Analysis - The Institute for Southern Studies

Exhibit 5B-12
Scenario #2: Cleanup Cost Estimates for CCR Impoundment Catastrophic Failures @ 10% Failures
% of Tons
Costs @3% Costs @7% % of Tons Costs @3% Costs @7%
Year
Baseline
(in millions) (in millions) Subtitle C (in millions) (in millions)
88.2% 2014 - - 88.2% - -
86.9% 2015 $1,146 $1,022 70.6% $930 $830
85.6% 2016 $1,095 $941 52.9% $677 $582
84.3% 2017 $1,047 $866 35.3% $438 $362
83.0% 2018 $1,001 $797 17.6% $213 $169
81.7% 2019 $956 $733 0.0% $0 $0
80.4% 2020 $914 $674
79.1% 2021 $873 $619
77.8% 2022 $833 $569
76.5% 2023 $796 $523
75.2% 2024 $759 $481
73.9% 2025 $724 $441
72.6% 2026 $691 $405
71.2% 2027 $659 $372
69.9% 2028 $628 $341
68.6% 2029 $598 $313
67.3% 2030 $569 $287
66.0% 2031 $542 $263
64.7% 2032 $516 $241
63.4% 2033 $491 $221
62.1% 2034 $467 $202
Baseline Total $15,305 $10,309 C Total $2,259 $1,943
Given the costs above, the total benefits of a Subtitle C phase out over 5 years would be the difference between the potential catastrophic
failure costs under C and the catastrophic failure costs under the baseline. For the 20% “Scenario #3”, this figure is double, as displayed below
in Exhibit 5B-13. For Subtitle D, it is assumed that the 48% of states (by tonnage, as described in Appendix K9) that have at least some
regulatory oversight currently, would enforce the retrofitting requirement. However, since 5.5% of impoundments already have composite
liners, these units would not be expected to close. Thus 94.5% times 48% leads to an approximately 45% of the Subtitle C benefits. For
Subtitle D prime, the requirement of dam safety inspections would be likely to result in some amount catastrophic failure reduction between the
baseline and the Subtitle D approach. This RIA uses the midpoint, a 23% reduction, as a best estimate. While these estimates are likely much
higher than the actual benefits from preventing catastrophic failures, they do help to define the upper bound of what is possible under current
practices of mismanagement.
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