- Page 1 and 2: Regulatory Impact Analysis For EPA
- Page 3 and 4: Table of Contents Executive Summary
- Page 5 and 6: Executive Summary This RIA evaluate
- Page 7 and 8: impoundments, the relative number t
- Page 9: Summary Exhibit 3 Induced Effect of
- Page 13 and 14: Chapter 1 Problem Statement: The Ne
- Page 15 and 16: Bevill Amendments 10 which exempted
- Page 17 and 18: Just three weeks after the TVA’s
- Page 19 and 20: 2. Waste & Environmental Management
- Page 21 and 22: This RIA did not discover similar d
- Page 23 and 24: Exhibit 2A Identity of Other Indust
- Page 25 and 26: Require review of surface impoundme
- Page 27 and 28: Chapter 3 Baseline CCR Management i
- Page 29 and 30: Exhibit 3C below, these 495 coal-fi
- Page 31 and 32: Exhibit 3C State-by-State Electric
- Page 33 and 34: 3B. Types of CCR Disposal Units Es
- Page 35 and 36: 92 plants Offsite landfill fly ash
- Page 37 and 38: electric utility plants in the data
- Page 39 and 40: Exhibit 3E Annual CCR Disposition f
- Page 41 and 42: 3D. Size of CCR Disposal Units The
- Page 43 and 44: costs for each type of disposal (no
- Page 45 and 46: annual sampling for surface impound
- Page 47 and 48: o Of the 25 state regulations revie
- Page 49 and 50: Exhibit 3I Baseline Compliance with
- Page 51 and 52: Baseline CCR Disposal Cost Estimati
- Page 53 and 54: Before-tax costs: 50-year period:
- Page 55 and 56: Baseline “Engineering Control”
- Page 57 and 58: assume that the same water trucks w
- Page 59 and 60: memorandum to George Garland, EPA,
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Exhibit 3K Summary of Industry & St
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($80,000 per year average Subtitle
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Validity Check of Baseline Cost Est
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Chapter 4 Estimated Cost for RCRA R
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B. Ancillary costs for CCR disposal
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location restriction mitigation inv
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o Impoundment berms: The average su
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State government average cost per w
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corrective action remedies usually
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Exhibit 4A Two Case Studies: Possib
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Biennial Report”). According to E
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4B.3 Land Disposal Restriction Cost
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The TVA cost study did not estimate
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Using the EPA ORCR 2009$ updated un
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Exhibit 4D Comparison of Annual O&M
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Exhibit 4E Summary of Wet Conversio
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o Recent Trend in CCR Impoundment P
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from coal to other fuels such as na
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o Result of Dry Conversion Cost Upd
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As summarized below in comparison t
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17% phase-out trend suggest the fut
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RIA 50- ye ar period Actual company
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4C. State-by-State Distribution of
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4D. Cost Estimation Uncertainty Thi
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Exhibit 4N Cost Estimation Uncertai
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In contrast to the Exhibit 5A list
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Step 2. Determine Potentially Affec
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Step 3. Apply EPA-ORCR 2009 Arsenic
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RISKn WELLREACH iRISK EDn N Where
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The constant slope allowed estimati
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Step 6. Monetize Future Avoided Can
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controls like surface-impoundment p
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Finally, for Subtitle C, there woul
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Exhibit 5A-12 Percentile of Cleanup
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Exhibit 5A-16 Per-Site Groundwater
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Multiple CCR disposal units at a si
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5B. Benefit of Preventing Future CC
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As displayed below in Exhibit 5B-2,
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Where: = Observed arrival rate (0.
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Step 3. Calculate Future Impoundmen
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some surface impoundment regulation
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Exhibit 5B-8 Poisson Distribution (
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With these new distributions, EPA p
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Exhibit 5B-12 Scenario #2: Cleanup
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5C. Induced Effect of RCRA Regulati
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Exhibit 5C-1 Estimate of Annual Mat
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Exhibit 5C-3 below presents a 2004
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To avoid double-counting of economi
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5C2. Potential Effect of RCRA Regul
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Others take a different view on how
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Exhibit 5C-7 EPA Extrapolation of E
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Based on the most recent CCR benefi
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Beneficial uses of CCR have been co
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Exhibit 5C-12 Beneficial Use Trend
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Increases due to increased disposal
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“Using [coal] fly ash in building
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Exhibit 5C-14 Historical Annual Per
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Hypothetical expansion of CCR custo
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Step 6: Apply Estimated Induced Eff
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Exhibit 5C-16 Scenario #1: Increase
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Exhibit 5C-17 Scenario #2: Decrease
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Exhibit 5C-18 Beneficial Use Trends
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Exhibit 5C-19 Scenario #1: Benefit
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Exhibit 5C-21 Scenario #2: Cost of
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Step 10: Quantify Potential Capacit
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Chapter 6 Comparison of Regulatory
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Exhibit 6B Comparison of Regulatory
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Exhibit 6D Comparison of Regulatory
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Exhibit 6F Comparison of Regulatory
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Exhibit 6F Scaling Factors (Extrapo
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Exhibit 6G Estimate of Subtitle D (
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detect contamination early and thus
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Step 1: Downloaded the annual milli
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Exhibit 7A State by State Breakout
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Small government: Based on the RFA/
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Step 3 & Step 4: Determine and docu
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Factor #2 of 2: The small business
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how much they use or indeed how muc
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Collection of Minority & Low-Income
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Comparison of Minority & Low-Income
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Exhibit 7G Minority and Low-Income
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Exhibit 7H Comparison of Minority a
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o The state-by-state range of minor
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CCR fraction #3: CCR fraction #4:
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7D. Child Population Statistics (Ex
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Comparison of Child Populations Liv
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Count of plant unique ZCTAds Exhibi
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Exhibit 7K Comparison of Child Popu
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7E. Unfunded Mandates (UMRA) & Fede
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Findings for UMRA Impact and Federa
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Exhibit 7M List of 74 Coal-Fired El