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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
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($80,000 per year average Subtitle
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Validity Check of Baseline Cost Est
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Chapter 4 Estimated Cost for RCRA R
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B. Ancillary costs for CCR disposal
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location restriction mitigation inv
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o Impoundment berms: The average su
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State government average cost per w
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- Page 79 and 80: Exhibit 4A Two Case Studies: Possib
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- Page 83 and 84: 4B.3 Land Disposal Restriction Cost
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- Page 87 and 88: Using the EPA ORCR 2009$ 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
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- Page 109 and 110: Exhibit 4N Cost Estimation Uncertai
- Page 111 and 112: In contrast to the Exhibit 5A list
- Page 113 and 114: Step 2. Determine Potentially Affec
- Page 115 and 116: Step 3. Apply EPA-ORCR 2009 Arsenic
- 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: Exhibit 5A-12 Percentile of Cleanup
- 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
- Page 165 and 166: Beneficial uses of CCR have been co
- Page 167 and 168: Exhibit 5C-12 Beneficial Use Trend
- Page 169 and 170: Increases due to increased disposal
- Page 171 and 172: “Using [coal] fly ash in building
- Page 173 and 174: Exhibit 5C-14 Historical Annual Per
- Page 175 and 176: Hypothetical expansion of CCR custo
- Page 177 and 178: 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