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Exhibit 5B-3 Cumulative Distribution Probability 100.0% 95.0% 90.0% 85.0% 80.0% 75.0% 70.0% 65.0% 60.0% 55.0% 50.0% 45.0% 40.0% 35.0% 30.0% 25.0% 20.0% 15.0% 10.0% 5.0% 0.0% 0 5 10 15 20 25 30 35 Events Catastrophic Significant 138
Step 3. Calculate Future Impoundment Failure Avoided Cleanup Cost Benefits After fitting a distribution of the number of releases likely to occur, EPA proceeded to combine these with the cost data presented in Step 1 above. This was done for the average case and three high-end cases (90 th , 95 th , and 99 th percentiles). For each case, the number of expected releases seen in Exhibit 5B-4 below was divided by 50 to get the expected number of releases per year. These events were then multiplied by their respective costs, and the catastrophic and significant release values were summed in each year. Exhibit 5B-4 Projected Future CCR Impoundment Releases Based on 15-Year (1995-2009) Period of Historical CCR Impoundment Structural Failure Cases Type of CCR Expected Number of Release Events Assigned Cost Impoundment Release 99 th %-ile 95 th %-ile 90 th %-ile Average Per Failure Event Catastrophic 8 7 6 3 $3.0 billion* Significant 27 24 22 17 $23.1 million * Note: $3.0 billion is EPA’s initial “social cost” estimate assigned in this RIA to the December 2008 TVA Kingston TN impoundment release event. Social cost represents the opportunity costs incurred by society, not just the monetary costs for cleanup. OMB's 2003 "Circular A-4: Regulatory Analysis" (page 18) instructs Federal agencies to estimate "opportunity costs" for purpose of valuing benefits and costs in RIAs. This $3.0 billion social cost estimate is larger than TVA’s $933 million to $1.2 billion cleanup cost estimate (i.e., TVA’s estimate as of 03 Feb 2010), because EPA’s social cost estimate consists of three other social cost elements in addition to TVA’s cleanup cost estimate: (a) TVA cleanup cost, (b) response, oversight and ancillary costs associated with local, state, and other Federal agencies, (c) ecological damages, and (d) local (community) socio-economic damages. Appendix Q to this RIA provides EPA's documentation and calculation of these four cost elements, which total $3.0 billion in social cost. Appendix Q to this RIA also provides an alternative, lower estimate of social costs, based on different modeling assumptions for capturing such costs. This alternative analysis suggests that TVA’s cleanup costs alone may be close to the social costs associated with the Kingston impoundment failure. EPA specifically requests comment on this social cost estimate, and will continue to develop this estimate for the final rule. However, EIA data indicate that there is a current trend among coal-fired power plants to switch from wet handling to dry handling. As seen below in Exhibit 5B-5, this will lead to a decrease of approximately 300,000 tons being disposed of in surface impoundments per year, or approximately 1.3% of the initial 22.5 million tons in 2005. Since the tons disposed of (and similarly, the number of surface impoundments) likely relate to the number of releases, these decreases are accounted for by using 2005 wet tonnage as a benchmark and assuming the quantity of wet tonnage declines 300,000 tons per year. The cost for each year is multiplied by the remaining percent still handled wet. 139
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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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($80,000 per year average Subtitle
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Validity Check of Baseline Cost Est
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Chapter 4 Estimated Cost for RCRA R
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B. Ancillary costs for CCR disposal
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location restriction mitigation inv
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o Impoundment berms: The average su
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State government average cost per w
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corrective action remedies usually
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Exhibit 4A Two Case Studies: Possib
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Biennial Report”). According to E
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4B.3 Land Disposal Restriction Cost
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The TVA cost study did not estimate
Page 87 and 88: Using the EPA ORCR 2009$ 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 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 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: Where: = Observed arrival rate (0.
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
Page 179 and 180: Exhibit 5C-16 Scenario #1: Increase
Page 181 and 182: Exhibit 5C-17 Scenario #2: Decrease
Page 183 and 184: Exhibit 5C-18 Beneficial Use Trends
Page 185 and 186: Exhibit 5C-19 Scenario #1: Benefit
Page 187 and 188: 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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