Attachment
A
Summary
of
Catalyst
Reclamation
and
Disposal
Costs
Before
the
final
listing
decision:

Recycling
costs
were
$500
­
$600
/
ton
with
a
passback
based
on
price
of
metals
recovered.

Disposal
in
subtitle
D
landfill
was
$50
­
$70
/
ton.

70%
of
spent
hydrotreating
and
hydrorefining
was
recycled.
Majority
was
recycled
because
of
uncertainty
of
future
regulatory
status.
Refineries
did
not
want
to
be
liable
for
subtitle
D
landfilling
of
what
could
become
hazardous
waste.
A
significant
portion
of
spent
catalyst
was
handled
as
characteristic
(ignitable)
waste.

After
the
final
listing
decision:

Recycling
costs
are
still
$500
/
$600
ton.
However,
metals
(vanadium)
market
is
depressed.
Almost
no
passback
to
refineries.

Costs
for
reclaimers
increased
slightly
as
a
result
of
the
final
rule
due
to
need
to
manage
derived­
from
wastes
as
hazardous
(previously
these
wastes
were
subject
to
characteristic/
ignitability
requirements).
Most
reclaimers
already
had
subtitle
C
storage
due
to
management
of
characteristic
wastes.

Disposal
in
Subtitle
C
landfill
is
approximately
$200/
ton.

A
lower
percentage
of
spent
catalyst
is
recycled
because
fear
of
future
regulation
is
gone,
not
because
of
any
actual
changes
in
the
cost
of
proper
waste
management.
And
in
fact,
spent
hydrocracking
catalysts
are
not
listed,
thus
providing
what
the
refineries
see
as
an
"exclusion"
from
subtitle
C
regulation.
Therefore,
no
hydrocracking
catalysts
are
recycled
and
until
our
11/
29/
99
memo,
dual
purpose
catalysts
were
not
recycled.

Claims
by
refineries
that
the
inclusion
of
spent
dual
purpose
catalysts
in
scope
of
listing
will
present
significant
new
burdens
are
mostly
without
merit,
given
that
only
two
refineries
have
dual
purpose
units
(Motiva
in
Convent,
LA,
BP
Amoco
in
Texas
City,
TX).

In
economic
analysis
for
final
rule,
we
assumed
a
5%
increase
in
recycling
costs
as
a
result
of
the
rule.
We
assumed
LDR
and
off­
site
disposal
costs
would
be
$240/
MT
and
$233/
MT.
This
is
almost
double
what
refineries
claim
currently
to
be
incurring.
