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Applying the percent of CCR beneficially used in each year to the quantities of CCR shown above, the following future annual tons of beneficially used CCR may be expected as displayed below in Exhibit 5C-13. The monetized value of this future baseline projection is: PV @3% discount PV @7% discount Economic value: $102,290 million PV $51,170 million PV Lifecycle social value: $1,554,323 million PV $777,541 million PV Exhibit 5C-13 Baseline Projected Future CCR Beneficial Use (Short Tons) Year CCR Beneficial Use Year CCR Beneficial Use Year CCR Beneficial Use Year CCR Beneficial Use 2012 69,234,181 2025 96,599,301 2038 119,713,602 2051 139,569,037 2013 71,516,427 2026 98,514,244 2039 121,345,430 2052 140,985,202 2014 73,767,022 2027 100,404,645 2040 122,958,473 2053 142,387,139 2015 75,986,563 2028 102,270,993 2041 124,553,122 2054 143,775,155 2016 78,175,638 2029 104,113,770 2042 126,129,762 2055 145,149,549 2017 80,334,827 2030 105,933,448 2043 127,688,769 2056 146,510,616 2018 82,464,703 2031 107,730,494 2044 129,230,513 2057 147,858,644 2019 84,565,827 2032 109,505,366 2045 130,755,358 2058 149,193,918 2020 86,638,755 2033 111,258,513 2046 132,263,659 2059 150,516,713 2021 88,684,034 2034 112,990,378 2047 133,755,767 2060 151,827,302 2022 90,702,202 2035 114,701,396 2048 135,232,025 2061 153,125,952 2023 92,693,789 2036 116,391,994 2049 136,692,770 2024 94,659,318 2037 118,062,592 2050 138,138,332 Step 3. Estimate Potential Induced Effect of RCRA Regulation on CCR Beneficial Use After establishing a future baseline of CCR beneficial use annual tonnage, this step involved formulating three alternative scenarios whereby future CCR beneficial use under RCRA regulation of CCR disposal could either: o Scenario #1: Increase in beneficial use o Scenario #2: Decrease o Scenario #3: Remain unchanged from baseline 168
Increases due to increased disposal costs were estimated first and constitute the “base case” of this RIA. By increasing disposal costs, electric utility plants face an “avoided disposal cost incentive” to ship their CCR farther for beneficial uses by other industries; that is, utilities would be willing to pay more transportation costs to avoid the higher disposal costs. Thus, RCRA regulation of CCR disposal would likely open new markets at farther transport distances, or increase purchases by existing markets. The effect of this stimulus would be to increase CCR beneficial use. The concept of “avoided disposal cost incentive” is recognized and defined by the American Coal Ash Association (ACAA) on its website as follows: “If a [coal-fired electric utility] plant markets its [CCR] into commercial applications, then disposal of this [CCR] is not required. Not only is a revenue stream created for the [coal-fired electricity plant] but also the need to dispose of the [CCR] is avoided. As discussed above, disposal is not just the transportation and placement of [CCR] in a disposal site. The need for future space is a concern. If [CCR is] marketed, then the need to develop future [CCR disposal] sites (including land acquisition, permitting, design and construction costs) is avoided …. It is not uncommon for a company to help offset the costs of transportation or placement at construction sites by providing the contractor or trucking firm a payment of some sort. For example, if the cost of disposal at a plant is normally four dollars a ton, then the company may arrange a payment of four dollars or less to the contractors to cover transportation and placement costs. The difference between the amount of this payment and the cost of disposal is also referred to as “avoided disposal costs.” Source: ACAA Frequently Asked Question nr. 14 webpage at: http://acaa.affiniscape.com/displaycommon.cfm?an=1&subarticlenbr=5#Q14 On the other hand, some stakeholders have claimed that a Subtitle C “hazardous waste” approach would have a “stigma” effect on CCR, reducing their use. That is, due to the label of “hazardous waste,” some purchasers of CCR might opt to turn down the CCR for more expensive substitutes in fear that the CCR might either harm their sales or create liability, and generators might be reluctant to provide the material to users because of liability concerns. The final alternative, that beneficial use quantities remain the same, results in no net costs or benefits for the Subtitle C approach because it is assumed that the baseline trend plays out the same as it would absent a rule. Thus, no further analysis of this option was necessary. The two alternative Scenario analyses (i.e., Scenario #1, Scenario #2) in this section build upon the ACAA’s historical CCR beneficial use data. 144 ACAA data on the beneficial use was modified to remove the use of CCR in minefilling applications because the proposed rule does not address minefilling operations. Excluding 100% of the ACAA reported quantity of CCR used in minefilling results in a reduction of 1.13 million tons per year in the amount beneficially used. As a result, the 2005 quantity of beneficial use relied upon for our analyses is 48.5 million tons per year of CCR, rather than the original 49.6 million tons per year reported by ACAA. 144 Source: Historical CCR beneficial use data from the American Coal Ash Association (ACAA) “Coal Combustion Products -- Production & Use Statistics” webpage at: http://acaa.affiniscape.com/displaycommon.cfm?an=1&subarticlenbr=3 169
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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
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In contrast to the Exhibit 5A list
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Step 2. Determine Potentially Affec
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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 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: Exhibit 5C-12 Beneficial Use Trend
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
Page 213 and 214: Factor #2 of 2: The small business
Page 215 and 216: how much they use or indeed how muc
Page 217 and 218: 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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