Appendix EProcedures for Estimating Hidden (Tier II) Costs
Regulatory costs are often charged to overhead, and are therefore “hidden” when project costs are evaluated. Hidden personnel costs are often difficult to account for because environmental reporting and recordkeeping are frequently performed by staff who divide their time between many different processes and facilities. Nevertheless, it is possible to estimate the time required to meet notification, reporting, manifesting and other administrative tasks associated with environmental compliance. Tables E-1 to E-5 give methods for estimating the notification, reporting, recordkeeping, manifesting, and labeling costs required by the Resource Conservation and Recovery Act (RCRA) for hazardous ...
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