Environmental Economics

The Impacts of Removing the TCLP Deferral for Petroleum-contaminated Media at Underground Storage Tank Sites

When the RCRA Toxicity Characteristic (TC) rule was promulgated in 1990, EPA temporarily deferred from Subtitle C requirements media contaminated by petroleum from leaking underground storage tanks (USTs). To determine whether to make the deferral permanent, EPA undertook to study the potential costs and benefits of regulating these media under Subtitle C. The contractor analyzed the potential impact that removing the TC deferral would have on several state UST programs. This report reviews the findings of these case studies and discusses the broader nationwide implications of removing the deferral.

The foundation of the research was a series of three case studies developed in cooperation with the states of Minnesota, Vermont, and Texas. The objective of these case studies was to develop detailed analyses of how removal of the deferral would affect UST cleanups, taking into account state-specific conditions (e.g., baseline cleanup standards, soil treatment costs) that influence the nature and magnitude of the impacts. Specifically, the case studies assessed the effect that removing the deferral would have on UST cleanup procedures, the pace of corrective action, the cost of corrective action, and the human health risk associated with the UST problem.

The report had two objectives: (1) to summarize the findings of the case studies, and (2) to generalize from these findings to develop an assessment of the national impacts of removing the TC deferral. For the national assessment, the case study finding are frequently supplemented with related UST research developed by EPA. Additional detail is provided by the case studies themselves, which are included as appendices to the report.

  • Keywords

    1. Benefits Analysis
    3. Cost and Economic Impacts Analysis
    1. Benefits Analysis - Quantification without Monetization
    3. Costs and Economic Impact Analysis - Specific Sectors and Pollutants
    Environmental Media:
    c. Land
    c. Land - Solid Waste/RCRA
    EPA Project Officer/ Manager:
    Geographic Area:
    Study Purpose:
    Empirical Application, Policy Evaluation
    Inventory Record #: EE-0343
  • Participating Organizations

    Research Organization:

    Industrial Economics, Inc.Address: 2627 Massachusetts Avenue
    City: Cambridge State: MA ZIP: 02140
    Phone: Fax:
    Funding Organization:
    Office of Policy, Planning and EvaluationAddress:
    City: Washington State: DC ZIP: 20460
    Phone: Fax:
  • Report Details
    Number of Pages:
    Comment: Also included in RERM as reference #S.92.4 and ID#KT00002D2A.
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    Date Linked: 08/25/2017