

Idaho 19 $4.79 $65.33 $25.36

Illinois 48 $21.28 $82.99 $40.34

Indiana 37 $14.36 $53.20 $34.28 1 $28.73 $28.73 $28.73

Iowa 64 $10.37 $63.84 $36.18

Kansas 61 $4.26 $106.40 $30.55

Kentucky 29 $16.12 $50.58 $32.05

Louisiana 21 $15.96 $47.88 $28.00 1 $19.15 $19.15 $19.15

Maine 8 $50.54 $90.44 $76.81 4 $60.61 $106.40 $85.38

Maryland 22 $31.92 $85.12 $55.71 3 $44.69 $71.82 $54.44

Massachusetts 24 $0.53 $117.15 $72.22 7 $53.20 $96.82 $77.82

Michigan 51 $15.96 $77.67 $39.80 3 $55.86 $93.48 $69.26

Minnesota 42 $11.70 $95.76 $50.68 8 $42.29 $74.48 $60.18

Mississippi 26 $9.58 $44.75 $26.52

Missouri 25 $17.56 $59.58 $38.12

Montana 22 $12.24 $88.31 $38.23 1 $63.84 $63.84 $63.84

Nebraska 22 $12.77 $46.82 $32.35

Nevada 13 $10.96 $42.56 $20.22

New Hampshire 12 $2.13 $91.30 $57.89 3 $69.16 $92.57 $82.28

New Jersey 15 $46.14 $101.35 $75.22 5 $64.90 $92.45 $74.56

New Mexico 29 $3.19 $38.30 $20.80

New York 34 $25.54 $106.40 $62.64 10 $23.41 $106.40 $69.46

North Carolina 55 $24.47 $105.34 $40.25 1 $48.94 $48.94 $48.94

North Dakota 21 $9.58 $39.90 $27.94
Exhibit 4-14 (continued)

Tipping Fees for Solid Waste Managed in

Non-Hazardous Waste Facilities in the United States, 2011 Dollars a

65

States

Municipal Solid Waste Landfill b Solid Waste Combustion b

Number of

Facilities

Minimum

Cost

($/ton)

Maximum

Cost

($/ton)

Average

Cost

($/ton)

Number of

Facilities

Minimum

Cost

($/ton)

Maximum

Cost

($/ton)

Average

Cost

($/ton)

Ohio 43 $17.56 $63.84 $36.60 1 $25.54 $25.54 $25.54

Oklahoma 40 $14.36 $47.88 $23.90 1 $58.52 $58.52 $58.52

Oregon 37 $9.58 $106.40 $31.61 2 $46.82 $71.77 $59.29

Pennsylvania 47 $37.24 $110.66 $61.38 7 $21.28 $77.14 $54.42

Rhode Island 4 $28.73 $69.16 $56.39

South Carolina 30 $12.77 $53.20 $35.70 1 $63.31 $63.31 $63.31

South Dakota 14 $6.38 $47.88 $32.57

Tennessee 36 $19.58 $51.07 $34.26 2 $27.66 $48.94 $38.30

Texas 173 $4.72 $133.00 $27.71 2 $106.40 $212.80 $159.60

Utah 26 $2.66 $68.10 $24.06 1 $26.60 $26.60 $26.60

Vermont 11 $25.54 $212.80 $93.89 1 $45.57 $45.57 $45.57

Virginia 65 $15.96 $63.84 $43.37 6 $35.11 $58.52 $43.10

Washington 25 $13.57 $138.32 $56.49 4 $95.92 $127.68 $110.39

West Virginia 19 $29.85 $74.48 $45.63

Wisconsin 40 $10.64 $106.40 $41.48 2 $36.71 $58.52 $47.61

Wyoming 36 $6.38 $58.52 $29.22

Total 1,818 111

Median per ton $37.00 Median per ton $59.00

Median per container $4.00 Median per container $6.00

a

 Tipping fee data were obtained from the following data source: Waste Business Journal’s “Directory & Atlas of Non-Hazardous Waste Sites 2007.

b

 2007 cost updated to 2011 dollars using the following data source: U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators 

for Gross Domestic Product.” Available online at: http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 16, 2011. Year 2007, Quarter IV = 106.958 and Year 2011, Quarter III = 113.823.
66

Exhibit 4-15 shows the annual avoided disposal cost per facility, by type of facilities and type of 

wipes. 

 

Exhibit 4-15

Annual Avoided Disposal Cost per Facility, 2011 Dollars

Type of

Facilities

Reusable

Wipes

Disposable

Wipes a, b, c

LQGs Not Applicable ($29,639)

SQGs Not Applicable ($3,970)

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = ([Cost per Facility for Hazardous Waste Incineration] + [Cost per Facility for Disposal of Incineration 

Ash at a Hazardous Waste Landfill]) – ([Cost per Facility for Disposal at Municipal Solid Waste Landfill] + [Cost per 

Facility for Solid Waste Combustion] + [Cost per Facility for Disposal of Incineration Ash at a Municipal Solid Waste 

Landfill])

where:

Cost per Facility for Hazardous Waste Incineration = [Total Annual Number of Containers per Facility 

(containers/facility)] x [$181/container]. The “total annual number of containers per facility” is 167 for LQGs and 22

for SQGs-disposable wipes. 

Cost per Facility for Disposal of Incineration Ash at a Hazardous Waste Landfill = [Annual Number of Wipes per 

Facility] / [33,333 wipes/ton] x [10% Incineration Ash Residual] x [$485/ton]. The “annual number of wipes per facility 

is 191,008 for LQGs and 25,587 for SQGs. 

Cost per Facility for Disposal at Municipal Solid Waste Landfill = [50% of Total Annual Number of Containers per 

Facility (containers/facility)] x [$4/container]. The “total annual number of containers per facility” is 167 for LQGs and 

22 for SQGs-disposable wipes. 

Cost per Facility for Solid Waste Combustion = [50% of Total Annual Number of Containers per Facility 

(containers/facility)] x [$6/container]. The “total annual number of containers per facility” is 167 for LQGs and 22 for 

SQGs-disposable wipes. 

Cost per Facility for Disposal of Incineration Ash at a Municipal Solid Waste Landfill = [50% of Annual Number of 

Wipes per Facility] / [33,333 wipes/ton] x [10% Incineration Ash Residual] x [$37/ton]. The “annual number of wipes 

per facility” is 191,008 for LQGs and 25,587 for SQGs. 

b

 Costs in the exhibit are rounded to the nearest whole number.

c Values in parentheses denote cost savings.

4.3.10. Complying with Recordkeeping Requirements under the Final Rule

Under the final rule, generators of solvent-contaminated wipes must maintain at their site 

documentation to demonstrate that they are managing excluded solvent-contaminated wipes 

according to the final rule requirements. 

• For solvent-contaminated reusable wipes, documentation must include: (1) name and 

address of the laundry or dry cleaner that is receiving the solvent-contaminated wipes,

(2) documentation that the 180-day accumulation time limit in 40 CFR 261.4(a)(26)(ii) is 

being met, and (3) description of the process the generator is using to ensure the 

solvent-contaminated wipes contain “no free liquids” at the point of being laundered or 

dry-cleaned on-site or at the point of being transported off-site for laundering or drycleaning.

• For solvent-contaminated disposable wipes, documentation must include: (1) name and 

address of the landfill or combustor that is receiving the solvent-contaminated wipes, (2) 

documentation that the 180 day accumulation time limit in 40 CFR 261.4(b)(18)(ii) is 

being met, and (3) description of the process the generator is using to ensure solventcontaminated wipes contain “no free liquids” at the point of being transported for 

disposal.
67

To estimate the costs associated with the above recordkeeping requirements, the analysis 

employs the following assumptions:

• Each designated person (i.e., a supervisory-level employee) is estimated to take about

15 minutes (or 0.25 hours) per year to document that the facility is managing excluded 

solvent-contaminated wipes in accordance with the final rule.

• This activity is expected to be conducted by a supervisory-level employee, making 

$33.36 per hour (2011 dollars). 

Exhibit 4-16 shows the annual cost per facility for complying with the recordkeeping 

requirements under the final rule, by type of facilities and type of wipes. 

 

Exhibit 4-16

Annual Costs, per Facility, to Comply with

the Recordkeeping Requirements under the Final Rule, 2011 Dollars

Type of

Facilities

Reusable

Wipes a, b

Disposable

Wipes a, b

LQGs $8 $8

SQGs $8 $8

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = [0.25 hours/generator] x [$33.36/hour].

b

 Costs in the exhibit are rounded to the nearest whole number.

4.3.11. Demonstrating Compliance with Final Rule Conditions

Generators and handlers of solvent-contaminated wipes will need to demonstrate compliance 

with the final rule conditions to inspectors from regulating agencies (i.e., state inspectors, or 

EPA Regional inspectors):

• Generators of solvent-contaminated reusable wipes. The analysis assumes that

generators in states that have exclusions for solvent-contaminated reusable wipes are 

already in compliance with applicable requirements. The only additional cost associated 

with this section is to demonstrate compliance with the recordkeeping requirements of 

the final rule.

• Generators of solvent-contaminated disposable wipes. The analysis assumes that any 

costs to demonstrate compliance with the final rule conditions and recordkeeping 

requirements are offset by the savings in demonstrating compliance with applicable 

hazardous waste requirements.

• Handlers of solvent-contaminated wipes. Handling facilities are subject to inspections 

and evaluations under the majority of statutory and regulatory programs (e.g., RCRA 

Subtitle C and D, as applicable; Clean Air Act; Clean Water Act; OSHA; Toxic 

Substances Control Act (TSCA)). Given that these inspections and evaluations will 
68

continue to take place under the final rule, this analysis assumes that there are no 

additional costs to handling facilities under this section.

To estimate the costs to generators of solvent-contaminated reusable wipes for demonstrating 

compliance with the final rule conditions, the analysis employs the following assumptions:

• In states that are expected to adopt the final rule, there are approximately 397 LQGs and 

62,081 SQGs that use solvent-contaminated reusable wipes.

• On average, 6 LQGs and 118 SQGs will be inspected by a regulatory agency each 

year.114 

• Each designated person (i.e., a supervisory-level employee) is estimated to take about 5 

minutes (or 0.08 hours) to provide evidence that shows compliance with the 

recordkeeping requirements of the final rule.

• This activity is expected to be conducted by a supervisory-level employee, making 

$33.36 per hour (2011 dollars). 

Exhibit 4-17 shows the annual cost, per facility, to demonstrate compliance with the 

recordkeeping requirements, by type of facilities and type of wipes. 

 

Exhibit 4-17

Annual Costs, per Facility, to Demonstrate

Compliance with the Recordkeeping Requirements, 2011 Dollars

Type of

Facilities

Reusable

Wipes a, b

Disposable

Wipes

LQGs $3 Not Applicable

SQGs $3 Not Applicable

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = [0.08 hours/generator] x [$33.36/hour].

b

 Costs in the exhibit are rounded to the nearest whole number.

 114 The analysis assumes that 15 percent of generators in the “chemical and allied products” economic subsector and 0.06 percent of generators in all other economic sub-sectors are subject to inspections each year. U.S. 

Environmental Protection Agency. Economics Background Document - Estimate of National Economic Impact for 

Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 167.
69

4.3.12. Avoided RCRA Information Collection Requirement Costs for SQGs that 

May Become CESQGs

Under the final rule, solvent-contaminated reusable and disposable wipes that meet the 

specified conditions will enter the non-hazardous waste stream and thus, will not be counted 

towards generator status determination (e.g., LQG, SQG). As a result, some SQGs may 

experience a change in generator status and become CESQGs.115 They are exempt from the

full hazardous waste regulations that apply to LQGs and SQGs, including information collection 

requirements. The avoided RCRA information requirements will result in cost savings to the 

SQGs that become CESQGs.

This analysis assumes that in states that have exclusions for solvent-contaminated reusable 

wipes, these wipes have already entered into the non-hazardous waste stream. As a result, 

SQGs that become CESQGs are not subject to the full hazardous waste regulations. Therefore, 

for solvent-contaminated reusable wipes, there are no cost savings associated with RCRA 

information collection requirements for SQGs that become CESQGs under the final rule. 

However, there are cost savings associated with RCRA information collection requirements for

solvent-contaminated disposable wipes.

To estimate the avoided RCRA information collection requirement costs, the analysis employs 

the following assumptions:

• In states that are expected to adopt the final rule, there are about 35 LQGs and 5,398

SQGs that generate solvent-contaminated disposable wipes (see Exhibit 3-1).

• None of the LQGs will experience a change in generator status under the final rule.116

• 1.7 percent or approximately 92 SQGs are expected (or estimated) to become CESQG 

under the final rule.117

• The annual costs associated with avoided RCRA information collection requirements are 

estimated to be $6,663 (2011 dollars) per generator. The cost in the economic 

background document originally developed for the proposed rule118 has been updated to 

2011 dollars using employment cost data developed by the Bureau of Labor Statistics.119 

 115 CESQGs are facilities that, in a single calendar month, generate 100 kilograms (220 pounds) or less of 

hazardous waste, or 1 kilogram (2.2 pounds) or less of acute hazardous waste.

116 This assumptions was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 168.

117 Ibid.

118 Ibid.

119 Bureau of Labor Statistics. Employment Cost Index - Historical Listing, June 2011, "Table 5. 

Employment Cost Index for total compensation, for private industry workers, by occupation and industry; Continuous 

occupational and industry series (not seasonally adjusted), p. 10. Available online at: 

http://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 26, 2011. Private Industry Workers, All Workers, 

September 2003=93.2 and June 2011=114.3.
70

Exhibit 4-18 shows the annual cost, per facility, to avoid RCRA information collection 

requirements, by type of facilities and type of wipes. 

 

Exhibit 4-18

Annual Cost, per Facility, to Avoid RCRA

Information Collection Requirements, 2011 Dollars

Type of

Facilities

Reusable

Wipes

Disposable

Wipes a

LQGs Not Applicable $0

SQGs Not Applicable ($6,663)

Handling Facilities Not Applicable Not Applicable

a Values in parentheses denote cost savings.

4.3.13. Avoided State Waste Fees and Taxes

Under the final rule, solvent-contaminated reusable and disposable wipes that meet the 

specified conditions will enter the non-hazardous waste stream. As a result, generators of 

solvent-contaminated wipes will be subject to state non-hazardous waste fees and taxes (as 

appropriate), as opposed to state hazardous waste fees and taxes. The avoided state waste 

fees and taxes will result in cost savings to generators.

This analysis assumes that generators in states that have exclusions for solvent-contaminated 

reusable wipes are not subject to state hazardous waste fees and taxes. Therefore, for solventcontaminated reusable wipes, there are no cost savings associated with state waste fees and 

taxes under the final rule. However, there are cost savings associated with state waste fees 

and taxes applied to solvent-contaminated disposable wipes.

To estimate the avoided state waste fees and taxes, the analysis employs the following 

assumptions:

• On average, each LQG facility generates about 191,008 solvent-contaminated 

disposable wipes per year; each SQG facility generates about 25,587 solventcontaminated disposable wipes per year.120 EPA estimates that, on average, the weight 

of a solvent-contaminated disposable wipe is 0.054 pounds (i.e., 33,333 wipes per 

ton).121 To estimate the annual tons of wipes per facility, the analysis takes the annual 

number of solvent-contaminated disposable wipes generated per facility and divides it by 

the number of solvent-contaminated disposable wipes per ton. Based on this 

calculation, EPA estimates that each LQG facility generates about 5 tons of solventcontaminated disposable wipes each year (i.e., 191,008 wipes per year / 33,333 wipes 

per ton); each SQG facility generates about 0.69 tons of solvent-contaminated 

disposable wipes each year (i.e., 25,587 wipes per year / 33,333 wipes per ton). 

 120 These estimates are based on the annual number of solvent-contaminated disposable wipes in 

Exhibit 3-2 and the number of generators of solvent-contaminated disposable wipes in Exhibit 3-1 of this document. 

Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

121 Ibid.
71

• Pursuant to 40 CFR 264.314, the placement of hazardous waste containing “free liquids” 

(whether or not sorbents have been added) in any landfill is prohibited. Without the “no 

free liquids” requirement in effect nationwide, there is no "guarantee" that any single 

container of solvent-contaminated disposable wipes contains "no free liquids.” 

Therefore, under the regulatory baseline, solvent-contaminated disposable wipes are not 

accepted at hazardous waste landfills because of the risk that the container also may 

contain "free liquids" that have percolated out of the wipes during transport to the landfill. 

All generators of solvent-contaminated disposable wipes send their wipes to hazardous 

waste incineration facilities.122

• Under the final rule, EPA estimates that 50 percent of solvent-contaminated disposable 

wipes will be sent to municipal solid waste landfills and the other 50 percent of solventcontaminated disposable wipes will be sent to solid waste combustors.123

• On average, EPA estimates that the residual of the incineration process (i.e., 

incineration ash) is 10 percent of the weight.124

• State waste fees and taxes are estimated as follows:

State Fee/Tax a Estimated Cost per Ton b

(2011 Dollars)

Generation of hazardous waste $1.18

Management of hazardous waste at incinerator $35

Management of non-hazardous waste at municipal solid waste landfill $1.98

Management of non-hazardous waste at solid waste combustor $1.51

a

 In estimating avoided state waste fees and taxes, the analysis does not take into account annual fees to hazardous waste 

generators that are not based on generated tons. For purposes of the analysis, it is assumed that generators of solventcontaminated wipes will continue to generate other types of hazardous wastes and thus, continue to be subject to the annual 

hazardous waste generator fee. 

b

 Estimated cost per ton was derived using data on waste fees and taxes for individual states. Detailed information on the 

derivation of the cost per ton is presented in Appendix B. 

Exhibit 4-19 shows the annual cost, per facility, to avoid state waste fees and taxes, by type of 

facilities and type of wipes. 

 

 122 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. p. 156.

123 Based on professional judgment.

124 Ibid.
72

Exhibit 4-19

Annual Cost, per Facility, to Avoid State Waste Fees and Taxes, 2011 Dollars

Type of

Facilities

Reusable

Wipes

Disposable

Wipes a, b, c

LQG Not Applicable ($178)

SQG Not Applicable ($24)

Handling Facilities Not Applicable Not Applicable

a

 Cost per Facility = ([Fee/Taxes per Facility for Hazardous Waste Generation] + [Fee/Taxes per Facility for Hazardous 

Waste Incineration]) – ([Fee/Taxes per Facility for Municipal Solid Waste Landfill Disposal] + [Fee/Taxes per Facility for 

Solid Waste Combustion])

where:

Fee/Taxes per Facility for Hazardous Waste Generation = [Tons of Wipes per Facility] [$1.18/ton)]. The “tons of 

wipes per facility” is 5 for LQGs and 0.69 for SQGs.

Fee/Taxes per Facility for Hazardous Waste Incineration = [Tons of Wipes per Facility] x [$35/ton)]. The “tons of 

wipes per facility” is 5 for LQGs and 0.69 for SQGs.

Fee/Taxes per Facility for Municipal Solid Waste Landfill Disposal = [50% of Tons of Wipes] x [$1.98/ton)]. The “tons 

of wipes per facility” is 5 for LQGs and 0.69 for SQGs.

Fee/Taxes per Facility for Solid Waste Combustion = [50% of Tons of Wipes] x [$1.51/ton)]. The “tons of wipes per 

facility” is 5 for LQGs and 0.69 for SQGs.

b

 Costs in the exhibit are rounded to the nearest whole number.

c Values in parentheses denote cost savings.
73

5. Other Expected Benefits of the Final Rule

The primary benefit of the final rule is the annual savings associated with RCRA regulatory 

compliance. As reported in Chapter 4, EPA estimates that the final rule will result in net savings

of approximately $18.0 million per year (2011 dollars), using real discount rates of 7 percent, 3 

percent, and 0 percent. In addition, EPA expects that the final rule will result in other expected 

benefits. 

This chapter describes the other expected benefits of the final rule. Section 5.1 summarizes the 

other annual expected benefits of the final rule. Section 5.2 estimates anticipated pollution 

prevention and waste minimization benefits of the final rule. Section 5.3 estimates fire safety 

benefits of the final rule. Section 5.4 estimates the expected benefits to industrial laundries by 

excluding solvent-contaminated reusable wipes from the definition of solid waste—that is, 

removing the label of “waste” for these wipes. 

5.1. Summary of Other Expected Benefits

Exhibit 5-1 summarizes the annual value of the other benefits of the final rule. EPA evaluated

these benefits over a 10-year period, using real discount rates of 7 percent, 3 percent, and 0 

percent.125 As shown in the exhibit, at all three discount rates, the other expected benefits of 

the final rule are estimated to be between $3.7 million and $9.9 million per year (2011 dollars).

 125 In annualizing the benefits, the analysis uses a procedure consistent with EPA’s guidelines for 

discounting future costs and benefits. U.S. Environmental Protection Agency. Guidelines for Preparing Economic 

Analyses, “Chapter 6, Discounting Future Benefits and Costs.” December 17, 2010. Available at: 

http://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0568-50.pdf/$file/EE-0568-50.pdf, last accessed on December 8, 

2011.
74

Exhibit 5-1

Other Expected Benefits of the Final Rule, 2011 Dollars a, b

(At All Three Discount Rates Used in the Analysis)

Type of Impacts Benefits

(2011 Dollars)

Annual Pollution Prevention and Waste Minimization Benefits c $212,358 to

$960,593

Annual Fire Safety Benefits d $230,922 to

$2,309,219

Annual Benefits to Industrial Laundries by excluding solvent-contaminated 

reusable wipes from the definition of solid wastee

$3,293,366 to

$6,586,733

Total Other Annual Expected Benefits f $3,736,647 to

$9,856,546

a Benefits are evaluated over a 10-year period.

b

 Because the value of the expected benefits is the same for each year under evaluation, the annual benefits are the same at all 

three discount rates used in the RIA. 

c

 Pollution prevention and waste minimization benefits are presented in Exhibit 5-2 of this document.

d

 Fire safety benefits are presented in Exhibit 5-3 of this document.

e

 Potential benefits to industrial laundries by excluding solvent-contaminated reusable wipes from the definition of solid waste are 

presented in Exhibit 5-4 of this document.

f

 Total Other Expected Benefits = [Annual Pollution Prevention and Waste Minimization Benefits] + [Annual Fire Safety Benefits] + 

[Annual Benefits to Industrial Laundries by excluding solvent-contaminated reusable wipes from the definition of solid waste].

g

 Equation used to calculate the present value of benefits is discussed in Section 4.1 of this document. h

 Equation used in annualizing benefits is discussed in Section 4.1 of this document.

5.2. Expected Pollution Prevention and Waste Minimization Benefits 

For purposes of this analysis, the pollution prevention and waste minimization benefits of the 

final rule would take the form of avoiding future purchases of virgin solvents if captured spent 

solvent “free liquids” are recycled. In estimating these benefits, the analysis relies on monetized 

benefit estimates (calculated in dollars per ton of spent solvent “free liquids” captured) used in 

the economic background document originally developed for the proposed rule.126, 127 

Generators of solvent-contaminated wipes have the potential to capture and recycle spent 

solvent “free liquids.” Under the final rule, solvent-contaminated reusable wipes must contain 

“no free liquids” at the point of being laundered or dry-cleaned on-site or at the point of being 

transported off-site for laundering or dry-cleaning. Similarly, solvent-contaminated disposable 

wipes must contain “no free liquids” when transported to a landfill or combustor. Therefore, 

generators of solvent-contaminated reusable and disposable wipes must remove (i.e., decant) 

containers in order for their wipes to be eligible for the conditional exclusions under the final 

rule. However, the final rule will lead to incremental pollution prevention and waste minimization 

 126 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. pp. 23-24.

127 In addition to the benefit of avoiding future purchases of virgin solvents if captured spent solvent “free 

liquids” are recycled, the potential environmental benefit of capturing (removing) spent solvent “free liquids” and 

preventing them from loading either into the air, land, or surface waters (via evaporation/volatilization, spills/leakages, 

or laundry effluent wastewaters) is not monetized in this analysis.
75

benefits only for solvent-contaminated disposable wipes, not solvent-contaminated reusable 

wipes.128 

Furthermore, under the hazardous waste regulations, large quantity generators (LQGs) have 

only 90 days to accumulate solvent-contaminated wipes. However, under the final rule, 

generators may accumulate solvent-contaminated wipes, along with free liquids, for up to 180 

days. Longer accumulation periods increase the potential for a generator to accumulate 

sufficient amounts of spent solvent to make recycling economically feasible.

Exhibit 5-2 shows the estimated quantity of spent solvent “free liquids” removed from containers

filled with solvent-contaminated disposable wipes in the states that are expected to adopt the 

final rule. The estimated quantity of spent solvent “free liquids” shown in Exhibit 5-2 was 

derived in Chapter 4 (Section 4.3.7). To estimate pollution prevention and waste minimization

benefits, the quantity of spent solvent “free liquids” is multiplied by monetized benefit estimates 

ranging from $810 to $3,664 per ton (2011 dollars). These monetized benefit estimates are 

based on volatile organic compound (VOC) emissions reduction health benefits that EPA 

applied in three earlier rulemakings promulgated in 1997, 1998, and 2000.129, 130 The per-ton 

benefit estimates in the economic background document for the proposed rule have been 

updated to 2011 dollars using GDP deflators developed by the U.S. Department of 

Commerce.131 

 128 The analysis assumes that, under existing state policies, solvent-contaminated reusable wipes already 

must contain “no free liquids” and, consequently, generators of solvent-contaminated reusable wipes are currently 

capturing and recycling spent solvent “free liquids.” Therefore, for solvent-contaminated reusable wipes, there are no 

incremental pollution prevention and waste minimization benefits associated with the final rule.

129 For additional information on these three rulemakings, refer to the following data sources: (1) EPA’s 

Office of Air and Radiation, Regulatory Impact Analyses for the Particulate Matter and Ozone National Ambient Air 

Quality Standards and Proposed Regional Haze Rule, July 17, 1997, http://www.epa.gov/ttn/oarpg/naaqsfin/ria.html; 

(2) EPA’s Office of Water, Economic Analysis of Final Effluent Limitations Guidelines and Standards for the 

Pharmaceutical Manufacturing Industry, July 30,1998, http://www.epa.gov/ost/guide/pharm/econanal/econanal.pdf; 

and (3) EPA’s Office of Water, “Effluent Guidelines for the Oil and Gas Extraction Point Source Category: Proposed 

Rule,” 65 FR 21567, April 21, 2000, http://www.epa.gov/waterscience/guide/sbf/sbfnoda.pdf. 

130 Many VOCs are carcinogens or contribute to the formation of particulate matter and ozone (i.e., air 

pollution). In the three rulemakings referenced above, VOC emissions reduction health benefits include reduction in 

mortality; cancer risk; chronic and acute bronchitis; hospital admissions due to respiratory problems, congestive heart 

failure, and ischemic heart disease; lower and upper respiratory symptoms; and work loss days. 

131 U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for 

Gross Domestic Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 6, 2011. Year 1998, Quarter IV = 85.988 and Year 2011, Quarter III = 113.823. 
76

Exhibit 5-2

Annual Pollution Prevention and

Waste Minimization Benefits of the Final Rule, 2011 Dollars

Type of Wipes

Annual Tons of

Solvent Removed

from Containers

Annual Pollution Prevention

and Waste Minimization Benefits

Lower Bound b Upper Bound c

Reusable Wipes Not Applicable Not Applicable Not Applicable

Disposable Wipes 262a $0.21 million $0.96 million

Total 262 $0.21 million $0.96 million

a

 The estimated quantity of solvent captured by decanting on-site accumulation containers was taken from Chapter 4 (Section 4.3.7) and 

converted to tons using a conversion factor of 0.0039 tons/gallon.

b

 Lower Bound = [Annual Tons of Solvent Captured] x [$810/ton].

c

 Upper Bound = [Annual Tons of Solvent Captured] x [$3,664/ton].

As shown in Exhibit 5-2, under the final rule, the total annual benefit associated with avoiding 

future purchases of virgin solvents is estimated to be between $0.21 million and $0.96 million.

5.3. Expected Fire Safety Benefits

EPA anticipates that the final rule will result in wipe-related fire safety benefits as a result of 

several specific rule conditions:

• Wipes must be stored in non‐leaking, closed containers. This condition ensures that the 

wipes are contained and are not exposed to the environment (and potential ignition 

sources).

• Wipes must be labeled "Excluded Solvent‐Contaminated Wipes." This condition 

ensures that the generators and handlers are aware of the contents of the containers 

and can handle them appropriately (e.g., not store the wipes next to an open flame). 

Although 46 states have similar requirements as the final rule, they do not have the 

labeling requirement.

• Wipes must contain "no free liquids." Because of this condition, the likelihood of starting 

a fire from solvent-contaminated wipes is greatly reduced.

The above conditions are expected to minimize fugitive air emissions, secure the solventcontaminated wipes from potentially incompatible wastes or ignition sources, and prevent spills 

of “free liquids,” resulting in a reduction in the risk of fires.

Generators and handlers in states that have exemptions/exclusions for solvent-contaminated 

reusable wipes are not currently subject to the hazardous waste regulations; only generators 

and handlers of solvent-contaminated disposable wipes are subject to the hazardous waste 

regulations. In addition, EPA has determined that the conditions of the final rule maintain the 

same level of fire protection as the existing hazardous waste regulations for disposable wipes. 

Therefore, EPA expects there would be no incremental fire safety benefits associated with 
77

solvent-contaminated disposable wipes from this rule. In contrast, EPA expects there would be 

fire safety benefits associated with solvent-contaminated reusable wipes from this rule.

For purposes of this analysis, fire safety benefits of the final rule are estimated as a percentage 

of the costs associated with structure fires caused by spontaneous combustion132 or chemical 

reaction of oily rags. The cost of structure fires caused by spontaneous combustion or chemical 

reaction of oily rags is estimated at $11.18 million per year (2011 dollars). This estimate is 

based on average property damage cost data developed by the National Fire Protection 

Association for the 2005-2009 period.133 

To estimate the maximum achievable fire safety benefit, the cost of structure fires caused by 

spontaneous combustion or chemical reaction of oily rags is assigned in proportion to the 

percent of facilities that generate solvent-contaminated reusable wipes and are located in the 

states that are expected to choose to adopt the final rule. That is, the cost of structure fires 

caused by spontaneous combustion or chemical reaction of oily rags is multiplied by the percent 

of facilities that generate solvent-contaminated reusable wipes and are located in the states that 

are expected to adopt the final rule. The calculation to estimate the maximum achievable fire 

safety benefit is illustrated below:

Maximum

Achievable

Fire Safety

Benefit

=

[Cost of Structure Fires 

Caused by Spontaneous

Combustion or Chemical 

Reaction of Oily Rags

($/year)]

X

[Total Number of Generators (LQGs and SQGs)

of Solvent-Contaminated Reusable Wipes

in states that Are Expected to Adopt the Final Rule]

[Total Number of Facilities in Economic Sub-Sectors with

Generators of Solvent-Contaminated Wipes (All States)]

Based on the above equation, the maximum achievable fire safety benefit associated with the 

final rule is estimated to be $2.31 million per year (i.e., $11.18 million per year x [62,478 LQGs 

and SQGs that use primarily reusable wipes (Exhibit 3-1) / 302,483 facilities that generate 

solvent-contaminated wipes (Exhibit 2-3)]).

For this analysis, EPA estimates a range of fire safety benefits because EPA cannot precisely 

estimate the actual dollar benefit due to the final rule. While there is a good source of 

information on the damage costs of structure fires caused by spontaneous combustion or 

 132 Spontaneous combustion is a byproduct of spontaneous heating, which occurs when a material 

increases in temperature without drawing heat from its surroundings. If the material reaches its ignition temperature, 

spontaneous ignition or combustion occurs. National Fire Protection Association. Fires Caused by Spontaneous 

Combustion or Chemical Reaction. November 2011. p. 2. Available online at: 

http://www.nfpa.org/assets/files/pdf/combustionexecsum.pdf, last accessed on June 5, 2012.

133 National Fire Protection Association. Fires Caused by Spontaneous Combustion or Chemical Reaction. 

November 2011. pp. 30, 34, 44, and 53. Available online at: 

http://www.nfpa.org/assets/files/pdf/combustionexecsum.pdf, last accessed on June 5, 2012. For purposes of this 

analysis, it was assumed that the 2005-2009 average property damage cost of $10.8 million per year was stated in 

2009 dollars. This analysis updated it to 2011 dollars using GDP deflators developed by the U.S. Department of 

Commerce. The estimated cost in 2011 dollars might be understated because the data source used in this analysis 

did not indicate whether the property damage cost data were reported in 2009 dollars or prior year dollars. U.S. 

Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for Gross Domestic 

Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 6, 2011. Year 2009, Quarter IV = 109.943 and Year 2011, Quarter III = 113.823.
78

chemical reaction of oily rags, there is greater uncertainty about the extent to which this rule will 

reduce fires. Therefore, we have assumed that the minimum fire safety benefit associated with 

the final rule would be 10 percent of the maximum achievable fire safety benefit.

Exhibit 5-3 summarizes the annual potential fire benefits of the final rule.

Exhibit 5-3

Annual Fire Safety Benefits of the Final Rule, 2011 Dollars

Type of Wipes

Annual Fire Safety Benefits

Lower Bound a Upper Bound b

Reusable Wipes $0.23 million $2.31 million

Disposable Wipes Not Applicable Not Applicable

Total $0.23 million $2.31 million

a

 Lower Bound = [10 percent of Upper Bound].

b

 Upper Bound = [$11.18 million/year] x [62,478 LQGs and SQGs that use primarily reusable wipes] / [302,483 

facilities that generate solvent-contaminated wipes].

As shown in Exhibit 5-3, under the final rule, the total annual benefit associated with avoiding 

structure fires caused by spontaneous combustion or chemical reaction of solvent-contaminated 

wipes is estimated to fall between $0.23 million and $2.31 million.

5.4. Expected Benefits to Industrial Laundries from Excluding SolventContaminated Reusable Wipes from the Definition of Solid Waste 

In a May 23, 2001 meeting between EPA and reusable wipes suppliers, at least one supplier 

indicated that reusable wipes suppliers (i.e., industrial laundries) want to avoid the negative 

market impact on a product of being labeled as a form of “waste.” Although 45 states provide 

regulatory relief for reusable solvent-contaminated wipes, as long as certain basic conditions 

are met, not all of them exclude reusable solvent-contaminated wipes from the definition of solid 

waste. Under the final rule, solvent-contaminated reusable wipes will be excluded from solid 

waste classification. As a result, solvent-contaminated reusable wipes could realize cachet134

value from not being labeled as a form of “waste”.

The potential magnitude of this benefit has been estimated as follows, drawing on assumptions 

used in the economic background document originally developed for the proposed rule.135 

These assumptions include:

 134 “Cachet” is defined as a seal or mark used especially to designate official approval; an indication of 

approval carrying great prestige; a characteristic feature or quality conferring prestige. Labeling a product as a form 

of waste may reduce the economic value of a product to levels below what one would expect when one takes into 

account the health/safety risk associated with it. There also are mechanisms that may contribute to the social 

amplification of stigma such as mass media reports, litigation, and increased regulation of an industry (Flynn, et al., 

2001, p. 355). 

135 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. p. 172.
79

• 50 percent of the states currently exclude solvent-contaminated reusable wipes from 

solid waste regulatory classification.

136

• The remaining 50 percent of the states currently exclude solvent-contaminated reusable 

wipes from hazardous waste regulatory classification, but not from solid waste 

classification.137

• On average, industrial laundry revenue per (laundered) wipe is $0.066 (2011 dollars). 

The per-wipe revenue estimate in the economic background document for the proposed 

rule has been updated to 2011 dollars using GDP deflators developed by the U.S. 

Department of Commerce. 138 

• Based on empirical findings from a study that measured changes in property values due 

to environmental contamination, EPA estimated that, labeling a product as “waste” may 

result in a 10 percent average loss in product value.139 Since there is uncertainty 

associated with estimating the loss in product value associated with the labeling of 

solvent-contaminated reusable wipes as a form of waste, EPA has assumed a range of 

product value loss from 5% to 10%.

Based on the above assumptions, of the 2.0 billion solvent-contaminated reusable wipes 

generated each year (Exhibit 2-7), 50 percent or 1.0 billion solvent-contaminated reusable wipes 

are generated in states that currently exclude solvent-contaminated reusable wipes from 

hazardous waste regulatory classification only. 

 136 This assumption was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 172.

137 This assumption was obtained from the economic background document developed for the proposed 

rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background 

Document - Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 172.

EPA only estimated benefits for facilities located in states that currently exclude reusable wipes from 

hazardous waste, but not solid waste regulation. Facilities in states that already exclude reusable wipes from solid 

waste classification were not included in this estimate.

138 U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for 

Gross Domestic Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 6, 2011. Year 2003, Quarter II = 93.815 and Year 2011, Quarter III = 113.823. 

139 EPA does not have specific data regarding to what extent the negative impression that may be caused 

by solid waste classification impacts on the reusable wipes market. However, EPA used empirical findings from a 

study that measured changes in property values in James Flynn, Paul Slovic, and Howard Kunreuther. Risk, Media, 

and Stigma: Understanding Public Challenges to Modern Science and Technology. Earthscan Publications Ltd., 

London. 2001. to estimate the benefits of avoided waste “stigma” to be 10% of product value. Since there is 

uncertainty associated with estimating the loss in product value associated with the “waste” label, EPA has assumed 

a range of product value loss from 5% to 10%. Economic loss from the “stigma” associated with hazardous 

chemical/material contamination is basically defined and measured as the difference in the market value of noncontaminated product or property, compared to the market value of comparable but contaminated product or property 

which has been fully remediated (i.e., cleaned-up or decontaminated). “Stigma” encompasses an intangible concept 

of perceived risk that lies beyond remediation costs and includes further discounts to compensate investors, 

purchasers, and/or lenders with the perceived risks associated with formerly contaminated products or property. The 

inference is that stigma may continue to affect product or property values without real or observable contamination 

(ibid, p.189). 
80

To estimate annual industrial laundry revenues, the affected number of solvent-contaminated 

reusable wipes is multiplied by the industrial laundry revenue per wipe. This calculation results 

in estimated annual industrial laundry revenues of $65.9 million (i.e., 1.0 billion wipes x 

$0.066/wipe). Therefore, the potential benefit to industrial laundries by excluding solventcontaminated reusable wipes from the definition of solid waste ranges from $3.3 million per year 

(i.e., 5 percent of $65.9 million/year) to $6.6 million per year (i.e., 10 percent of $65.9

million/year).

Exhibit 5-4 summarizes the benefits of excluding solvent-contaminated reusable wipes from the 

definition of solid waste for LQGs and SQGs. 

Exhibit 5-4

Annual Cachet Benefit to Industrial Laundries from

Excluding Solvent-Contaminated Reusable Wipes From the Definition of Solid Waste, 

2011 Dollars

Type of Wipes

Annual Loss in Product Value

(Sales Revenues)

Lower Bound a Upper Bound b

Reusable Wipes $3.3 million $6.6 million

Disposable Wipes Not Applicable Not Applicable

Total $3.3 million $6.6 million

a

 Lower Bound = [5 percent of Annual Loss in Product Value], where [Annual Loss in Product Value] = [50 percent 

of 2.0 billion solvent-contaminated reusable wipes].x [$0.066/wipe].

b

 Upper Bound = [10 percent of Annual Loss in Product Value] ], where [Annual Loss in Product Value] = [50 

percent of 2.0 billion solvent-contaminated reusable wipes].x [$0.066/wipe].
81

6. Comparison of Benefits to Costs

This chapter compares benefits to costs in order to estimate the net benefits of the final rule. 

The chapter also presents the results of a sensitivity analysis conducted to determine whether, 

and to what extent, the results of the analysis are sensitive to changes in key assumptions and 

numeric inputs. 

6.1. Net Benefits of the Final Rule

This section compares benefits to costs in order to estimate the net benefits of the final rule. 

Based on this comparison, the final rule will result in net savings. 

Exhibit 6-1 presents the costs and benefits of the final rule. As shown in the exhibit, the annual 

net benefits of the final rule are estimated at between $21.7 million and $27.8 million (2011 

dollars), regardless of discount rate. Therefore, EPA can certify that the final rule is not an

“economically significant regulatory action” under Section 3(f)(1) of Executive Order 12866

(Regulatory Planning and Review).140

 140 Under Section 3(f)(1) of Executive Order 12866, Regulatory Planning and Review, a "significant 

regulatory action" means any regulatory action that is likely to result in a rule that may have an annual effect on the 

economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, 

productivity, competition, jobs, the environment, public health or safety, or state, local, or tribal governments or 

communities.
82

Exhibit 6-1

Comparison of Benefits to Costs under the Final Rule, 2011 Dollars a

Type of Impacts 7% 3% 0%

Discount Rate Discount Rate Discount Rate

Benefits

Annual Regulatory Compliance Savings

(i.e., avoided costs) b $24,375,585 $24,375,585 $24,375,585

Other Annual Expected Benefits c $3,736,647 to

$9,856,546

$3,736,647 to

$9,856,546

$3,736,647 to

$9,856,546

Total Benefits $28,112,232 to

$34,232,131

$28,112,232 to

$34,232,131

$28,112,232 to

$34,232,131

Costs

Annual Regulatory Compliance Costs d, e $6,424,899 $6,401,231 $6,384,241

Total Costs $6,424,899 $6,401,231 $6,384,241

Net Benefits

Net Benefits f $21,687,333 to

$27,807,231

$21,711,001 to

$27,830,900

$21,727,991 to

$27,847,890

a

 Costs and benefits are evaluated over a 10-year period.

b

 Annual regulatory compliance savings are reported as estimated in Exhibit 4-1 of this document, and include: (1) management of “free liquids” removed from 

containers, (2) avoided hazardous waste manifest costs, (3) avoided disposal costs, (4) avoided RCRA information collection requirement costs to SQGs that 

may become CESQGs, and (5) avoided state waste fees and taxes.

c Other annual expected benefits are reported as estimated in Exhibit 5-1 of this document, and include: (1) pollution prevention and waste minimization 

benefits, (2) fire safety benefits, and (3) benefits to industrial laundries by excluding solvent-contaminated reusable wipes from the definition of solid waste.

d

 Annual regulatory compliance costs are reported as estimated in Exhibit 4-1 of this document, and include: (1) reading the final rule, (2) management of 

“free liquids” removed from containers, (3) avoided hazardous waste manifest costs, (4) avoided disposal costs, (5) avoided RCRA information collection 

requirement costs to SQGs that may become CESQGs, and (6) avoided state waste fees and taxes.

e Annual regulatory compliance costs include annualized one-time costs as well as annual costs.

f

 Net Benefits = [Total Benefits] - [Total Costs].

6.2. Sensitivity Analysis

This section presents a sensitivity analysis in order to determine whether, and to what extent, 

the results of the analysis are sensitive to changes in key assumptions and numeric inputs. The 

sensitivity analysis estimates economic impacts according to the three alternative sets of 

parameters shown in Exhibit 6-2:

• Lower Bound Values. Lowest estimate of number of entities directly impacted, as well 

as minimum unit values and quantities.

• Most Likely Values. EPA’s “best judgment” for key parameters (which do not necessarily 

represent the mid-point between the lower and upper bound). These values reflect the 

key assumptions and numeric inputs discussed in Chapters 2 through 5 of this 

document. 

• Upper Bound Values. Highest estimate of number of entities impacted, as well as 

maximum unit values and quantities.
83

Exhibit 6-2 presents the assumptions associated with key parameters used in the sensitivity 

analysis. These assumptions are shown in percentages. These percentages are applied to the 

number of generators and handlers of solvent-contaminated wipes and to the number of 

solvent-contaminated wipes, as appropriate, in order to analyze the sensitivity of the costs and 

benefits of the final rule. The percentages presented in Exhibit 6-2 are taken directly from the 

economic background document originally developed for the proposed rule.141 

Exhibit 6-2

Assumptions Associated with Key Parameters Used

in Sensitivity Analysis of Economic Impact Estimation

Cost Elements Lower 

Bound 

Most 

Likely

Upper 

Bound

Affected

Universe Percent of states that are expected to adopt the final rule 50% 75% 100%

Containers

for SolventContaminated

Wipes

Percent of wipes not currently accumulated, stored, and 

transported in closed containers 25% 50% 80%

Management of 

"Free Liquids"

Percent of solvent-contaminated wipes 

with "free liquids"

Printers 90% 100% 100%

Non-Printers 40% 50% 60%

In conducting the sensitivity analysis, EPA re-computed the annual costs and benefits of the 

final rule using the lower-bound and the upper-bound parameters shown in Exhibit 6-2. The 

results of the sensitivity analysis are presented in Exhibit 6-3.

Exhibit 6-3

Net Annual Benefits of the Final Rule 

Based on the Sensitivity Analysis, 2011 Dollars a, b

Alternative

Set of Parameters

7%

Discount Rate

3%

Discount Rate

0%

Discount Rate

Lower Bound $15,590,382 to

$20,705,549

$15,614,050 to

$20,729,217

$15,631,040 to

$20,746,207

Most Likely $21,687,333 to

$27,807,231

$21,711,001 to

$27,830,900

$21,727,991 to

$27,847,890

Upper Bound $27,622,585 to

$34,735,348

$27,646,254 to

$34,759,016

$27,663,243 to

$34,776,006

a

 Except for the use of the percentages shown in Exhibit 6-2, the methodology used to estimate the annualized costs 

and benefits of the final rule for the lower-bound and the upper-bound alternatives is the same as presented in 

Chapters 4 (for costs) and 5 (for benefits).

b

 Costs and benefits are evaluated over a 10-year period.

 141 U.S. Environmental Protection Agency. Economics Background Document - Estimate of National 

Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. 

July 17, 2003. pp. 31-35. 
84

As shown in the exhibit, the net annual benefits of the final rule are estimated to be between 

$15.6 million and $34.8 million (2011 dollars), depending on the alternative set of parameters 

used to estimate the costs and benefits. In all cases, EPA concludes that the final rule is not an

“economically significant regulatory action” under Section 3(f)(1) of Executive Order 12866.
85

7. Supplemental Analyses Required by Congressional Statutes or 

White House Executive Orders

This chapter presents supplemental analyses for Congressional statutes and White House 

Executive Orders.

7.1. Regulatory Flexibility Act (RFA), as Amended by the Small Business 

Regulatory Enforcement Fairness Act (SBREFA)

The Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory 

Enforcement Fairness Act (SBREFA), requires EPA to prepare a regulatory flexibility analysis 

and convene a Small Business Advocacy Review (SBAR) Panel of any rule subject to notice 

and comment rulemaking requirements under the Administrative Procedure Act (APA) or any 

other statute, unless the Agency can certify that the rule will not have a significant economic 

impact on a substantial number of small entities. Small entities include small businesses, small 

organizations, and small governmental jurisdictions.

This analysis documents the Agency’s basis for certifying that the final rule will not result in a 

significant economic impact on a substantial number of small entities.142 In making this 

determination, the analysis first identifies the industries (based on five- or six-digit NAICS code)

that will be affected by the final rule. For each of the industries, the analysis estimates the 

number of small affected entities. The analysis then compares the average compliance cost per

entity, regardless of size, with the estimated revenue for the smallest of the small entities, firms 

with one employee. The ratio of compliance cost as a percentage of revenue is one of the 

impact measures recommended in EPA guidance for assessing a rule's economic impact on 

small entities.

143 The analysis assumes that small entities incurring incremental costs of less 

than one percent will not face significant economic impacts as a result of the final rule. 

The final rule will affect various entities that generate or handle solvent-contaminated reusable 

or disposable wipes (LQGs, SQGs, and handling facilities). These entities are characterized in 

Chapter 2 of this document. However, all affected entities generating or handling solventcontaminated disposable wipes are expected to incur savings as a result of the final rule (see 

Exhibit 4-3 of this document). Consequently, these small entities are not expected to incur any 

adverse impact as a result of the final rule. 

 142 Generally, the certification is based on an analysis that considers the small affected entities and 

compares their compliance costs to their revenues. However, a conservative approach was taken to analyze the 

economic impacts on these small affected entities. An analysis of average compliance cost per entity, regardless of 

size (including larger entities), and revenue generated by the smallest of small entities, firms with only one employee 

was conducted to certify that the final rule will not result in significant economic impacts on a substantial number of 

small entities. Using average cost per entity, regardless of size, will overestimate the economic impacts on small 

entities because smaller operations use fewer rags and wipes compared to larger operations and therefore, have 

lower compliance costs. Similarly, using revenue estimates based on firms with only one employee will 

underestimate the revenue generated by small entities because many, if not most affected small entities will have 

more than one employee and, thus, will generate higher levels of revenue to support more employees. Because the 

resulting impacts are less than one percent (i.e., cost as a percent of revenue), EPA concluded that the majority of 

small entities will not face significant economic impacts as a result of the final rule.

143 U.S. Environmental Protection Agency. Final Guidance for EPA Rulewriters: Regulatory Flexibility Act 

as Amended by the Small Business and Regulatory Enforcement Fairness Act. November 2006. Available at: 

http://www.epa.gov/rfa/documents/Guidance-RegFlexAct.pdf, last accessed on December 19, 2011. 
86

The analysis and results are summarized in Exhibit 7-1 and are described in more detail in the 

following paragraphs.
March 16, 2012 DRAFT 87

Exhibit 7-1

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a, b

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Printing

323110 < 500 Employees $235,891 10 $495 0.21% 5,306 $98 0.04% 1 ($11,851) - 461 ($1,218) - 0 0.00%

323111 < 500 Employees $165,574 8 $495 0.30% 117 $98 0.06% 1 ($11,851) - 10 ($1,218) - 0 0.00%

323112 < 500 Employees $397,617 4 $495 0.12% 357 $98 0.02% 0 ($11,851) - 31 ($1,218) - 0 0.00%

323113 < 500 Employees $174,561 1 $495 0.28% 2,157 $98 0.06% 0 ($11,851) - 188 ($1,218) - 0 0.00%

323114 < 500 Employees $105,164 0 $495 0.47% 3,143 $98 0.09% 0 ($11,851) - 273 ($1,218) - 0 0.00%

323115 < 500 Employees $148,186 0 $495 0.33% 815 $98 0.07% 0 ($11,851) - 71 ($1,218) - 0 0.00%

323116 < 500 Employees $612,537 0 $495 0.08% 213 $98 0.02% 0 ($11,851) - 19 ($1,218) - 0 0.00%

323117 < 500 Employees $284,476 0 $495 0.17% 221 $98 0.03% 0 ($11,851) - 19 ($1,218) - 0 0.00%

323118 < 500 Employees $173,974 0 $495 0.28% 85 $98 0.06% 0 ($11,851) - 7 ($1,218) - 0 0.00%

323119 < 500 Employees $105,239 1 $495 0.47% 1,025 $98 0.09% 0 ($11,851) - 89 ($1,218) - 0 0.00%

323121 < 500 Employees $165,487 0 $495 0.30% 467 $98 0.06% 0 ($11,851) - 41 ($1,218) - 0 0.00%

323122 < 500 Employees $92,254 2 $495 0.54% 643 $98 0.11% 0 ($11,851) - 56 ($1,218) - 0 0.00%

Publishing

(printed matter)

51111 < 500 Employees $109,363 0 $461 0.42% 2,499 $94 0.09% 0 ($10,653) - 217 ($1,089) - 0 0.00%

51112 < 500 Employees $377,341 0 $461 0.12% 2,770 $94 0.02% 0 ($10,653) - 241 ($1,089) - 0 0.00%

51113 < 500 Employees $156,368 0 $461 0.29% 1,371 $94 0.06% 0 ($10,653) - 119 ($1,089) - 0 0.00%

51114 < 500 Employees $235,415 0 $461 0.20% 491 $94 0.04% 0 ($10,653) - 43 ($1,089) - 0 0.00%

51119 < 500 Employees $316,855 1 $461 0.15% 553 $94 0.03% 0 ($10,653) - 48 ($1,089) - 0 0.00%

Business

Services

(copy shops)

561439 < $7 Million 

Annual Revenue $145,696 1 $450 0.31% 1,145 $93 0.06% 0 ($10,281) - 100 ($1,040) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

88

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Chemical

and Allied

Products

211112 < 500 Employees $1,761,649 0 $364 0.02% 14 $112 0.01% 0 ($27,151) - 1 ($6,880) - 0 0.00%

32511 < 1,000 

Employees $294,240 1 $364 0.12% 3 $112 0.04% 0 ($27,151) - 0 ($6,880) - 0 0.00%

32512 < 1,000 

Employees $639,081 0 $364 0.06% 10 $112 0.02% 0 ($27,151) - 1 ($6,880) - 0 0.00%

325131 < 1,000 

Employees $330,780 1 $364 0.11% 7 $112 0.03% 0 ($27,151) - 1 ($6,880) - 0 0.00%

325132 < 750 Employees $343,876 1 $364 0.11% 10 $112 0.03% 0 ($27,151) - 1 ($6,880) - 0 0.00%

325181 < 1,000 

Employees $460,389 0 $364 0.08% 3 $112 0.02% 0 ($27,151) - 0 ($6,880) - 0 0.00%

325182 < 500 Employees - 0 $364 - 1 $112 - 0 ($27,151) - 0 ($6,880) - - -

325188 < 1,000 

Employees $858,195 4 $364 0.04% 39 $112 0.01% 0 ($27,151) - 3 ($6,880) - 0 0.00%

325191 < 500 Employees $355,140 0 $364 0.10% 5 $112 0.03% 0 ($27,151) - 0 ($6,880) - 0 0.00%

325192 < 750 Employees $613,182 0 $364 0.06% 2 $112 0.02% 0 ($27,151) - 0 ($6,880) - 0 0.00%

325193 < 1,000 

Employees $5,561,097 0 $364 0.01% 30 $112 0.00% 0 ($27,151) - 3 ($6,880) - 0 0.00%

325199 < 1,000 

Employees $1,360,726 7 $364 0.03% 54 $112 0.01% 1 ($27,151) - 5 ($6,880) - 0 0.00%

325998 < 500 Employees $810,885 9 $364 0.04% 132 $112 0.01% 1 ($27,151) - 11 ($6,880) - 0 0.00%

331311 < 1,000 

Employees $212,667 0 $364 0.17% 1 $112 0.05% 0 ($27,151) - 0 ($6,880) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

89

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Plastics

and Rubber

31332 < 1,000 

Employees $242,185 7 $367 0.15% 17 $112 0.05% 1 ($27,607) - 2 ($7,010) - 0 0.00%

315299 < 500 Employees $166,288 0 $367 0.22% 51 $112 0.07% 0 ($27,607) - 4 ($7,010) - 0 0.00%

315999 < 500 Employees $218,587 0 $367 0.17% 82 $112 0.05% 0 ($27,607) - 7 ($7,010) - 0 0.00%

325991 < 500 Employees $470,938 3 $367 0.08% 59 $112 0.02% 0 ($27,607) - 5 ($7,010) - 0 0.00%

326113 < 500 Employees $478,738 7 $367 0.08% 64 $112 0.02% 1 ($27,607) - 6 ($7,010) - 0 0.00%

326121 < 500 Employees $425,156 1 $367 0.09% 61 $112 0.03% 0 ($27,607) - 5 ($7,010) - 0 0.00%

32613 < 500 Employees $308,226 7 $367 0.12% 28 $112 0.04% 1 ($27,607) - 2 ($7,010) - 0 0.00%

32614 < 500 Employees $1,357,239 0 $367 0.03% 51 $112 0.01% 0 ($27,607) - 4 ($7,010) - 0 0.00%

32615 < 500 Employees $492,198 1 $367 0.07% 57 $112 0.02% 0 ($27,607) - 5 ($7,010) - 0 0.00%

32616 < 500 Employees $1,245,605 0 $367 0.03% 22 $112 0.01% 0 ($27,607) - 2 ($7,010) - 0 0.00%

326191 < 500 Employees $177,794 1 $367 0.21% 66 $112 0.06% 0 ($27,607) - 6 ($7,010) - 0 0.00%

326192 < 750 Employees $107,375 1 $367 0.34% 4 $112 0.10% 0 ($27,607) - 0 ($7,010) - 0 0.00%

326199 < 500 Employees $375,035 14 $367 0.10% 790 $112 0.03% 2 ($27,607) - 69 ($7,010) - 0 0.00%

326211 < 1,000 

Employees $341,923 1 $367 0.11% 9 $112 0.03% 0 ($27,607) - 1 ($7,010) - 0 0.00%

32622 < 500 Employees $513,576 1 $367 0.07% 22 $112 0.02% 0 ($27,607) - 2 ($7,010) - 0 0.00%

326291 < 500 Employees $445,488 3 $367 0.08% 52 $112 0.03% 0 ($27,607) - 5 ($7,010) - 0 0.00%

326299 < 500 Employees $370,958 6 $367 0.10% 78 $112 0.03% 1 ($27,607) - 7 ($7,010) - 0 0.00%

337215 < 500 Employees $319,668 1 $367 0.11% 111 $112 0.04% 0 ($27,607) - 10 ($7,010) - 0 0.00%

339113 < 500 Employees $212,023 4 $367 0.17% 225 $112 0.05% 0 ($27,607) - 20 ($7,010) - 0 0.00%

339932 < 500 Employees $156,400 0 $367 0.23% 94 $112 0.07% 0 ($27,607) - 8 ($7,010) - 0 0.00%

339991 < 500 Employees $204,194 1 $367 0.18% 68 $112 0.05% 0 ($27,607) - 6 ($7,010) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

90

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Fabricated

Metal

Products

332812 < 500 Employees $730,880 32 $360 0.05% 299 $110 0.02% 3 ($26,568) - 26 ($6,735) - 0 0.00%

332813 < 500 Employees $232,299 18 $360 0.15% 348 $110 0.05% 2 ($26,568) - 30 ($6,735) - 0 0.00%

339911 < 500 Employees $299,142 0 $360 0.12% 242 $110 0.04% 0 ($26,568) - 21 ($6,735) - 0 0.00%

339912 < 500 Employees $133,170 0 $360 0.27% 19 $110 0.08% 0 ($26,568) - 2 ($6,735) - 0 0.00%

339914 < 500 Employees $77,565 0 $360 0.46% 79 $110 0.14% 0 ($26,568) - 7 ($6,735) - 0 0.00%

Industrial

Machinery and

Equipment

314999 < 500 Employees $181,095 0 $415 0.23% 296 $124 0.07% 0 ($34,356) - 26 ($8,676) - 0 0.00%

332323 < 500 Employees $147,765 1 $415 0.28% 355 $124 0.08% 0 ($34,356) - 31 ($8,676) - 0 0.00%

33241 < 500 Employees $1,172,743 1 $415 0.04% 34 $124 0.01% 0 ($34,356) - 3 ($8,676) - 0 0.00%

332991 < 750 Employees $499,154 0 $415 0.08% 12 $124 0.02% 0 ($34,356) - 1 ($8,676) - 0 0.00%

333111 < 500 Employees $324,274 3 $415 0.13% 149 $124 0.04% 0 ($34,356) - 13 ($8,676) - 0 0.00%

33312 < 750 Employees $583,597 3 $415 0.07% 88 $124 0.02% 0 ($34,356) - 8 ($8,676) - 0 0.00%

33322 < 500 Employees $314,635 0 $415 0.13% 69 $124 0.04% 0 ($34,356) - 6 ($8,676) - 0 0.00%

333295 < 500 Employees $673,464 2 $415 0.06% 23 $124 0.02% 0 ($34,356) - 2 ($8,676) - 0 0.00%

333298 < 500 Employees $256,551 1 $415 0.16% 166 $124 0.05% 0 ($34,356) - 14 ($8,676) - 0 0.00%

333319 < 500 Employees $507,088 1 $415 0.08% 166 $124 0.02% 0 ($34,356) - 14 ($8,676) - 0 0.00%

333414 < 500 Employees $227,172 0 $415 0.18% 51 $124 0.05% 0 ($34,356) - 4 ($8,676) - 0 0.00%

333511 < 500 Employees $139,846 1 $415 0.30% 270 $124 0.09% 0 ($34,356) - 23 ($8,676) - 0 0.00%

333512 < 500 Employees $143,050 1 $415 0.29% 75 $124 0.09% 0 ($34,356) - 7 ($8,676) - 0 0.00%

333513 < 500 Employees $197,809 0 $415 0.21% 38 $124 0.06% 0 ($34,356) - 3 ($8,676) - 0 0.00%

333514 < 500 Employees $104,804 0 $415 0.40% 428 $124 0.12% 0 ($34,356) - 37 ($8,676) - 0 0.00%

333515 < 500 Employees $326,685 0 $415 0.13% 202 $124 0.04% 0 ($34,356) - 18 ($8,676) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

91

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Industrial

Machinery and

Equipment

(continued)

333518 < 500 Employees $419,408 0 $415 0.10% 48 $124 0.03% 0 ($34,356) - 4 ($8,676) - 0 0.00%

333911 < 500 Employees $305,604 2 $415 0.14% 50 $124 0.04% 0 ($34,356) - 4 ($8,676) - 0 0.00%

333923 < 500 Employees $665,645 3 $415 0.06% 33 $124 0.02% 0 ($34,356) - 3 ($8,676) - 0 0.00%

333999 < 500 Employees $525,606 2 $415 0.08% 210 $124 0.02% 0 ($34,356) - 18 ($8,676) - 0 0.00%

33651 < 1,000 

Employees $899,757 0 $415 0.05% 19 $124 0.01% 0 ($34,356) - 2 ($8,676) - 0 0.00%

Furniture

and Fixtures

337110 < 500 Employees $96,548 13 $363 0.38% 1,364 $111 0.12% 1 ($27,040) - 119 ($6,832) - 0 0.00%

337121 < 500 Employees $142,994 0 $363 0.25% 187 $111 0.08% 0 ($27,040) - 16 ($6,832) - 0 0.00%

337122 < 500 Employees $210,111 1 $363 0.17% 487 $111 0.05% 0 ($27,040) - 42 ($6,832) - 0 0.00%

337124 < 500 Employees $181,943 0 $363 0.20% 45 $111 0.06% 0 ($27,040) - 4 ($6,832) - 0 0.00%

337127 < 500 Employees $212,645 0 $363 0.17% 87 $111 0.05% 0 ($27,040) - 8 ($6,832) - 0 0.00%

337211 < 500 Employees $359,656 2 $363 0.10% 62 $111 0.03% 0 ($27,040) - 5 ($6,832) - 0 0.00%

337212 < 500 Employees $254,149 1 $363 0.14% 220 $111 0.04% 0 ($27,040) - 19 ($6,832) - 0 0.00%

337215 < 500 Employees $319,668 1 $363 0.11% 111 $111 0.03% 0 ($27,040) - 10 ($6,832) - 0 0.00%

Auto Dealers

(retail trade)

44111 < 200 Employees $1,769,995 0 $352 0.02% 2,917 $109 0.01% 0 ($25,593) - 254 ($6,476) - 0 0.00%

44112 < $23 Million 

Annual Revenue $626,214 1 $352 0.06% 3,258 $109 0.02% 0 ($25,593) - 283 ($6,476) - 0 0.00%

Military

Bases 92812 - - 0 $389 - 0 $119 - 0 ($26,742) - 0 ($7,495) - - -

Electronics

and Computers

334411 < 750 Employees $134,300 2 $641 0.48% 6 $180 0.13% 0 ($65,304) - 1 ($16,522) - 0 0.00%

334412 < 500 Employees $268,086 8 $641 0.24% 83 $180 0.07% 1 ($65,304) - 7 ($16,522) - 0 0.00%

334413 < 500 Employees $425,346 30 $641 0.15% 77 $180 0.04% 3 ($65,304) - 7 ($16,522) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

92

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Transportation

Equipment

332912 < 500 Employees $342,938 0 $350 0.10% 37 $108 0.03% 0 ($25,247) - 3 ($6,395) - 0 0.00%

336111 < 1,000 

Employees $2,933,702 6 $350 0.01% 16 $108 0.00% 0 ($25,247) - 1 ($6,395) - 0 0.00%

336112 < 1,000 

Employees $1,533,251 3 $350 0.02% 4 $108 0.01% 0 ($25,247) - 0 ($6,395) - 0 0.00%

336211 < 1,000 

Employees $526,895 10 $350 0.07% 88 $108 0.02% 1 ($25,247) - 8 ($6,395) - 0 0.00%

336312 < 750 Employees $435,006 2 $350 0.08% 107 $108 0.02% 0 ($25,247) - 9 ($6,395) - 0 0.00%

33633 < 750 Employees $803,710 2 $350 0.04% 23 $108 0.01% 0 ($25,247) - 2 ($6,395) - 0 0.00%

33634 < 750 Employees $563,004 0 $350 0.06% 22 $108 0.02% 0 ($25,247) - 2 ($6,395) - 0 0.00%

336399 < 750 Employees $321,211 7 $350 0.11% 142 $108 0.03% 1 ($25,247) - 12 ($6,395) - 0 0.00%

336411 < 1,500 

Employees $359,948 17 $350 0.10% 16 $108 0.03% 1 ($25,247) - 1 ($6,395) - 0 0.00%

336412 < 1,000 

Employees $581,014 10 $350 0.06% 30 $108 0.02% 1 ($25,247) - 3 ($6,395) - 0 0.00%

336414 < 1,000 

Employees $186,489 1 $350 0.19% 0 $108 0.06% 0 ($25,247) - 0 ($6,395) - 0 0.00%

336415 < 1,000 

Employees $188,950 1 $350 0.19% 0 $108 0.06% 0 ($25,247) - 0 ($6,395) - 0 0.00%

336419 < 1,000 

Employees $185,908 0 $350 0.19% 5 $108 0.06% 0 ($25,247) - 0 ($6,395) - 0 0.00%

336612 < 500 Employees $279,063 11 $350 0.13% 135 $108 0.04% 1 ($25,247) - 12 ($6,395) - 0 0.00%

336992 < 1,000 

Employees $230,571 1 $350 0.15% 6 $108 0.05% 0 ($25,247) - 1 ($6,395) - 0 0.00%

48839 < $7 Million 

Annual Revenue $121,153 0 $350 0.29% 63 $108 0.09% 0 ($25,247) - 5 ($6,395) - 0 0.00%

54171 < 500 Employees $273,692 6 $350 0.13% 1,543 $108 0.04% 0 ($25,247) - 134 ($6,395) - 0 0.00%

81149 < $7 Million 

Annual Revenue $93,674 0 $350 0.37% 831 $108 0.12% 0 ($25,247) - 72 ($6,395) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

93

Economic Sub-Sectors with Generators of Solvent-Contaminated Wipes

Economic

Sub-Sectors

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

LQGs that Use

Primarily Reusable Wipes

SQGs that Use

Primarily Reusable Wipes

LQGs that Use

Primarily Disposable Wipes

SQGs that Use

Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) i

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities g, h

Average

PerFacility

Costs

(2011

Dollars) h

Cost 

as a

Percent

of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Auto Repair

and

Maintenance

811111 < $7 Million 

Annual Revenue $142,100 1 $343 0.24% 8,823 $107 0.08% 0 ($28,944) - 767 ($6,250) - 0 0.00%

811112 < $7 Million 

Annual Revenue $152,753 0 $343 0.22% 324 $107 0.07% 0 ($28,944) - 28 ($6,250) - 0 0.00%

Economic Sub-Sectors with Handlers of Solvent-Contaminated Wipes

Economic

Sub-Sector

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size 

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

Handlers of Reusable Wipes Handlers of Disposable Wipes All Handlers

Number Affected

Small Entities g, h

Average

Per-Facility Costs

(2011 Dollars) i

Cost as a

Percent of

Revenue

Number Affected

Small Entities g, h

Average

Per-Facility Costs

(2011 Dollars) i

Cost as a

Percent of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Solid Waste

Management

Non-Hazardous

Wastes

562111 < $12.5 Million 

Annual Revenue $164,098 - - - 293 ($157) - 0 0.00%

562212 < $12.5 Million 

Annual Revenue $258,634 - - - 348 ($157) - 0 0.00%

562213 < $12.5 Million 

Annual Revenue $175,073 - - - 84 ($157) - 0 0.00%

562219 < $12.5 Million 

Annual Revenue $212,238 - - - 706 ($157) - 0 0.00%

56292 < $12.5 Million 

Annual Revenue $314,032 - - - 1 ($157) - 0 0.00%

Solid Waste

Management

Hazardous

Wastes

562112 < $12.5 Million 

Annual Revenue $631,835 - - - 155 ($157) - 0 0.00%

562211 < $12.5 Million 

Annual Revenue $250,991 - - - 644 ($157) - 0 0.00%
Exhibit 7-1 (continued)

Small Business Size Standards, Number of Affected Small Entities, Per-Facility Costs,

Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a

94

Economic Sub-Sectors with Handlers of Solvent-Contaminated Wipes

Economic

Sub-Sector

Industries

(5- or 6-

Digit NAICS

Code) c, d

SBA Size 

Standard

for Small

Businesses e

Estimated

Revenue

for Entity

with One

Employee

(2011 

Dollars) f

Handlers of Reusable Wipes Handlers of Disposable Wipes All Handlers

Number Affected

Small Entities g, h

Average

Per-Facility Costs

(2011 Dollars) i

Cost as a

Percent of

Revenue

Number Affected

Small Entities g, h

Average

Per-Facility Costs

(2011 Dollars) i

Cost as a

Percent of

Revenue

Number

Affected

Small

Entities 

Over 1%

Percent

of 

Affected

Small

Entities

Over 1%

Linen Supply

and Laundering 812332 < $35.5 Million Annual Revenue $208,895 227 $51 0.02% - - - 0 0.00%

Total for All Sub-Sectors

 All Affected Small Entities (Total) 0 0.00%

a

 The economic impact measure used in this analysis is the compliance cost as a percentage of revenue; [Compliance Cost / Revenue]. The analysis likely overstates impacts because: (1) the incremental per facility cost is based on the 

average per-facility cost for an industry, when in reality, smaller firms generally will incur lower costs under the final rule; (2) revenue per firm is proxied by revenue per facility, so may be understated; in addition, the analysis scales revenue 

down to firms with only one employee, even though many or most small entities will have more than one employee and sufficient revenue to support more than one employee. In effect, the analysis assumes that all affected small entities are 

very small, having only one employee and one facility. In reality, most affected small entities will have more than one employee, and many affected small entities will have more than one facility (along with greater revenue to support the 

additional facility(ies)).

b In the exhibit, “-“ means that the data element is not applicable or available. 

c

 Affected industries (based on five- or six-digit NAICS codes) are as reported in Chapter 2 of this document. 

d

 Appendix A describes each of the NAICS codes in the exhibit.

e

 Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes. November 5, 2010. Available at: http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf, 

last accessed on December 6, 2011.

f

 The analysis estimates “revenue for entity with one employee” using linear regression on revenue data for entities with between 0 and 60 employees in each affected industry. Revenue data were obtained from the following data source: 

U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six-Digit NAICS Code. Available at http://www.census.gov/econ/susb/data/susb2007.html, last accessed on December 6, 2011.

g

 Total number of small firms for each industry was obtained from the following two data sources: (1) U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six Digit NAICS Code. Available at: 

http://www.census.gov/econ/susb/data/susb2007.html, last accessed on December 6, 2011. (2) U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S. all industries data by receipt size. Available at: 

http://www.sba.gov/advocacy/849/12162#susb, last accessed on December 20, 2011. 

h The analysis assumes that, within each industry, the percent of small firms affected by the final rule is equal to the percent of facilities that generate (LQGs and SQGs) or handle solvent-contaminated reusable wipes in states that will adopt 

the final rule, as estimated in Appendix C.

i

 Estimation of per-facility costs is discussed in Chapter 4.
95

• Identification of affected industries. EPA identified 121 industries (based on 5- or 6-digit 

NAICS code) with generators or handlers of solvent-contaminated wipes, as reported in 

Chapter 2 of this document. Exhibit 7-1 identifies the affected industries. 

• Estimation of the number of affected small entities. The analysis defines small entities 

based on size standards established by the Small Business Administration (SBA).144 

These standards define small businesses as firms having less than a specified number 

of employees or less than a specified level of annual receipts. To estimate the total 

number of small firms in each of the 121 affected industries, the analysis draws on 2007 

SUSB data published by the U.S. Census Bureau.145, 146 The SUSB provides 

information on the number of firms, number of establishments, and estimated receipts 

(or revenues), by enterprise employment size and by receipt size (e.g., less than 

$100,000, $100,000 to 499,000). These data are used to determine the number of small 

entities in each industry. To estimate the number of small entities affected by the final 

rule, the analysis assumes that, within each industry, the percent of small firms affected 

by the final rule is equal to the percent of facilities that generate (LQGs and SQGs) or 

handle solvent-contaminated wipes in states that will adopt the final rule. For example, if 

92 percent of facilities in an industry are SQGs that generate solvent-contaminated 

reusable wipes in the states that will adopt the final rule, the analysis assumes that, in 

that industry, 92 percent of small firms are SQGs that generate solvent-contaminated 

reusable wipes in states that will adopt the final rule. Appendix C presents, for each 

industry, the percent of facilities that generate or handle solvent-contaminated wipes in 

states that will adopt the final rule. Exhibit 7-1 provides the SBA small business size 

standard and the number of affected small entities for each industry. The analysis 

estimates that 57,786 small entities that use or handle solvent-contaminated wipes are 

located in states that will adopt the final rule (i.e., 55,327 generators and 2,458 

handlers).

• Estimation of compliance costs. The analysis assumes that small entities incur the 

average per-facility cost for their industry.147 This average per-facility cost is the same 

for all entities (i.e., large and small entities) within an industry. Compliance costs vary 

for each type of facility (i.e., LQG, SQG, and handling facility) in each of the 121 affected 

industries. Exhibit 7-1 presents the resulting per-facility costs for each affected industry. 

Using the average per-facility cost likely will overstate the actual cost for many or most 

small entities, including in particular the smallest of the small entities that are considered 

in this analysis (see next bullet). Consequently, impacts also may be overstated. 

Moreover, the analysis evaluates the impact to small entities based on first-year costs, 

which include both annual and first-year one-time costs. The use of first-year one-time 

costs will overstate the actual costs for small entities because the first-year one-time 

costs will be spread over the life of the firm. Costs in subsequent years will be less (i.e.,

 144 Small Business Administration. Table of Small Business Size Standards Matched to North American 

Industry Classification System Codes. November 5, 2010. Available at: 

http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf, last accessed on December 6, 2011.

145 U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six Digit NAICS 

Code. Available at: http://www.census.gov/econ/susb/data/susb2007.html, last accessed on December 6, 2011.

146 U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S. all industries data 

by receipt size. Available at: http://www.sba.gov/advocacy/849/12162#susb, last accessed on December 20, 2011.

147 In estimating the average per-facility cost for an industry, the analysis applies the methodology 

described in Chapter 4 of this document.
96

they do not include the first-year one-time costs). Therefore, economic impacts in 

subsequent years will be reduced. 

• Estimation of total revenue. Financial information is not available on every firm that is 

going to be affected by the final rule. Therefore, in evaluating the impacts of the final 

rule on small entities, the analysis uses distributional data on firm revenue for each 

industry. The analysis obtained revenue data for each of the 121 affected industries 

from the 2007 SUSB data published by the U.S. Census Bureau.148 Estimated 

revenues have been updated to 2011 dollars using GDP deflators developed by the U.S. 

Department of Commerce.149 Using the updated revenue data, the analysis then used a 

linear regression model to estimate small entity total revenue as a function of the 

number of employees. Exhibit 7-1 reports the estimated revenue for the smallest of the 

small entities, firms with one employee. Firms with one employee are used to analyze 

the impacts on small entities because they are they are the smallest of the small entities. 

Firms with more than one employee would be expected to have higher revenue and, 

therefore, smaller impacts. Based on the analysis of firms with one employee will 

overstate the economic impacts on small entities. 

• Evaluation of impacts. The analysis estimates the compliance cost under the final rule 

as a percentage of an entity’s total revenue for each type of facility (i.e., LQGs, SQGs, 

and handling facilities) in the 121 affected industries. To derive this measure, the 

analysis divides the per-facility compliance costs by the total revenue of firms with oneemployee. Exhibit 7-1 presents the resulting economic impact measures for each 

affected industry. 

As shown in Exhibit 7-1, costs of the final rule expressed as a percentage of revenue for the 

smallest of small entities (firms with only one employee), range from only 0.002 percent to 0.537 

percent.150 These results are well below the one percent screening criterion used to identify 

firms that might experience significant economic impacts. Small entities that have more than 

one employee generally will have higher revenues and smaller economic impacts compared to 

firms with one employee. Based on this screening analysis, the majority of the firms are not 

expected to face significant economic impacts as a result of the final rule; this analysis 

concludes that the final rule will not result in significant economic impacts on a substantial 

number of small entities.

Note that this analysis is likely to overstate the impacts of the final rule on small entities in the 

following ways: (1) use of average per-facility costs for an industry will overstate costs for most 

small firms which are likely to have smaller operations and smaller costs than large firms; 

(2) use of first-year costs (which include one-time costs as well as annual costs) will overstate 

costs and impacts in subsequent years); (3) the analysis is sensitive to the smallest of the small 

 148 U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six-Digit NAICS 

Code. Available at: http://www.census.gov/econ/susb/data/susb2007.html, last accessed on December 6, 2011.

149 U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for 

Gross Domestic Product.” Available online at: 

http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, 

last accessed on November 6, 2011. Year 2007, Quarter IV = 106.958 and Year 2011, Quarter III = 113.823. 

150 The analysis only considers entities that will incur costs as a result of the final rule. For those entities that 

will benefit from the final rule in the form of cost savings, they were not factored into the analysis to assess the 

economic impact on small entities. 
97

entities (i.e., one-employee firms), given that many or most affected small entities will have 

more employees and thus, the higher levels of revenue needed to support more employees. 

7.2. Executive Order 12630: Regulatory Takings Analysis

The final rule does not constitute a regulatory taking because it is not expected to result in the 

physical invasion of property and should not negatively impact the economic viability of 

property.

7.3. Executive Order 12988: Civil Justice Reform

The final rule specifies in clear language the effect of the regulation; specifies its relationship to 

the provisions of other laws; incorporates clear legal standards; has no retroactive effect; and 

defines key terms. Therefore, no additional analysis or actions are required under Executive 

Order 12988.

7.4. Executive Order 12898: Federal Actions to Address Environmental Justice 

in Minority Populations and Low-Income Populations

Executive Order 12898 (59 FR 7629; 60 FR 6381), “Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations,” requires Federal agencies to 

“make achieving environmental justice part of its mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or environmental effects of its 

programs, policies, and activities on minority populations and low-income populations...” 

In response to Executive Order 12898, EPA developed an environmental justice (EJ) 

strategy.151 The purpose of the strategy is to ensure the integration of EJ into EPA’s programs, 

policies, and activities consistent with the Executive Order. As stated in the strategy, EPA’s 

goals are to ensure that no segment of the population, regardless of race, color, national origin, 

or income suffers disproportionately from adverse human health or environmental effects as a 

result of EPA’s policies, programs, and activities; and that all people live in clean, healthy, and 

sustainable communities.

The methodology for evaluating the potential for disproportionate adverse impacts to minority 

and low-income populations as a result of a rulemaking consists of two parts. First, the Agency 

evaluates the potential for adverse impacts to any populations as a result of a rulemaking. 

Second, if there is a potential for adverse impacts, then EPA evaluates whether those impacts 

would disproportionately affect minority and/or low-income populations.

In evaluating the potential impacts of the solvent-contaminated wipes final rule, EPA has 

determined that there are no potential adverse impacts to any populations. Therefore further 

analysis is not required because there would also be no potential adverse impacts to minority or 

low-income populations.

 151 U.S. Environmental Protection Agency. The EPA's Environmental Justice Strategy. April 3, 1995. 

Available at: http://www.epa.gov/environmentaljustice/resources/policy/ej_strategy_1995.pdf, last accessed on 

December 9, 2011. 
98

Potential for Adverse Impacts 

Hazardous waste solvents can pose a potential hazard to human health and the environment. 

When EPA listed the F001-F005 spent solvents, as well as the corresponding P- or U-listed 

solvents as hazardous waste, the Agency determined that they pose significant risk to human 

health and the environment due to their toxicity, and/or ignitability.

However, EPA does not anticipate that solvent-contaminated wipes subject to the final rule will 

adversely impact human health and the environment for several reasons. First, the solventcontaminated wipes (whether sent for disposal or recycling) must contain "no free liquids" (using 

the Paint Filter Liquids Test, or other similar tests as required by the states) prior to be 

transported off-site. Additionally, the container the solvent-contaminated wipes are transported 

in also must not contain free liquid prior to transport off-site. Thus, the amount of actual solvent 

that is transported, whether for disposal or recycling/reuse, will be minimal and reduce the 

hazards from releases of “free liquids,” fugitive air emissions, fires, and explosions. (Note: Free 

liquids that are removed the solvent-contaminated wipes or containers that hold the solventcontaminated wipes must be managed in accordance with the applicable hazardous waste 

regulations found in 40 CFR parts 260 through 273.) Next, for solvent-contaminated wipes 

disposed in a landfill, they must be sent to a landfill that is subject to the standards under 40 

CFR Part 258, including 40 CFR 258.40 (i.e., a municipal solid waste landfill). (In developing 

these standards, the Agency recognized that hazardous wastes from CESQGs would also being 

sent to such landfills, and thus, the specific standards reflect the acceptance of such hazardous 

wastes.) The design criteria at 40 CFR 258.40 include requirements that landfills be lined, or 

that they have an approved design that is protective of the uppermost aquifer. The risk analysis 

conducted for this final rule also demonstrates that there is no significant risk to human health 

and the environmental from groundwater contamination from eligible solvent-contaminated 

wipes disposed in these landfills under the final rule.152 Similarly, solvents that are sent for 

burning must go a combustor regulated under section 129 of the Clean Air Act or operating 

under 40 CFR 264 or 265, which address potential risks from air emissions. Finally, solventcontaminated wipes intended for laundering or dry cleaning must go to an industrial laundry or a 

dry cleaner whose discharges, if any, are regulated under sections 402 and section 307(b) of 

the Clean Water Act, to address potential risks to surface waters.

Furthermore, EPA anticipates that additional conditions of the final rule will help reduce adverse 

human health and environmental effects that sometimes result from the mismanagement of 

solvent-contaminated wipes:

• Wipes must be stored in non‐leaking, closed containers. This condition ensures that the 

wipes are contained and are not exposed to the environment (and potential ignition 

sources).

• Wipes must be labeled "Exempt Solvent‐Contaminated Wipes." This condition ensures 

that the generator, transporter, and handler are aware of the contents of the containers 

and can handle them appropriately.

Finally, EPA anticipates that the final rule will not adversely affect transportation risk. In the 

case of disposable wipes, they will need to be transported to municipal solid waste landfills or 

 152 Solvent-contaminated wipes risk analysis documents are available from www.regulations.gov in docket 

under Docket ID No. EPA-HQ- RCRA-2003-0004. 
99

solid waste combustion units under the rule instead of hazardous waste facilities. Municipal 

solid waste landfills and solid waste combustion units are expected to be closer to generators of 

solvent-contaminated wipes because they are more numerous. Because solvent-contaminated 

wipes are expected to be transported over shorter distances under the rule, overall hazards 

associated with transportation are expected to decrease as the total vehicle miles traveled for 

trucks carrying the solvent-contaminated wipes decreases

In addition, EPA anticipates that fewer trips will be needed to transport solvent-contaminated 

wipes under the rule. When disposed of as hazardous waste, solvent-contaminated wipes 

would likely be transported within 90 days of generation by large quantity generators, and 180 

days by small quantity generators, and then must be transported by a licensed hazardous waste 

transporter, which may require special trips at less than truckload capacity. When disposed of 

as municipal solid waste, the disposable wipes are likely to present only an incremental addition 

to the total amount of municipal solid waste disposed, and not present a need for special or 

additional trips, reducing the total number of truck trips and vehicle miles travelled and not 

affecting the overall impact of the well established solid waste hauler routes.

Conclusion

Based on the above information, EPA believes that there will be no adverse impacts to human 

health and the environment as a result of the final rule, and that in most cases, hazards 

associated with solvent-contaminated wipes will be reduced for all population. Therefore, EPA 

there would not be disproportionately high and adverse human health or environmental impacts 

on minority populations and low-income populations from the final rule.

7.5. Executive Order 13045: Protection of Children from Environmental Health 

Risks and Safety Risks 

Executive Order 13045 (62 FR 19885; 68 FR 19931), “Protection of Children from 

Environmental Health Risks and Safety Risks,” applies to any rule that: (1) is determined to be 

‘‘economically significant’’ as defined under Executive Order 12866 (Regulatory Planning and 

Review), and (2) concerns an environmental health risk or safety risk that an agency has reason 

to believe may disproportionately affect children. If the regulatory action meets both criteria, the 

agency must evaluate the environmental health or safety effects of the planned regulation on 

children, and explain why the planned regulation is preferable to other potentially effective and 

reasonably feasible alternatives considered by the agency.

The final rule is not subject to Executive Order 13045 because it is not an economically 

significant regulatory action as defined in Executive Order 12866, and because EPA does not 

have reason to believe the environmental health risks or safety risks addressed by the final rule

present a disproportionate risk to children. As discussed in Section 7.2, this final rule applies to 

industrial launderers, and generators and handlers of solvent-contaminated wipes. Therefore, it

is not expected to increase exposure of solvents to the general public (i.e., adults or children).

7.6. Unfunded Mandate Reform Act (UMRA)

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), Pub. L. 104–4, establishes 

requirements for Federal agencies to assess the effects of their regulatory actions on state, 

local, and tribal governments, and the private sector. Under Section 202 of the UMRA, Federal 

agencies must prepare a written statement for proposed and final rules that include any 
100

“Federal mandate” that may result in expenditures by state, local, and tribal governments, in the 

aggregate, or by the private sector, of $100 million or more in any one year. 

Before a Federal regulatory agency promulgates a rule for which a written statement is needed, 

Section 205 of the UMRA requires the Federal agency to identify and consider a reasonable 

number of regulatory alternatives and, from those alternatives, adopt the least costly, most costeffective, or least burdensome alternative that achieves the objectives of the rule. The

provisions of Section 205 do not apply when they are inconsistent with applicable law. 

Moreover, Section 205 allows the Federal agency to adopt an alternative other than the least 

costly, most cost-effective, or least burdensome alternative if the head of the agency publishes 

with the final rule an explanation of why that alternative was not adopted. 

Before establishing any regulatory requirements that might significantly or uniquely affect small 

governments, Federal agencies must have developed, under Section 203 of the UMRA, a small

government agency plan. The plan must provide for notifying potentially affected small 

governments; enabling officials of affected small governments to provide meaningful and timely 

input in the development of regulatory proposals containing significant Federal

intergovernmental mandates; and informing, educating, and advising small governments on 

compliance with the regulatory requirements.

Under the final rule, EPA is modifying its hazardous waste management regulations under 

RCRA to: (1) conditionally exclude from the definition of solid waste solvent-contaminated 

reusable wipes and (2) conditionally exclude from the definition of hazardous waste solventcontaminated disposable wipes. The conditional exclusions are considered less stringent than 

the current Federal regulations because they exclude certain materials now regulated by RCRA 

subtitle C. Thus, authorized states are not required to adopt the final rule, provided their 

program is at least as stringent as the Federal program. In addition, even if the final rule is 

adopted by their state, generators of solvent-contaminated wipes may opt to continue to 

manage solvent-contaminated wipes under current Federal hazardous waste regulations rather 

than under the conditional exclusions. Therefore, the final rule does not contain Federal 

mandates (under the provisions of Title II of the UMRA) for state, local, or tribal governments, or 

the private sector. 

In addition, EPA has determined that the final rule contains no regulatory requirements that 

might significantly or uniquely affect small governments. Furthermore, as analyzed in Chapter 6 

of this document, the final rule will not result in expenditures by state, local, and tribal 

governments, in the aggregate, or by the private sector, of $100 million or more in any one year. 

Based on the information above, the final rule is not subject to the requirements of Sections

202, 203, or 205 of the UMRA.
101

7.7. Executive Order 13132: Federalism

Executive Order 13132 (64 FR 43255), “Federalism,” requires Federal agencies to develop an

accountable process to ensure ‘‘meaningful and timely input by state and local officials in the 

development of regulatory policies that have federalism implications.’’ ‘‘Policies that have

federalism implications’’ is defined in the Executive Order to include regulations that have 

‘‘substantial direct effects on the states, on the relationship between the national government 

and the states, or on the distribution of power and responsibilities among the various levels of 

government.’’

Executive Order 13132 instructs Federal agencies to take national action limiting the 

policymaking discretion of the states “only when there is constitutional and statutory authority for 

the action and the national activity is appropriate in light of the presence of a problem of national 

significance.” With respect to preemption, Federal agencies should “construe a Federal statute 

to preempt state law only where the statute contains an express preemption provision or there is 

some other clear evidence that Congress intended preemption of state law, or where the 

exercise of state authority conflicts with the exercise of Federal authority under the Federal 

statute.” “Any regulatory preemption of state law must be restricted to the minimum level 

necessary to achieve the objectives of the statute pursuant to which the regulations are 

promulgated.”

The Resource Conservation and Recovery Act (RCRA, 42 U.S.C. 6901 to 6992k) establishes

the relationship between states and the national government with respect to hazardous waste 

management, including provisions for authorized state hazardous waste programs (42 U.S.C.

6926, Section 3006) and retention of state authority (42 U.S.C. 6929, Section 3009). Under 

Section 3009 of RCRA, states and their political subdivisions may not impose requirements less

stringent for hazardous waste management than the national government. Therefore, although 

the final rule prevents state and local laws that are less stringent with respect to management of

solvent-contaminated wipes, the final rule does not have federalism implications beyond those 

already established by RCRA. It will not have substantial direct effects on the states, on the 

relationship between the national government and the states, or on the distribution of power and

responsibilities among the various levels of government, as specified in Executive Order 13132. 

7.8. Executive Order 13175: Consultation and Coordination with Indian Tribal 

Governments

Executive Order 13175 (65 FR 67249), “Consultation and Coordination with Indian Tribal 

Governments,” requires Federal agencies to develop an accountable process to ensure 

“meaningful and timely input by tribal officials in the development of regulatory policies that have 

tribal implications.” “Policies that have tribal implications” is defined in the Executive Order to 

include regulations that have “substantial direct effects on one or more Indian tribes, on the

relationship between the Federal Government and Indian tribes, or on the distribution of power 

and responsibilities between the Federal Government and Indian tribes.”

EPA has concluded that this action may have tribal implications to the extent that generating 

facilities on tribal lands use solvents on wipes or handling facilities located on tribal lands may 

receive solvent-contaminated wipes. However, it will neither impose substantial direct 

compliance costs on tribal governments, nor preempt Tribal law. 
102

7.9. Executive Order 13211: Actions That Significantly Affect Energy Supply, 

Distribution, or Use

Executive Order 13211 (66 FR 28355), “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use,” requires federal agencies to prepare a “Statement of 

Energy Effects” when undertaking certain regulatory actions. A Statement of Energy Effects 

describes the adverse effects of a “significant energy action” on energy supply, distribution and 

use, reasonable alternatives to the action, and the expected effects of the alternatives on 

energy supply, distribution and use. A significant energy action is an action that “promulgates or 

is expected to lead to the promulgation of a final rule or regulation” (and normally published in 

the Federal Register), including notices of inquiry, advance notices of proposed rulemaking, and 

notices of proposed rulemaking, and that is: 1) a significant regulatory action under Executive 

Order 12866 (or successor order) that is likely to have a significant adverse effect on the supply, 

distribution, or use of energy (see next section for determining “significant adverse energy 

effect”); or 2) is designated by the Administrator of the Office of Information and Regulatory 

Affairs as a significant energy action.

This action is not a “significant energy action” as defined in Executive Order 13211 (66 FR 

28355 (May 22, 2001)), because it is not likely to have a significant adverse effect on the 

supply, distribution, or use of energy. This final rule reduces net regulatory burden and may 

possibly induce fuel efficiency and energy savings from the voluntary shifting of solventcontaminated wipes from more distantly located RCRA permitted hazardous waste landfills and 

combustors to more closely located MSWLFs and combustors, where it is cost effective to do 

so. It therefore should not adversely affect energy supply, distribution, or use.

7.10. Executive Order 13352: Facilitation of Cooperative Conservation

Executive Order 13352 (69 FR 52989), “Facilitation of Cooperative Conservation,” requires 

specified Federal agencies, including EPA, to carry out the activities relating to the environment 

and natural resources in a manner that: facilitates cooperative conservation, considers interests 

of landowners and others with interest in land and other natural resources, accommodates local 

participation, and considers protection of public health and safety.

The final rule is designed to promote cooperative conservation of the environment and natural 

resources between EPA, state, and local governments by identifying clear criteria for the 

appropriate management of solvent-contaminated wipes, while maintaining protection of human 

health and the environment. 
March 16, 2012 DRAFT A-1

Appendix A

Description of North American Industry Classification System (NAICS)

Codes Associated with Industries that May Be Affected by the Final Rule

Generators of Solvent-Contaminated Wipes

Printing

323110 Commercial Lithographic Printing

323111 Commercial Gravure Printing

323112 Commercial Flexographic Printing

323113 Commercial Screen Printing

323114 Quick Printing

323115 Digital Printing

323116 Manifold Business Forms Printing

323117 Books Printing

323118 Blankbook, Looseleaf Binders, and Devices 

Manufacturing

323119 Other Commercial Printing

323121 Tradebinding and Related Work

323122 Prepress Services

Publishing (printed matter)

51111 Newspaper Publishers

51112 Periodical Publishers

51113 Book Publishers

51114 Directory and Mailing List Publishers

51119 Other Publishers

Business services (copy shops)

561439 Other Business Service Centers (including 

Copy Shops)

Chemical and Allied Products

211112 Natural Gas Liquid Extraction

32511 Petrochemical Manufacturing

32512 Industrial Gas Manufacturing

325131 Inorganic Dye and Pigment Manufacturing

325132 Synthetic Organic Dye and Pigment 

Manufacturing

325181 Alkalies and Chlorine Manufacturing

325182 Carbon Black Manufacturing

325188 All Other Basic Inorganic Chemical 

Manufacturing

325191 Gum and Wood Chemical Manufacturing

325192 Cyclic Crude and Intermediate Manufacturing

325193 Ethyl Alcohol Manufacturing

325199 All Other Basic Organic Chemical 

Manufacturing

325998 All Other Miscellaneous Chemical Product and 

Preparation Manufacturing

331311 Alumina Refining

Plastics and Rubber

31332 Fabric Coating Mills

315299 All Other Cut and Sew Apparel Manufacturing

315999 Other Apparel Accessories and Other Apparel 

Manufacturing

325991 Custom Compounding of Purchased Resins

326113 Unlaminated Plastics Film and Sheet (except 

Packaging) Manufacturing

326121 Unlaminated Plastics Profile Shape 

Manufacturing

32613 Laminated Plastics Plate, Sheet (except 

Packaging), and Shape Manufacturing

32614 Polystyrene Foam Product Manufacturing

32615 Urethane and Other Foam Product (except 

Polystyrene) Manufacturing

32616 Plastics Bottle Manufacturing

326191 Plastics Plumbing Fixture Manufacturing

326192 Resilient Floor Covering Manufacturing

326199 All Other Plastics Product Manufacturing

326211 Tire Manufacturing (except Retreading)

32622 Rubber and Plastics Hoses and Belting 

Manufacturing

326291 Rubber Product Manufacturing for Mechanical 

Use

326299 All Other Rubber Product Manufacturing

337215 Showcase, Partition, Shelving, and Locker 

Manufacturing

339113 Surgical Appliance and Supplies Manufacturing

339932 Game, Toy, and Children's Vehicle 

Manufacturing

339991 Gasket, Packing, and Sealing Device 

Manufacturing

Fabricated Metal Products

332812 Metal Coating, Engraving (except Jewelry and 

Silverware), and Allied Services to 

Manufacturers

332813 Electroplating, Plating, Polishing, Anodizing, 

and Coloring

339911 Jewelry (except Costume) Manufacturing

339912 Silverware and Hollowware Manufacturing

339914 Costume Jewelry and Novelty Manufacturing

Industrial Machinery and Equipment

314999 All Other Miscellaneous Textile Product Mills

332323 Ornamental and Architectural Metal Work 

Manufacturing

33241 Power Boiler and Heat Exchanger 

Manufacturing

332991 Ball and Roller Bearing Manufacturing

333111 Farm Machinery and Equipment Manufacturing

33312 Construction Machinery Manufacturing

33322 Plastics and Rubber Industry Machinery 

Manufacturing

333295 Semiconductor Machinery Manufacturing

333298 All Other Industrial Machinery Manufacturing

333319 Other Commercial and Service Industry 

Machinery Manufacturing

333414 Heating Equipment (except Warm Air Furnaces) 

Manufacturing

333511 Industrial Mold Manufacturing

333512 Machine Tool (Metal Cutting Types) 

Manufacturing

333513 Machine Tool (Metal Forming Types) 

Manufacturing

333514 Special Die and Tool, Die Set, Jig, and Fixture 

Manufacturing

333515 Cutting Tool and Machine Tool Accessory 

Manufacturing

333518 Other Metalworking Machinery Manufacturing

333911 Pump and Pumping Equipment Manufacturing

333923 Overhead Traveling Crane, Hoist, and Monorail 

System Manufacturing

333999 All Other Miscellaneous General Purpose 

Machinery Manufacturing

33651 Railroad Rolling Stock Manufacturing
Appendix A (continued)

Description of North American Industry Classification System (NAICS)

Codes Associated with Industries that May Be Affected by the Final Rule

March 16, 2012 DRAFT C-2

Furniture and Fixtures

337110 Wood Kitchen Cabinet and Countertop 

Manufacturing

337121 Upholstered Household Furniture Manufacturing

337122 Nonupholstered Wood Household Furniture 

Manufacturing

337124 Metal Household Furniture Manufacturing

337127 Institutional Furniture Manufacturing

337211 Wood Office Furniture Manufacturing

337212 Custom Architectural Woodwork and Millwork 

Manufacturing

337215 Showcase, Partition, Shelving, and Locker 

Manufacturing

Auto Dealers (retail trade)

44111 New Car Dealers

44112 Used Car Dealers

Military Bases

92812 International Affairs

Electronics and Computers

334411 Electron Tube Manufacturing

334412 Bare Printed Circuit Board Manufacturing

334413 Semiconductor and Related Device 

Manufacturing

Transportation Equipment

332912 Fluid Power Valve and Hose Fitting 

Manufacturing

336111 Automobile Manufacturing

336112 Light Truck and Utility Vehicle Manufacturing

336211 Motor Vehicle Body Manufacturing

336312 Gasoline Engine and Engine Parts 

Manufacturing

33633 Motor Vehicle Steering and Suspension 

Components (except Spring) Manufacturing

33634 Motor Vehicle Brake System Manufacturing

336399 All Other Motor Vehicle Parts Manufacturing

336411 Aircraft Manufacturing

336412 Aircraft Engine and Engine Parts Manufacturing

336414 Guided Missile and Space Vehicle 

Manufacturing

336415 Guided Missile and Space Vehicle Propulsion 

Unit and Propulsion Unit Parts Manufacturing

336419 Other Guided Missile and Space Vehicle Parts 

and Auxiliary Equipment Manufacturing

336612 Boat Building

336992 Military Armored Vehicle, Tank, and Tank 

Component Manufacturing

48839 Other Support Activities for Water 

Transportation

54171 Research and Development in the Physical, 

Engineering, and Life Sciences

81149 Other Personal and Household Goods Repair 

and Maintenance

Auto Repair and Maintenance

811111 General Automotive Repair

811112 Automotive Exhaust System Repair

Handlers of Solvent-Contaminated Wipes

Solid Waste Management – Hazardous Wastes

562112 Hazardous Waste Collection

562211 Hazardous Waste Treatment and Disposal

Solid Waste Management – Non Hazardous Wastes

562111 Solid Waste Collection

562212 Solid Waste Landfill

562213 Solid Waste Combustors and Incinerators

562219 Other Nonhazardous Waste Treatment and 

Disposal

56292 Materials Recovery Facilities

Linen Supply and Laundering

812332 Industrial Launderers
March 16, 2012 DRAFT B-1

Appendix B

Information on State Waste Fees and Taxes

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Alabama 78,668 8,973 $71.60 $0.00 $0.00 $1.00 $0.00

(1) Alabama Department of Revenue. "Frequently Asked Questions" Web Site, "Hazardous 

Waste Fees" and "Solid Waste Disposal Fees." Available at: 

http://www.ador.state.al.us/tobaccotax/faqtt.html#waste, last accessed on November 15, 2011. 

Average of disposal fees for hazardous waste, P-listed wastes, and U-listed wastes at 

management facilities other than the Emelle, Alabama facility.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Alaska 202 229 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Arizona 29,280 4,115 $40.00 $0.00 $10.00 $0.00 $0.00

(1) Arizona Department of Environmental Quality. "Draft Hazardous Waste Fees as authorized 

by HB 2705." Available at: http://www.azdeq.gov/environ/waste/download/061411dhwf.pdf , 

last accessed on November 15, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Arkansas 49,425 4,711 $11.00 $3,000.00 $0.00 $0.00 $0.00

(1) Arkansas Pollution Control and Ecology Commission. Regulation No. 23 - Hazardous Waste 

Management, Section 6 - Fees and Costs. Available at: 

http://www.adeq.state.ar.us/regs/files/reg23_final_110926.pdf, last accessed on November 15, 

2011. Fee on generation of hazardous waste based on Category 2, 30,000 pounds to 99,999 

pounds (i.e., 15 tons to 49.99 tons).

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p.169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-2

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

California 100,112 52,131 $49.95 $5.58 $0.00 $20.16 $5.58

(1) California Department of Toxic Substances Control. "Department of Toxic Substances 

Control Fee Summary - Effective January, 2011;" "TABLE 3: Land Disposal Fees for CY 2011" 

and "TABLE 10: Generator Fee CY 2011." Available at: 

http://www.dtsc.ca.gov/IDManifest/2011_Fee_Summary.cfm#c, last accessed November 15, 

2011. Generation fee based on generator size "0 but less than 250 tons/year."

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Colorado 5,186 10,978 $9.92 $7.09 $0.00 $5.25 $7.09

Colorado Department of Public Health and Environment. "Solid and Hazardous Waste 

Commission Regulations 6 CCR 1007-3," "Part 100 - Permit Regulations" and "Part 262 -

Standards Applicable to Generators of HW." Available at: 

http://www.cdphe.state.co.us/regulations/hazwaste/, last accessed on November 15, 2011. 

Annual generation fee based on LQG fee.

Connecticut 3,048 4,214 $15.00 $15.00 $9.60 $0.50 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Delaware 746 2,624 $21.00 $4.00 $0.00 $0.00 $0.00

(1) State of Delaware. "Delaware Online Code" Web site, "Delaware Code of Regulations," 

TITLE 7 - Conservation, Natural Resources," "Chapter 63 - Hazardous Waste Management," " 

Subchapter II - Miscellaneous Provisions," "Section 6319(f)." Available at: 

http://delcode.delaware.gov/title7/c063/sc02/index.shtml, last accessed on November 15, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

District of

Columbia 416 7 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-3

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Florida 4,367 4,616 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Georgia 15,135 22,500 $23.00 $23.00 $0.00 $0.00 $0.00

(1) Georgia Department of Natural Resources. Guidelines for Calculating Hazardous Waste 

Management Fees and Hazardous Substance Reporting Fees, "Section 2.3.2 - Large Quantity 

Generators (LQG); Calculation of the Hazardous Waste Management Fees." Available at: 

http://www.georgiaepd.org/Files_PDF/forms/hwb/fee_guide.pdf, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Hawaii 48 166 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Idaho 6,825 1,545 $30.00 $30.00 $0.00 $0.00 $0.00

(1) State of Idaho. Idaho Code of Regulations, "Title 39 - Health and Safety, " "Chapter 44 -

Hazardous Waste Management, " "Section 39-4427 - Commercial Disposal Fees." Available at: 

http://www.legislature.idaho.gov/idstat/Title39/T39CH44SECT39-4427.htm, last accessed on 

November 15, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Illinois 40,444 15,791 $61.00 $20.00 $0.00 $0.95 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-4

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Indiana 196,654 24,710 $11.50 $11.50 $0.00 $0.00 $0.00

(1) State of Indiana. "Information Maintained by the Office of Code Revision Indiana Legislative 

Services Agency" Web site, "IC 13-22-12-2, Fee Schedule; Application Fees." Available at: 

http://www.state.in.us/legislative/ic/code/title13/ar22/ch12.html, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Iowa 30,937 6,961 $40.00 $0.00 $50.00 $0.00 $0.00

(1) Iowa Department of Natural Resources. "Iowa Department of Natural Resources Hazardous 

Waste Activities Form." Available at: 

http://www.iowadnr.gov/portals/idnr/uploads/consites/hwfeeform.pdf?amp;tabid=698, last 

accessed on November 15, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Kansas 5,839 4,006 $10.00 $20.00 $0.00 $0.00 $0.00

(1) Kansas Department of Health and Environment, Bureau of Waste Management. "Hazardous 

Waste Fees." http://www.kdheks.gov/waste/p_hwfees.html, last accessed on November 15, 

2011. Based on generator fee for "greater than 50 tons but less than or equal to 500 tons" 

category.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Kentucky 3,525 13,921 $24.10 $12.05 $10.50 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Louisiana 30,357 19,032 $85.00 $0.00 $0.00 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Maine 914 188 $40.00 $30.00 $0.00 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-5

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Maryland 17,231 6,082 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Massachusetts 2,233 4,723 $0.00 $0.00 $0.00 $0.00 $0.00

(1) Massachusetts Department of Environmental Protection. "Service Center" Web site, "Fees, 

Billing & Timelines ," Annual Compliance Fees." Available at: 

http://www.mass.gov/dep/service/acfees.pdf, last accessed on November 15, 2011. Hazardous 

waste generation fee based on LQG fee.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Michigan 15,544 20,414 $10.00 $10.00 $0.00 $0.00 $0.00

(1) Michigan Department of Environmental Quality. "Hazardous Waste User Charges and 

Invoice Packets." Available at: http://www.michigan.gov/deq/0,4561,7-135-3312_4118_4240-

47207--,00.html, last accessed on November 16, 2011. Hazardous waste generation fee based 

on LQG fee. 

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Minnesota 7,489 9,725 $77.11 $19.28 $0.00 $0.45 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Mississippi 3,495 17,894 $10.00 $2.00 $0.00 $1.00 $1.00

(1) State of Mississippi. "Mississippi Code of 1972," "Section 49-31-25 - Pollution Prevention 

Fee; Penalty for Failure to Pay." Available at: 

http://www.mscode.com/free/statutes/49/031/0025.htm, last accessed on November 16, 2011. 

Hazardous waste generation fee based on "100.00 to 999.99 tons" generated/released 

category. 

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-6

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Missouri 9,040 18,056 $25.50 $2.00 $5.00 $0.00 $0.00

(1) State of Missouri. Missouri Revised Statutes, "Chapter 260 - Environmental Control," 

"Section 260.475 - Fees to be Paid by Hazardous Waste Generators--Exceptions--Deposit of 

Moneys--Violations, Penalty--Deposit--Fee Requirement, Expiration." Available at: 

http://www.moga.mo.gov/statutes/C200-299/2600000475.HTM, last accessed on November 16, 

2011.

(2) State of Missouri. Missouri Revised Statutes, "Chapter 260 - Environmental Control," 

"Section 260.390 - Duties of Hazardous Waste Facility Owners and Operators--Tax to be 

Collected, Disposition--Duties upon Termination of Use of Facility--Inspection Fees, Commercial 

Facilities, Requirements." Available at: http://www.moga.mo.gov/statutes/C200-

299/2600000390.HTM, last accessed on November 16, 2011.

(3) State of Missouri. Missouri Revised Statutes, "Chapter 260 - Environmental Control," 

"Section 260.380 - Duties of Hazardous Waste Generators--Fees to be Collected, Disposition--

Exemptions." Available at: http://www.moga.mo.gov/statutes/C200-299/2600000380.HTM, last 

accessed on November 16, 2011.

(4) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Montana 6,434 662 $8.00 $8.00 $15.00 $0.00 $0.00 Montana Department of Environmental Quality, "Hazardous Waste Program" Web site. 

Available at: http://deq.mt.gov/HazWaste/default.mcpx, last accessed on November 16, 2011.

Nebraska 37,345 1,220 $22.40 $1.92 $0.00 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Nevada 7,549 726 $40.20 $17.75 $0.00 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

New Hampshire 22 95 60 60 $0.00 $1.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

New Jersey 397,378 13,958 $0.00 $0.00 $0.00 $0.00 $0.00

(1) State of New Jersey. "Hazardous Waste Regulations, N.J.A.C. 7:26G-1 et seq," 

"Subchapter 3 - Hazardous Waste Fees, "Section 7:26G-3.3 - Fee Schedule for Hazardous 

Waste Facilities, Generators, and Transporters." Available at: 

http://www.state.nj.us/dep/dshw/resource/hazreg03.pdf, last accessed on November 16, 2011. 

Hazardous waste generation fee based on "Equal to or greater than 150 tons of hazardous 

waste generated" category.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-7

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

New Mexico 838 1,055 $0.00 $0.00 $0.00 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

New York 41,665 14,444 $27.00 $9.00 $0.00 $0.00 $0.00

(1) New York State Department of Environmental Conservation. "Hazardous Waste 

Assessments and Fees" Web site. Available at: http://www.dec.ny.gov/chemical/9099.html, last 

accessed on November 16, 2011.

(2) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(3) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

North Carolina 26,886 26,015 $2.45 $2.45 $0.70 $0.00 $0.00

(1) North Carolina Department of Environment and Natural Resources. "Hazardous Waste 

Section" Web site, "Hazardous Waste 2010 Fee Increase." Available at: 

http://portal.ncdenr.org/web/wm/hw, last accessed on November 16, 2011. Hazardous waste 

generation fee based on LQG.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

North Dakota 0 229 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Ohio 63,341 38,785 $9.00 $2.00 $0.00 $0.00 $0.00

(1) State of Ohio. Ohio Revised Code, "Title [37] XXXVII - Health - Safety - Morals," "Chapter 

3734 - Solid and Hazardous Wastes," "Section 3734.18 - Fees - Hazardous Waste Facility 

Management Fund." Available at: http://codes.ohio.gov/orc/3734.18, last accessed on 

November 16, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-8

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Oklahoma 9,075 1,815 $9.00 $9.00 $0.00 $0.00 $0.00

(1) State of Oklahoma. Oklahoma Administrative Code, "Title 252 - Department of 

Environmental Quality," "Chapter 205 - Hazardous Waste Management," "Section 252:205-21-2 

- Generator Fees." Available at: http://www.deq.state.ok.us/rules/205.pdf, last accessed on 

November 16, 2011.

(2) State of Oklahoma. Oklahoma Administrative Code, "Title 252 - Department of 

Environmental Quality," "Chapter 205 - Hazardous Waste Management," "Section 252:205-21-4 

- Treatment, Storage, Off-Site Recycling, and Disposal Facility Fees." Available at: 

http://www.deq.state.ok.us/rules/205.pdf, last accessed on November 16, 2011.

(3) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Oregon 48,983 4,014 $176.90 $117.94 $0.00 $0.00 $0.00

(1) State of Oregon Department of Environmental Quality. "Hazardous Waste Generator Fee 

Information" Fact Sheet. Available at: 

http://www.deq.state.or.us/lq/pubs/factsheets/hw/HWGeneratorFee.pdf, last accessed on 

November 16, 2011. Hazardous waste generation fee based on LQG.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Pennsylvania 46,439 14,465 $12.00 $5.00 $0.00 $3.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Rhode Island 57 1,455 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-9

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

South Carolina 8,397 5,337 $34.00 $10.00 $0.00 $13.70 $10.00

(1) South Carolina Department of Health and Environmental Control, Land and Waste 

Management. "Laws & Regulations" Web site, "South Carolina Hazardous Waste Management 

Regulations R.61-79," "Section 264.78 - Hazardous Waste Contingency Fund Fees." Available 

at: http://www.scdhec.gov/environment/lwm/regs/264%2010.pdf, last accessed on November 

16, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

South Dakota 6 262 $50.00 $50.00 $0.00 $0.00 $0.00

(1) State of South Dakota. South Dakota Codified Laws, "Title 34A - Environmental Protection," 

"Chapter 34A-11 - Hazardous Waste Management," "Section 34A-11-25 - Disposal Fee Levied 

by State--Records." Available at: 

http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=34A-11-25, last 

accessed on November 16, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Tennessee 5,015 5,175 $5.00 $2.50 $0.00 $0.00 $0.00

(1) State of Tennessee. "Rules of the Tennessee Department of Environment and 

Conservation, Division of Solid/Hazardous Waste Management," "Chapter 1200-01-11 -

Hazardous Waste Management Regulations," "Section 1200-1-11-.08 - Fee System for 

Transporters, Storers, Treaters, Disposers, and Certain Generators of Hazardous Wastes and 

for Certain Used Oil Facilities or Transporters." Available at: 

http://www.state.tn.us/sos/rules/1200/1200-01/1200-01-11/1200-01-11-.08.pdf, last accessed on 

November 16, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Texas 84,904 104,074 $30.00 $16.00 $2.00 $6.00 $3.20

Texas Natural Resource Conservation Commission. Texas Commission on Environmental 

Quality Rules and Regulations, "Chapter 335 - Industrial Solid Waste and Municipal Hazardous 

Waste," "Subchapter J - Hazardous Waste Generation, Facility and Disposal Fee System." 

Available at: http://www.tceq.state.tx.us/assets/public/legal/rules/rules/pdflib/335j.pdf, last 

accessed on November 16, 2011.

Utah 80,701 6,401 $14.00 $9.00 $0.00 $0.00 $2.50

(1) State of Utah. "Hazardous Waste and Nonhazardous Solid Waste Fee and Tax 

Amendments," 2004 General Session." Available at: 

http://www.le.state.ut.us/~2004/bills/hbillint/hb0013.htm, last accessed on November 16, 2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 170.
Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C-10

State

Hazardous Waste

Management

State Hazardous Waste

Fees and Taxes

State Non-Hazardous Waste

Fees and Taxes

Data Source(s)

Management Generation Management

Tons

Managed in

Landfill

Tons

Managed in

Incinerator

Disposal

($/ton)

Incineration

($/ton) ($/ton) Disposal($/ton)

Incineration

($/ton)

Vermont 364 109 $112.00 $56.00 $0.00 $6.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 170.

Virginia 7,868 9,769 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 170.

Washington 20,175 5,607 $0.00 $0.00 $12.00 $8.03 $8.03

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 170.

West Virginia 1,718 5,796 $35.29 $26.47 $0.00 $0.00 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 170.

Wisconsin 11,958 11,912 $0.15 $0.15 $12.83 $0.30 $0.00

U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 170.

Wyoming 2,044 1,517 $0.00 $0.00 $0.00 $0.00 $0.00

(1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information - TSDF. Report on 

Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 

2006 Update, "Section 13 - State Taxes and Fees." Available at: 

http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15, 

2011.

(2) U.S. Environmental Protection Agency. Economics Background Document - Estimate of 

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA 

Hazardous Waste Regulation. July 17, 2003. p. 169.

Tons-Weighted Mean Fee/Tax Rate

($/ton) $25.00 $35.00 $1.18 $1.98 $1.51
March 16, 2012 DRAFT C-1

Appendix C

Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry a

Economic 

Sub-Sector

Industries

(5- or 6-

Digit

NAICS 

Code) a

LQGs SQGs Total Percent of All 

Facilities that 

Are LQGs 

Reusable 

Wipes c

Percent of All 

Facilities that 

Are SQGs 

Reusable 

Wipes d

Percent of All 

Facilities that 

Are LQGs 

Disposable 

Wipes e

Percent of All 

Facilities that 

Are SQGs 

Disposable 

Wipes f

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Total

Printing

323110 11 1 12 5,654 492 6,146 5,665 493 6,158 0.18% 91.82% 0.02% 7.98%

323111 9 1 10 135 12 147 144 13 156 5.74% 86.26% 0.50% 7.50%

323112 5 0 5 422 37 459 427 37 464 1.04% 90.96% 0.09% 7.91%

323113 1 0 1 2,189 190 2,379 2,190 190 2,380 0.03% 91.97% 0.00% 8.00%

323114 0 0 0 3,209 279 3,488 3,209 279 3,488 0.00% 92.00% 0.00% 8.00%

323115 0 0 0 876 76 952 876 76 952 0.00% 92.00% 0.00% 8.00%

323116 0 0 0 292 25 318 292 25 318 0.00% 92.00% 0.00% 8.00%

323117 0 0 0 251 22 272 251 22 272 0.00% 92.00% 0.00% 8.00%

323118 0 0 0 95 8 103 95 8 103 0.00% 92.00% 0.00% 8.00%

323119 1 0 2 1,042 91 1,133 1,043 91 1,134 0.12% 91.88% 0.01% 7.99%

323121 0 0 0 480 42 522 480 42 522 0.00% 92.00% 0.00% 8.00%

323122 2 0 2 712 62 774 714 62 776 0.27% 91.73% 0.02% 7.98%

Publishing 

(printed 

matter)

51111 0 0 0 4,003 348 4,351 4,003 348 4,351 0.00% 92.00% 0.00% 8.00%

51112 0 0 0 3,638 316 3,954 3,638 316 3,954 0.00% 92.00% 0.00% 8.00%

51113 0 0 0 1,535 134 1,669 1,535 134 1,669 0.00% 92.00% 0.00% 8.00%

51114 0 0 0 855 74 929 855 74 929 0.00% 92.00% 0.00% 8.00%

51119 1 0 1 639 56 695 640 56 695 0.10% 91.90% 0.01% 7.99%

Business 

services

(copy shops)

561439 1 0 2 2,632 229 2,861 2,633 229 2,862 0.05% 91.95% 0.00% 8.00%
Appendix C (continued)

Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry a

March 16, 2012 DRAFT C-2

Economic 

Sub-Sector

Industries

(5- or 6-

Digit

NAICS 

Code) a

LQGs SQGs Total Percent of All 

Facilities that 

Are LQGs 

Reusable 

Wipes c

Percent of All 

Facilities that 

Are SQGs 

Reusable 

Wipes d

Percent of All 

Facilities that 

Are LQGs 

Disposable 

Wipes e

Percent of All 

Facilities that 

Are SQGs 

Disposable 

Wipes f

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Total

Chemical and 

Allied 

Products

211112 0 0 0 45 4 49 45 4 49 0.00% 92.00% 0.00% 8.00%

32511 1 0 2 7 1 7 8 1 9 15.58% 76.42% 1.35% 6.65%

32512 1 0 2 76 7 83 78 7 84 1.63% 90.37% 0.14% 7.86%

325131 2 0 2 11 1 12 13 1 14 14.73% 77.27% 1.28% 6.72%

325132 1 0 2 14 1 15 15 1 16 8.44% 83.56% 0.73% 7.27%

325181 1 0 1 6 1 7 7 1 7 9.22% 82.78% 0.80% 7.20%

325182 0 0 0 4 0 5 4 0 5 0.00% 92.00% 0.00% 8.00%

325188 8 1 9 78 7 84 86 7 93 8.86% 83.14% 0.77% 7.23%

325191 0 0 0 7 1 8 7 1 8 0.00% 92.00% 0.00% 8.00%

325192 1 0 1 4 0 4 4 0 5 14.57% 77.43% 1.27% 6.73%

325193 0 0 0 34 3 37 34 3 37 0.00% 92.00% 0.00% 8.00%

325199 11 1 12 89 8 97 100 9 109 10.15% 81.85% 0.88% 7.12%

325998 11 1 12 164 14 178 175 15 190 5.80% 86.20% 0.50% 7.50%

331311 0 0 0 2 0 2 2 0 2 0.00% 92.00% 0.00% 8.00%
Appendix C (continued)

Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry a

March 16, 2012 DRAFT C-3

Economic 

Sub-Sector

Industries

(5- or 6-

Digit

NAICS 

Code) a

LQGs SQGs Total Percent of All 

Facilities that 

Are LQGs 

Reusable 

Wipes c

Percent of All 

Facilities that 

Are SQGs 

Reusable 

Wipes d

Percent of All 

Facilities that 

Are LQGs 

Disposable 

Wipes e

Percent of All 

Facilities that 

Are SQGs 

Disposable 

Wipes f

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Total

Plastics and 

Rubber

31332 8 1 8 20 2 22 28 2 30 25.35% 66.65% 2.20% 5.80%

315299 0 0 0 55 5 59 55 5 59 0.00% 92.00% 0.00% 8.00%

315999 0 0 0 83 7 90 83 7 90 0.00% 92.00% 0.00% 8.00%

325991 3 0 4 79 7 86 83 7 90 3.84% 88.16% 0.33% 7.67%

326113 10 1 11 89 8 97 99 9 107 9.01% 82.99% 0.78% 7.22%

326121 1 0 1 84 7 91 85 7 92 0.75% 91.25% 0.07% 7.93%

32613 8 1 9 32 3 34 40 3 43 19.09% 72.91% 1.66% 6.34%

32614 1 0 1 77 7 84 78 7 85 0.82% 91.18% 0.07% 7.93%

32615 2 0 2 89 8 97 91 8 99 2.09% 89.91% 0.18% 7.82%

32616 0 0 0 55 5 60 55 5 60 0.00% 92.00% 0.00% 8.00%

326191 1 0 2 74 6 81 75 7 82 1.68% 90.32% 0.15% 7.85%

326192 2 0 2 6 1 7 8 1 9 22.58% 69.42% 1.96% 6.04%

326199 18 3 20 991 86 1,077 1,009 89 1,097 1.62% 90.30% 0.23% 7.85%

326211 1 0 2 17 1 18 18 2 20 7.00% 85.00% 0.61% 7.39%

32622 2 0 2 34 3 37 36 3 39 5.29% 86.71% 0.46% 7.54%

326291 4 0 5 70 6 77 75 6 81 5.10% 86.90% 0.44% 7.56%

326299 8 1 8 97 8 105 104 9 114 6.69% 85.31% 0.58% 7.42%

337215 1 0 1 120 10 131 121 11 131 0.53% 91.47% 0.05% 7.95%

339113 5 0 5 271 24 294 275 24 299 1.61% 90.39% 0.14% 7.86%

339932 0 0 0 96 8 104 96 8 104 0.00% 92.00% 0.00% 8.00%

339991 1 0 1 86 8 94 87 8 95 0.73% 91.27% 0.06% 7.94%

Fabricated 

Metal 

Products

332812 37 3 40 337 29 367 374 33 406 9.00% 83.00% 0.78% 7.22%

332813 19 2 20 367 32 399 386 34 419 4.44% 87.56% 0.39% 7.61%

339911 0 0 0 246 21 268 246 21 268 0.00% 92.00% 0.00% 8.00%

339912 0 0 0 20 2 21 20 2 21 0.00% 92.00% 0.00% 8.00%

339914 0 0 0 80 7 86 80 7 86 0.00% 92.00% 0.00% 8.00%
Appendix C (continued)

Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry a

March 16, 2012 DRAFT C-4

Economic 

Sub-Sector

Industries

(5- or 6-

Digit

NAICS 

Code) a

LQGs SQGs Total Percent of All 

Facilities that 

Are LQGs 

Reusable 

Wipes c

Percent of All 

Facilities that 

Are SQGs 

Reusable 

Wipes d

Percent of All 

Facilities that 

Are LQGs 

Disposable 

Wipes e

Percent of All 

Facilities that 

Are SQGs 

Disposable 

Wipes f

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Total

Industrial 

Machinery 

and 

Equipment

314999 0 0 0 308 27 334 308 27 334 0.00% 92.00% 0.00% 8.00%

332323 1 0 2 367 32 399 368 32 400 0.34% 91.66% 0.03% 7.97%

33241 1 0 1 43 4 47 44 4 48 1.45% 90.55% 0.13% 7.87%

332991 0 0 0 26 2 28 26 2 28 0.00% 92.00% 0.00% 8.00%

333111 3 0 3 165 14 179 167 15 182 1.52% 90.48% 0.13% 7.87%

33312 3 0 4 110 10 119 113 10 123 2.81% 89.19% 0.24% 7.76%

33322 0 0 0 74 6 80 74 6 80 0.00% 92.00% 0.00% 8.00%

333295 2 0 2 29 3 32 31 3 34 6.10% 85.90% 0.53% 7.47%

333298 1 0 1 180 16 196 181 16 196 0.35% 91.65% 0.03% 7.97%

333319 1 0 1 190 17 206 191 17 207 0.33% 91.67% 0.03% 7.97%

333414 0 0 0 59 5 64 59 5 64 0.00% 92.00% 0.00% 8.00%

333511 1 0 1 282 25 307 283 25 307 0.22% 91.78% 0.02% 7.98%

333512 1 0 1 81 7 88 81 7 88 0.78% 91.22% 0.07% 7.93%

333513 0 0 0 41 4 45 41 4 45 0.00% 92.00% 0.00% 8.00%

333514 0 0 0 442 38 480 442 38 480 0.00% 92.00% 0.00% 8.00%

333515 0 0 0 215 19 234 215 19 234 0.00% 92.00% 0.00% 8.00%

333518 0 0 0 54 5 58 54 5 58 0.00% 92.00% 0.00% 8.00%

333911 3 0 3 68 6 74 71 6 77 3.59% 88.41% 0.31% 7.69%

333923 3 0 4 39 3 42 42 4 46 7.48% 84.52% 0.65% 7.35%

333999 2 0 2 232 20 252 234 20 254 0.81% 91.19% 0.07% 7.93%

33651 1 0 1 30 3 33 31 3 34 2.04% 89.96% 0.18% 7.82%
Appendix C (continued)

Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry a

March 16, 2012 DRAFT C-5

Economic 

Sub-Sector

Industries

(5- or 6-

Digit

NAICS 

Code) a

LQGs SQGs Total Percent of All 

Facilities that 

Are LQGs 

Reusable 

Wipes c

Percent of All 

Facilities that 

Are SQGs 

Reusable 

Wipes d

Percent of All 

Facilities that 

Are LQGs 

Disposable 

Wipes e

Percent of All 

Facilities that 

Are SQGs 

Disposable 

Wipes f

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Total

Furniture and 

Fixtures

337110 13 1 14 1,383 120 1,503 1,396 121 1,517 0.86% 91.14% 0.08% 7.92%

337121 0 0 0 206 18 224 206 18 224 0.00% 92.00% 0.00% 8.00%

337122 1 0 2 502 44 546 503 44 547 0.25% 91.75% 0.02% 7.98%

337124 0 0 0 49 4 54 49 4 54 0.00% 92.00% 0.00% 8.00%

337127 0 0 0 96 8 105 96 8 105 0.00% 92.00% 0.00% 8.00%

337211 2 0 2 68 6 74 70 6 76 2.73% 89.27% 0.24% 7.76%

337212 1 0 1 225 20 245 226 20 246 0.28% 91.72% 0.02% 7.98%

337215 1 0 1 120 10 131 121 11 131 0.53% 91.47% 0.05% 7.95%

Auto Dealers 

(retail trade)

44111 0 0 0 3,425 298 3,723 3,425 298 3,723 0.00% 92.00% 0.00% 8.00%

44112 1 0 1 3,775 328 4,103 3,776 328 4,104 0.02% 91.98% 0.00% 8.00%

Military Bases 92812 0 0 0 39 3 43 39 3 43 0.00% 92.00% 0.00% 8.00%

Electronics 

and 

Computers

334411 2 0 2 8 1 9 11 1 11 18.07% 73.93% 1.57% 6.43%

334412 9 1 10 92 8 100 101 9 110 8.17% 83.83% 0.71% 7.29%

334413 38 3 41 98 9 106 136 12 148 25.69% 66.31% 2.23% 5.77%
Appendix C (continued)

Number of Facilities that Generate Solvent-Contaminated Wipes, by Industry a

March 16, 2012 DRAFT C-6

Economic 

Sub-Sector

Industries

(5- or 6-

Digit

NAICS 

Code) a

LQGs SQGs Total Percent of All 

Facilities that 

Are LQGs 

Reusable 

Wipes c

Percent of All 

Facilities that 

Are SQGs 

Reusable 

Wipes d

Percent of All 

Facilities that 

Are LQGs 

Disposable 

Wipes e

Percent of All 

Facilities that 

Are SQGs 

Disposable 

Wipes f

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Subtotal

Use 

Primarily 

Reusable

Wipes

Use 

Primarily 

Disposable

Wipes

Total

Transportation 

Equipment

332912 0 0 0 54 5 58 54 5 58 0.00% 92.00% 0.00% 8.00%

336111 7 1 8 20 2 22 27 2 29 23.40% 68.60% 2.04% 5.96%

336112 5 0 5 7 1 8 12 1 13 36.34% 55.66% 3.16% 4.84%

336211 12 1 14 106 9 116 119 10 129 9.62% 82.38% 0.84% 7.16%

336312 3 0 3 123 11 134 126 11 137 2.02% 89.98% 0.18% 7.82%

33633 3 0 3 33 3 36 36 3 39 7.14% 84.86% 0.62% 7.38%

33634 0 0 0 33 3 36 33 3 36 0.00% 92.00% 0.00% 8.00%

336399 9 1 10 196 17 213 205 18 223 4.03% 87.97% 0.35% 7.65%

336411 22 2 24 22 2 24 44 4 48 46.48% 45.52% 4.04% 3.96%

336412 13 1 14 41 4 44 54 5 59 22.33% 69.67% 1.94% 6.06%

336414 10 1 11 0 0 0 10 1 11 92.00% 0.00% 8.00% 0.00%

336415 3 0 3 1 0 1 4 0 4 66.92% 25.08% 5.82% 2.18%

336419 0 0 0 7 1 8 7 1 8 0.00% 92.00% 0.00% 8.00%

336612 12 1 13 148 13 160 159 14 173 6.78% 85.22% 0.59% 7.41%

336992 1 0 1 8 1 9 9 1 9 7.29% 84.71% 0.63% 7.37%

48839 0 0 0 102 9 111 102 9 111 0.00% 92.00% 0.00% 8.00%

54171 8 1 8 2,128 185 2,313 2,136 186 2,321 0.33% 91.67% 0.03% 7.97%

81149 0 0 0 1,439 125 1,564 1,439 125 1,564 0.00% 92.00% 0.00% 8.00%

Auto Repair 

and 

Maintenance

811111 1 0 1 11,254 979 12,233 11,255 979 12,233 0.01% 91.99% 0.00% 8.00%

811112 0 0 0 463 40 504 463 40 504 0.00% 92.00% 0.00% 8.00%

Total 397 35 432 62,081 5,398 67,479 62,478 5,434 67,911 0.58% 91.41% 0.05% 7.95%

a

 Estimation of number of LQGs and SQGs that generate solvent-contaminated reusable and disposable wipes is discussed in Chapter 2.

b

 Appendix A describes each of the NAICS codes in the exhibit.

c

 [Percent of Total Number of Facilities that Are LQGs and Use Primarily Reusable Wipes] = [Number of LQGs that Use Primarily Reusable Wipes] / [Total Number of LQGs and SQGs]. d

 [Percent of Total Number of Facilities that Are SQGs and Use Primarily Reusable Wipes] = [Number of SQGs that Use Primarily Reusable Wipes] / [Total Number of LQGs and SQGs].

e

 [Percent of Total Number of Facilities that Are LQGs and Use Primarily Disposable Wipes] = [Number of LQGs that Use Primarily Disposable Wipes] / [Total Number of LQGs and SQGs]. f

 [Percent of Total Number of Facilities that Are SQGs and Use Primarily Disposable Wipes] = [Number of SQGs that Use Primarily Disposable Wipes] / [Total Number of LQGs and SQGs].