Analysis - The Institute for Southern Studies

dry disposal within the next eight to 10 years (i.e. by 2019). Conversions of this sort are a current trend, and they will definitely
continue, even in the absence of the CCR proposed rule. As summarized in Exhibit 4H above (columns A to D), EPA identified 18
such plants constituting 17% of the industry-wide wet CCR disposal tonnage as of 2005. It is inappropriate to attribute the wet disposal
phase-out cost of the CCR proposed rule to plants independently moving to dry CCR disposal. At this point, EPA expects that most
plants will choose to move to dry disposal given the additional factors presented below.
2. Plants switching to other fuels: EPA assumes this factor is reflected in the phase-out trend applied to the cost update. Some coalfired
electricity plants have since 2005 switched, or are planning to switch, some or all of their coal-fired boilers at certain plants, from
coal to other fuels (e.g. natural gas) for reasons unrelated to the CCR proposed rule. In such cases, the cost of closure of their CCR
disposal impoundments should not be attributed to the cost of the proposed rule. This factor decreases the estimated cost of the rule,
and particularly EPA’s estimated future cost of phasing-out wet disposal attributable to the proposed rule. For example, based on
EPA’s recent internet search, as also displayed in Exhibit 4H above (columns E to H), EPA identified 8 coal-fired electric utility plants
using impoundments (as of 2005) representing 3% of wet CCR disposal by the 158 plants, which have or plan to switch fuels at one or
more of their coal-fired electricity generation boilers within one or more plants, or to close one or more of their coal-fired boilers or
entire coal-fired plants.
3. Lifespan expiration of existing CCR impoundments: This factor suggests a faster future phase-out trend than applied in the cost
update, but is not applied in the cost update. Another factor which corroborates the future continuation of the electric utility industry’s
voluntary phase-out of CCR impoundments, is the fact that existing (i.e., active, operational) CCR impoundments have distinct
operational lifespans. When an impoundment reaches its end-of-lifespan, the electric utility plant must in that future year either add
new impoundment capacity by installing another impoundment, or convert to dry disposal by installing a landfill (or providing their
annual CCR for beneficial uses). For purpose of estimating the “engineering cost” component (in Chapter 4 of this RIA), EPA
assigned impoundment lifespan start years (i.e., year in which impoundment construction was completed and began receiving CCR),
and future expected impoundment operational lifespan closure years, to each of the 158 coal-fired plants with operational CCR
impoundments (as of 2005) identified in this RIA. For the most part, the impoundment start years were based on actual industryreported
data from the references cited in this RIA. However, expected closure years were provided by industry for 78 of the 158
plants; thus, EPA assigned expected closure years to the remainder 80 plants assuming a 40-year lifespan. Exhibit 4J below presents a
summary of the expected future closure years in relation to the remaining lifespan years and associated impoundment tonnages which
are expected to reach end of operational lifespan in absence of the CCR rule. This summary indicates that all existing CCR
impoundments could be expected to reach end-of-lifespan by year 2051, and that 20% of impoundments will have reached end-oflifespan
by year 2018. According to the cost update assumptions discussed in the 2 nd update steps of prior section above, year 2018
represents the 5 th year of the CCR final rule’s assumed 5-year phase-out period spanning 2014 to 2018, which also assumes the CCR
final rule is promulgated by EPA at the start of 2012 and that state governments will adopt the rule 2-years later by the end of 2013.
This lifespan expiration trend corroborates the assumed continuation of the phase-out trend depicted in Exhibit 4I (column A1) which
indicates that 17% of CCR impoundment tonnage may be expected to have phased-out by year 2018 (i.e., 18.7 million tons remaining
by 2018 compared to 22.5 million tons in the analysis base year 2005) in absence of the CCR rule. In fact, given that end-of-lifespan
provides companies with a low-cost opportunity to convert to dry disposal, the higher 20% end-of-lifespan percentage compared to the
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