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Exhibit 5C-8 Extending EIA Projections 1,400,000,000 1,350,000,000 1,300,000,000 1,250,000,000 Coal Burned (Tons) 1,200,000,000 1,150,000,000 1,100,000,000 1,050,000,000 1,000,000,000 950,000,000 900,000,000 2007 2012 2017 2022 2027 2032 2037 2042 2047 2052 2057 Year EIA Projection EPA Regression 162
Based on the most recent CCR beneficial use data from ACAA, EPA estimated the average tons of CCR generated for every ton of coal burned by electric utility plants. For this calculation, this RIA only used the most recent data year (2008) to estimate a conversion rate because over time, the quantities of CCR generated per ton of coal combusted has steadily increased. Thus an average of recent years would not reflect this trend. The steady increase over time is due to tightening of industrial air pollution regulations. This trend would likely continue in the future as further facilities undergo new source review, or implement new Clean Air Act requirements under upcoming EPA rules like the Clean Air Interstate Rule (CAIR) and the Clean Air Mercury Rule (CAMR). Thus, the future annual tonnages of CCR estimated in this RIA are likely under-estimates. Dividing the 2008 tons of CCR generated (136 million tons) by the 2008 tons of coal burned by the electric power sector (1,042 million tons), EPA produced a CCR-to-coal relationship factor of 0.131. Applying this factor to the extrapolated coal consumption projection produced the future CCR generation scenario displayed below in Exhibit 5C-9. Exhibit 5C-9 Projected Future Annual CCR Generation by the Electric Utility Industry: Scenario Based on Extrapolation of EIA’s Projection of Electric Power Sector Coal Burned 2007-2035 (Short Tons) Year CCR Year CCR Year CCR Year CCR 2012 134,764,862 2025 145,087,115 2038 155,409,369 2051 165,731,622 2013 135,558,881 2026 145,881,135 2039 156,203,388 2052 166,525,642 2014 136,352,901 2027 146,675,154 2040 156,997,408 2053 167,319,661 2015 137,146,920 2028 147,469,174 2041 157,791,427 2054 168,113,681 2016 137,940,940 2029 148,263,193 2042 158,585,447 2055 168,907,700 2017 138,734,959 2030 149,057,213 2043 159,379,466 2056 169,701,720 2018 139,528,979 2031 149,851,232 2044 160,173,486 2057 170,495,739 2019 140,322,998 2032 150,645,252 2045 160,967,505 2058 171,289,759 2020 141,117,018 2033 151,439,271 2046 161,761,525 2059 172,083,778 2021 141,911,037 2034 152,233,291 2047 162,555,544 2060 172,877,798 2022 142,705,057 2035 153,027,310 2048 163,349,564 2061 173,671,817 2023 143,499,076 2036 153,821,330 2049 164,143,583 2024 144,293,096 2037 154,615,349 2050 164,937,603 Appendix K5 to this RIA presents alternative estimates of future CCR generation. These estimates take into account the recent increasing trend in the ratio of tons CCR generated to the tons coal combustion. For example, in year 2035 the constant ratio projection above yields a value of 153 million tons CCR generated whereas the increasing ratio projection in Appendix K5 yields a value of 191 million tons of CCR generated. While the exact magnitude of such an increase is uncertain, there would be at least some increase as a result of increased air pollution controls. These include future changes due to EPA’s New Source Review (NSR), EPA’s Clean Air Interstate Rule (CAIR), and EPA’s Clean Air Mercury Rule (CAMR). 163
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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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($80,000 per year average Subtitle
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Validity Check of Baseline Cost Est
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Chapter 4 Estimated Cost for RCRA R
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B. Ancillary costs for CCR disposal
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location restriction mitigation inv
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o Impoundment berms: The average su
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State government average cost per w
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corrective action remedies usually
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Exhibit 4A Two Case Studies: Possib
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Biennial Report”). According to E
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4B.3 Land Disposal Restriction Cost
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The TVA cost study did not estimate
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Using the EPA ORCR 2009$ updated un
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Exhibit 4D Comparison of Annual O&M
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Exhibit 4E Summary of Wet Conversio
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o Recent Trend in CCR Impoundment P
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from coal to other fuels such as na
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o Result of Dry Conversion Cost Upd
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As summarized below in comparison t
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17% phase-out trend suggest the fut
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RIA 50- ye ar period Actual company
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4C. State-by-State Distribution of
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4D. Cost Estimation Uncertainty Thi
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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 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: Exhibit 5C-7 EPA Extrapolation of E
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
Page 189 and 190: Step 10: Quantify Potential Capacit
Page 191 and 192: Chapter 6 Comparison of Regulatory
Page 193 and 194: Exhibit 6B Comparison of Regulatory
Page 195 and 196: Exhibit 6D Comparison of Regulatory
Page 197 and 198: Exhibit 6F Comparison of Regulatory
Page 199 and 200: Exhibit 6F Scaling Factors (Extrapo
Page 201 and 202: Exhibit 6G Estimate of Subtitle D (
Page 203 and 204: detect contamination early and thus
Page 205 and 206: Step 1: Downloaded the annual milli
Page 207 and 208: Exhibit 7A State by State Breakout
Page 209 and 210: Small government: Based on the RFA/
Page 211 and 212: 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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