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Monetization of Potential “Stigma” Decrease in CCR Beneficial Use (Scenario #2) The $559 per ton social benefit value estimated above is the proper estimate for increased beneficial use because this RIA assumes that all beneficial uses will increase in equal proportions. However, it would not be appropriate to apply this same dollar estimate to decreased beneficial use from stigma because different uses decrease by different amounts, and therefore the decrease in benefits would not necessarily equal the 51% decrease in tons. Based on the breakdown of beneficial uses displayed below in Exhibit 5C-20, these individual use category losses were summed to create a weighted average benefit reduction of 42%. However, on a tonnage basis 51% of beneficial use tons are reduced. Dividing the weighted value by the unweighted value for each ton lost, the benefits decreased by only 82% of the average $559/ton, or $458/ton. This average unitized social benefits value is used to monetize the estimated tons lost from the stigma Scenario #2. Exhibit 5C-20 Calculation of the “Stigma” Adjustment Factor for the CCR Beneficial Use Reduction Scenario #2 Beneficial Use Industrial Category CCR Beneficial Use (2005 tons) Disposal Cost Savings Life Cycle Benefits Total Benefits Percent Lost From Stigma Benefits Lost (millions) (millions) (millions) (millions) 1. Concrete/concrete products/grout 16,353,331 $1,390 $17,593 $18,983 37.5% $7,118.6 2. Blended cement/raw feed for clinker 4,215,234 $358 Not estimated $358 50% $179.0 3. Flowable fill 259,907 $22 Not estimated $22 37.5% $8.3 4. Structural fill/embankments 8,349,999 $710 Not estimated $710 80% $568.0 5. Road base/sub-base 1,461,992 $124 Not estimated $124 80% $99.2 6. Soil modification/stabilization 1,139,640 $97 Not estimated $97 80% $77.6 7. Mineral filler in asphalt 140,838 $12 Not estimated $12 50% $6.0 8. Snow & ice control 547,541 $47 Not estimated $47 80% $37.6 9. Blasting grit/roofing granules 1,633,407 $139 Not estimated $139 37.5% $52.1 10. Gypsum panel products (wallboard) 8,178,079 $695 $5,387 $6,082 50% $3,041.0 11. Waste stabilization/solidification 2,839,954 $241 Not estimated $241 0% $0.0 12. Agriculture 415,741 $35 Not estimated $35 80% $28.0 13. Aggregate 872,776 $74 Not estimated $74 80% $59.2 14. Miscellaneous other 2,071,157 $176 Not estimated $176 65% $114.4 Weighted Total = 48,479,596 $4,120 $22,980 $27,100 42% $11,382 Unweighted Total = 48,479,596 $4,120 $22,980 $27,100 51% $13,821 Adjustment Factor = 0.82 Exhibit 5C-21 below provides an estimate of the beneficial use decrease scenario. This quantity is calculated each year as the quantity projected under subtitle C (with stigma) less the quantity projected under the baseline. 186
Exhibit 5C-21 Scenario #2: Cost of Potential Future Reduction in CCR Beneficial Use Under Subtitle C with “Stigma” Year CCR Beneficial Use Decrease Nominal Costs (Millions) Discounted Costs @ 3% (Millions) Discounted Costs @ 7% (Millions) (Short Tons) Economic Social Economic Social Economic Social 2012 -33,342,859 -$1,269 -$15,816 -$1,269 -$15,816 -$1,269 -$15,816 2013 -33,342,859 -$1,269 -$15,816 -$1,232 -$15,355 -$1,186 -$14,781 2014 -33,342,859 -$1,269 -$15,816 -$1,196 -$14,908 -$1,109 -$13,814 2015 -33,342,859 -$1,269 -$15,816 -$1,162 -$14,474 -$1,036 -$12,910 2016 -33,342,859 -$1,269 -$15,816 -$1,128 -$14,052 -$968 -$12,066 2017 -33,342,859 -$1,269 -$15,816 -$1,095 -$13,643 -$905 -$11,276 2018 -33,342,859 -$1,269 -$15,816 -$1,063 -$13,245 -$846 -$10,539 2019 -33,342,859 -$1,269 -$15,816 -$1,032 -$12,860 -$790 -$9,849 2020 -33,342,859 -$1,269 -$15,816 -$1,002 -$12,485 -$739 -$9,205 2021 -33,342,859 -$1,269 -$15,816 -$973 -$12,122 -$690 -$8,603 2022 -33,342,859 -$1,269 -$15,816 -$944 -$11,768 -$645 -$8,040 2023 -33,342,859 -$1,269 -$15,816 -$917 -$11,426 -$603 -$7,514 2024 -33,342,859 -$1,269 -$15,816 -$890 -$11,093 -$564 -$7,022 2025 -33,342,859 -$1,269 -$15,816 -$864 -$10,770 -$527 -$6,563 2026 -33,342,859 -$1,269 -$15,816 -$839 -$10,456 -$492 -$6,134 2027 -33,342,859 -$1,269 -$15,816 -$815 -$10,152 -$460 -$5,732 2028 -33,342,859 -$1,269 -$15,816 -$791 -$9,856 -$430 -$5,357 2029 -33,342,859 -$1,269 -$15,816 -$768 -$9,569 -$402 -$5,007 2030 -33,342,859 -$1,269 -$15,816 -$746 -$9,290 -$376 -$4,679 2031 -33,342,859 -$1,269 -$15,816 -$724 -$9,020 -$351 -$4,373 2032 -33,342,859 -$1,269 -$15,816 -$703 -$8,757 -$328 -$4,087 2033 -33,342,859 -$1,269 -$15,816 -$682 -$8,502 -$307 -$3,820 2034 -33,342,859 -$1,269 -$15,816 -$662 -$8,254 -$287 -$3,570 2035 -33,342,859 -$1,269 -$15,816 -$643 -$8,014 -$268 -$3,336 2036 -33,342,859 -$1,269 -$15,816 -$624 -$7,780 -$250 -$3,118 2037 -33,342,859 -$1,269 -$15,816 -$606 -$7,554 -$234 -$2,914 2038 -33,342,859 -$1,269 -$15,816 -$589 -$7,334 -$219 -$2,723 2039 -33,342,859 -$1,269 -$15,816 -$571 -$7,120 -$204 -$2,545 2040 -33,342,859 -$1,269 -$15,816 -$555 -$6,913 -$191 -$2,379 2041 -33,342,859 -$1,269 -$15,816 -$539 -$6,711 -$178 -$2,223 2042 -33,342,859 -$1,269 -$15,816 -$523 -$6,516 -$167 -$2,078 2043 -33,342,859 -$1,269 -$15,816 -$508 -$6,326 -$156 -$1,942 2044 -33,342,859 -$1,269 -$15,816 -$493 -$6,142 -$146 -$1,815 2045 -33,342,859 -$1,269 -$15,816 -$479 -$5,963 -$136 -$1,696 2046 -33,342,859 -$1,269 -$15,816 -$465 -$5,789 -$127 -$1,585 2047 -33,342,859 -$1,269 -$15,816 -$451 -$5,621 -$119 -$1,481 2048 -33,342,859 -$1,269 -$15,816 -$438 -$5,457 -$111 -$1,384 2049 -33,342,859 -$1,269 -$15,816 -$425 -$5,298 -$104 -$1,294 187
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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
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RISKn WELLREACH iRISK EDn N Where
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The constant slope allowed estimati
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Step 6. Monetize Future Avoided Can
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controls like surface-impoundment p
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Finally, for Subtitle C, there woul
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Exhibit 5A-12 Percentile of Cleanup
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Exhibit 5A-16 Per-Site Groundwater
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Multiple CCR disposal units at a si
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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 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: Exhibit 5C-19 Scenario #1: Benefit
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
Page 219 and 220: Comparison of Minority & Low-Income
Page 221 and 222: Exhibit 7G Minority and Low-Income
Page 223 and 224: Exhibit 7H Comparison of Minority a
Page 225 and 226: o The state-by-state range of minor
Page 227 and 228: CCR fraction #3: CCR fraction #4:
Page 229 and 230: 7D. Child Population Statistics (Ex
Page 231 and 232: Comparison of Child Populations Liv
Page 233 and 234: Count of plant unique ZCTAds Exhibi
Page 235 and 236: 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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