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square whose center was the facility WMU. This is illustrated in Exhibit 5A-2 below. It was also assumed that only down-gradient populations would be affected (red rectangle), and no up-gradient populations would be affected. This was accounted for by dividing the onemile population by two. The issue of surface waterbodies is addressed below. Appendix K3 provides a detailed explanation of the derivation of the exposed population by plant. Overall, 715,855 individuals are potentially exposed to CCR. Of this total, 34,533 use private drinking water wells. Exhibit 5A-2 Conceptual Model for Exposed Well-Drinking Population Potentially Exposed Population Groundwater Flow Unexposed Population W M U Contaminant Plume 1-mile Surface Waterbody 114
Step 3. Apply EPA-ORCR 2009 Arsenic Groundwater Risk Results This step involved determining the most appropriate individual risk factors for use in estimating arsenic cancer population risk for the estimated populations residing near the CCR disposal sites. There are two sources of information on individual risks associated with arsenic exposure: IRIS 1998: Based on skin cancer incidence, as data on skin cancer risks were available prior to the availability of quantitative data for internal cancers. Skin cancer is a health endpoint associated with lower fatality risk than the internal cancers induced by arsenic. The skin cancer based risk assessments no longer represent the current state of the science for health risk assessment for arsenic. This RIA presents these estimates below for informational purposes only. This source describes a distribution of risks to a hypothetical individual who drinks water from a well located at a randomly selected point one mile down-gradient from the waste management unit edge. The probabilistic risk estimates were “site-based” (that is, not sitespecific, but based roughly on 181 actual coal-fired power plants that were operating in 1995). EPA has only the “peak” risks (i.e., those corresponding generally to the highest groundwater concentrations that are modeled to occur) available for analysis because computer modeling of peak risks contain gigabytes worth of information, and while EPA attempted to keep track of risks up to 10,000 years of the computer model run, the data in these large files became corrupted and are now unusable. However, below in this RIA EPA does extrapolate population risks in other years. These other years are the years between the cessation of operation of the landfill, or the years after the beginning of operation of the surface impoundment, leading up to the years in which the “peak” risks occur at half of the modeled facilities. NRC 2001: The latest science on health risks associated with arsenic exposure is from the National Research Council (NRC) report “Arsenic in Drinking Water: 2001 Update” 112 which reviewed the available toxicological, epidemiological, and risk assessment literature on the health effects of inorganic arsenic, building upon the NRC’s prior report, “Arsenic in Drinking Water” (1999). The 2001 report, developed by an eminent committee of scientists with expertise in arsenic toxicology and risk assessment provides a scientifically sound and transparent assessment of cancer risks from inorganic arsenic. EPA’s Science Advisory Board endorses these estimates and the IRIS estimates are currently being updated to reflect this latest science. Therefore, while IRIS estimates exist, because the more recent NRC scientific information is available, this RIA relies on the NRC information for analysis of the cancer risks associated with CCR. Appendix K4 provides more detailed information on how this NRC research was used. For the purposes of initially estimating the expected number of cancers (i.e., cancer risks) in Steps 3 and 4, this RIA applied risk results obtained with the latest (i.e., 1998) IRIS value. However, in Step 5 below, the 2001 NRC research was used to update these cancer estimates. It should be noted that the 1998 IRIS skin cancer value does not examine bladder and lung cancer incidence, and therefore is not a substitute for the 2001 NRC cancer risk research in this area. To the extent that the skin cancers estimated by the IRIS value are not accounted for, this RIA may underestimate total cancer incidence. 112 National Research Council, Arsenic in Drinking Water: 2001 Update, National Academy Press, 2001 at http://www.nap.edu/openbook.php?isbn=0309076293 115
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Regulatory Impact Analysis For EPA
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Table of Contents Executive Summary
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Executive Summary This RIA evaluate
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impoundments, the relative number t
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Summary Exhibit 3 Induced Effect of
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Summary Exhibit 6 Comparison of Reg
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Chapter 1 Problem Statement: The Ne
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Bevill Amendments 10 which exempted
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Just three weeks after the TVA’s
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2. Waste & Environmental Management
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This RIA did not discover similar d
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Exhibit 2A Identity of Other Indust
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Require review of surface impoundme
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Chapter 3 Baseline CCR Management i
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Exhibit 3C below, these 495 coal-fi
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Exhibit 3C State-by-State Electric
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3B. Types of CCR Disposal Units Es
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92 plants Offsite landfill fly ash
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electric utility plants in the data
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Exhibit 3E Annual CCR Disposition f
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3D. Size of CCR Disposal Units The
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costs for each type of disposal (no
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annual sampling for surface impound
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o Of the 25 state regulations revie
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Exhibit 3I Baseline Compliance with
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Baseline CCR Disposal Cost Estimati
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Before-tax costs: 50-year period:
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Baseline “Engineering Control”
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assume that the same water trucks w
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memorandum to George Garland, EPA,
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Exhibit 3K Summary of Industry & St
Page 63 and 64: ($80,000 per year average Subtitle
Page 65 and 66: Validity Check of Baseline Cost Est
Page 67 and 68: Chapter 4 Estimated Cost for RCRA R
Page 69 and 70: B. Ancillary costs for CCR disposal
Page 71 and 72: location restriction mitigation inv
Page 73 and 74: o Impoundment berms: The average su
Page 75 and 76: State government average cost per w
Page 77 and 78: corrective action remedies usually
Page 79 and 80: Exhibit 4A Two Case Studies: Possib
Page 81 and 82: Biennial Report”). According to E
Page 83 and 84: 4B.3 Land Disposal Restriction Cost
Page 85 and 86: The TVA cost study did not estimate
Page 87 and 88: Using the EPA ORCR 2009$ updated un
Page 89 and 90: Exhibit 4D Comparison of Annual O&M
Page 91 and 92: Exhibit 4E Summary of Wet Conversio
Page 93 and 94: o Recent Trend in CCR Impoundment P
Page 95 and 96: from coal to other fuels such as na
Page 97 and 98: o Result of Dry Conversion Cost Upd
Page 99 and 100: As summarized below in comparison t
Page 101 and 102: 17% phase-out trend suggest the fut
Page 103 and 104: RIA 50- ye ar period Actual company
Page 105 and 106: 4C. State-by-State Distribution of
Page 107 and 108: 4D. Cost Estimation Uncertainty Thi
Page 109 and 110: Exhibit 4N Cost Estimation Uncertai
Page 111 and 112: In contrast to the Exhibit 5A list
Page 113: Step 2. Determine Potentially Affec
Page 117 and 118: RISKn WELLREACH iRISK EDn N Where
Page 119 and 120: The constant slope allowed estimati
Page 121 and 122: Step 6. Monetize Future Avoided Can
Page 123 and 124: controls like surface-impoundment p
Page 125 and 126: Finally, for Subtitle C, there woul
Page 127 and 128: Exhibit 5A-12 Percentile of Cleanup
Page 129 and 130: Exhibit 5A-16 Per-Site Groundwater
Page 131 and 132: Multiple CCR disposal units at a si
Page 133 and 134: 5B. Benefit of Preventing Future CC
Page 135 and 136: As displayed below in Exhibit 5B-2,
Page 137 and 138: Where: = Observed arrival rate (0.
Page 139 and 140: Step 3. Calculate Future Impoundmen
Page 141 and 142: some surface impoundment regulation
Page 143 and 144: Exhibit 5B-8 Poisson Distribution (
Page 145 and 146: With these new distributions, EPA p
Page 147 and 148: Exhibit 5B-12 Scenario #2: Cleanup
Page 149 and 150: 5C. Induced Effect of RCRA Regulati
Page 151 and 152: Exhibit 5C-1 Estimate of Annual Mat
Page 153 and 154: Exhibit 5C-3 below presents a 2004
Page 155 and 156: To avoid double-counting of economi
Page 157 and 158: 5C2. Potential Effect of RCRA Regul
Page 159 and 160: Others take a different view on how
Page 161 and 162: Exhibit 5C-7 EPA Extrapolation of E
Page 163 and 164: 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
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Analysis - The Institute for Southern Studies

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