Analysis - The Institute for Southern Studies

5B. Benefit of Preventing Future CCR Impoundment Structural Failures (Avoided Cleanup Costs)
In December 2008, a failure of a CCR impoundment at the Tennessee Valley Authority (TVA) Kingston Fossil Fuel Plant TN resulted in the
environmental release of 5.4 million cubic yards of CCR. This impoundment failure event illustrated the potential environmental damage
severity of structural failures involving CCR impoundments. This section of the RIA estimates future avoided impoundment failure cleanup
costs as a potential benefit of the CCR proposed rule, according to the following 5-step method.
Step 1. Characterize CCR Impoundment Release Data
EPA began by examining the CCR impoundment survey data collected in March and April 2009 by EPA under the authority of Section 104(e)
of the Comprehensive Emergency Response, Compensation and Liability Act (CERCLA), from 162 individual electric utility plants and from
61 electric utility corporate headquarters offices. EPA obtained its list of facilities from a 2005 Department of Energy (DOE) Survey of coal
burning electric utility facilities. EPA used DOE’s 2005 Energy Information Agency F767 database, which provides information on the
disposition of coal ash from coal burning electricity producers. The database included "steam-electric plants with a generator nameplate rating
of 10 or more megawatts." The term “generator,” means the actual electric generator, not the whole plant. A plant typically will have one or
more generators. EPA also sent the letters to corporate offices of the electric utilities to make sure that all of their facilities were accounted for
due to limitations in the DOE survey. Based on information received in response to the initial letter to the utility corporate headquarters
offices, on April 27, 2009, EPA sent information request letters to an additional 48 plants that had been identified by the corporate offices.
Based EPA’s initial collation of the mail survey data, 42 CCR releases from impoundments were reported, all of which occurred within the last
15 years (1995-2009), in response to Question 8 of the survey questionnaire which asked for electric power plants to report all CCR
impoundment releases which occurred within the last 10 years (i.e., 1999 to 2008). Exhibit 5B-1 below presents a summary of these 42 CCR
impoundments release cases. Appendix K11 provides additional information about these 42 release cases.
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