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RCRA Box 321 

Prepped by Ryan Dugan 

Document Number: 

250) OGRC-S0040.A 

Docket Number: 

F-93-OGRC-FFFFF 

Printed 5/8/2007 3:36:33 PM Sheet 250 of 259 
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Economic Analysis - Impacts of the Toxicity Characteristic on 

Crude oil Reclaimers 

The Toxicity Characteristic Regulatory Impact Analysis (RIA) 

Appendix C contains information concerning costs to handlers of 

non-hazardous wastes that will be reclassified as hazardous wastes. 

EPA developed unit costs in dollars per metric ton for both 

. baseline management practices and compliance management practices. 

This information can be applied to the problem of estimating 

compliance costs for crude oil reclaimers that are affected by the 

TC, although additional data will be needed in order to derive an 

accurate cost estimate. These data will be available after further 

analysis of the crude oil reclaiming industry. Specifically, 

information concerning the components and volumes of the crude oil 

reclaiming waste is needed. 

Appendix C supplies cost estimates for different types of 

waste disposal such as land treatment, landfills, and deep well 

injection. The different components of the reclaimers' wastes will 

require different management, and therefore each component will 

contribute a different cost to the overall treatment/management 

costs of these wastes. In addition, due to economies of scale, 

generators of small or large volumes of waste will incur different 

costs for management. Data currently being gathered through phone 

contacts, surveys, and any other sources regarding the crude oil 

reclaiming industry's size and its volume of waste production can 

be applied to existing cost estimates for different sizes of waste 

generators, as modeled in the TC RIA. 

Furthermore, the cost information in Appendix C does not 

provide estimates for the crude oil industry specifically. This 

industry may ba grouped with the Petroleum Refining industry that 

is considered in the RIA, but this will probably result in an 

overestimate of costs for the reclaiming industry. 

Two groups of reclaimers are subject to different costs of 

compliance, depending on their management practices. One group 

sends its wastes off-site for treatment after storing it for a 

maximum of 90 days. This group will incur the new costs of sending 

wastes off-site to a hazardous waste treatment facility, of 

notification and biennial reporting, and of tank and container 

upgrades* Appendix c does not provide specific costs for these 

administrative activities, but these costs may be derived from 

other information concerning permitting costs. An after-tax cost 

estimate of $200/metric ton for the shipment of wastes to a 

commercial hazardous waste storage facility may be.assumed, but 

this figure is a general estimate for all industries, not for crude 

oil reclaimers specifically. 

The other group of reclaimers produce a large enough volume 

of waste to justify treatment on-site. This group will incur TSD 

costs of permitting, closure and post-closure, financial 

assurances, as well es the notification and reporting costs 

discussed above. Appendix C provides capital cost and O&M cost 

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assumptions for Subtitle C landfills, land treatment, and deep well 

injection. (It may be necessary to derive costs for Subtitle c 

surface impoundments from other RlAs.) As discussed previously, 

the portion of reclaiming wastes requiring each different type of 

disposal is necessary before accurate estimates can be made, in 

addition, the size of disposal facilities must be considered, if 

crude oil reclaimer disposal sites are generally smaller or larger 

than those modeled in the RIA, the cost estimates would be over or 

under estimated. 

Once additional data on types and quantities of waste 

generated, and types and numbers of disposal units used by the 

crude oil reclaimers industry are compiled, we can estimate 

compliance costs for the industry, with the limitations and 

assumptions noted above.