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6B. Factors Applied for Scaling Benefits and Costs to the Three 2010 Regulatory Options The regulatory compliance cost estimation presented in Chapter 4 of this RIA was initially formulated with reference to the October 2009 draft RIA regulatory options. Furthermore, the regulatory benefits evaluation in Chapter 5 of this RIA was based only on the 2010 regulatory options. To resolve this inconsistency in scope between the two different sets of regulatory options evaluated for costs and for benefits, respectively, this RIA applies the scaling factors (i.e., percentage extrapolation multipliers) displayed below in Exhibit 6F. The cost analysis presented in Chapter 4 of this RIA is built upon a detailed (i.e., plant-by-plant for all 495 coal-fired electric utility plants) engineering cost model which estimated "engineering control" costs associated with the RCRA 3004(x) custom-tailored technical standards of the 2009 regulatory options (i.e., Subtitle C "hazardous waste" option, Subtitle D non-hazardous waste option requiring composite liners for new CCR disposal units, and a "hybrid" C/D option). Although the engineering control costs were the same for each of the three October 2009 options, "ancillary costs" differed according to whether an option was formulated in reference to Subtitle C or to Subtitle D authority. For example, only the Subtitle C "hazardous waste" option and the Subtitle C component of the "Hybrid C/D" option required the cost associated with manifesting offsite shipments of CCR between coal-fired electric utility plants and offsite CCR disposal locations. The October 2009 draft RIA presented the "dry conversion cost" element as a separable "sub-option" for both the Subtitle C and Subtitle D options. However, in 2010 EPA identified a different set of three regulatory options to describe in the proposed rule and evaluate in RIA (i.e., Subtitle C "special waste" option with wet disposal phase-out, Subtitle D option which in effect would phase-out wet CCR disposal by requiring retrofitting existing impoundments with composite liners, and a Subtitle "D prime" option requiring liners only for new disposal units). In order to meet EPA’s end-of-March 2010 internal deadline for completing the 2 nd draft of this RIA, EPA did not revised the Chapter 4 cost analysis or the Chapter 7 supplemental analyses, but applied scaling factors for bridging the cost estimates to the 2010 options. Numerically, the scaling factors represent alternative compliance rate assumptions in relation to the 2009 draft RIA’s Subtitle C "hazardous waste" option as a reference case for both cost and benefit estimate scaling to the three 2010 regulatory options. The scaling factors assume less compliance under the non-Federally enforceable Subtitle D based options compared to the Federally-enforceable Subtitle C option. Section 6B of this RIA provides the numerical values assigned to the scaling factors on an itemized basis according to the separate cost element and benefit element categories, for each of the three 2010 regulatory options. Exhibit 6F Scaling Factors (Extrapolation Multipliers) Applied in this RIA to Estimate the Costs & Benefits of the 2010 Regulatory Options for CCR Disposal Economic Impact Category Subtitle C Special Waste Subtitle D (version 2) Subtitle “D prime” Regulatory Compliance Costs: 1. Engineering control costs 100% 48% 48% 2. Ancillary costs 100% 48% 48% 3. Dry conversion costs 100% 40% 0% Regulatory Benefits: 198
Exhibit 6F Scaling Factors (Extrapolation Multipliers) Applied in this RIA to Estimate the Costs & Benefits of the 2010 Regulatory Options for CCR Disposal Economic Impact Category Subtitle C Special Waste Subtitle D (version 2) Subtitle “D prime” 1. Groundwater contamination prevention benefits: Groundwater remediation costs avoided 100% 48% 30% Monetized value of human cancer risks avoided 100% 48% 30% 2. Impoundment structural failure cleanup costs avoided 100% 45% 23% 3. Induced impact on CCR beneficial use: Scenario #1: Induced increase Scenario #2: Induced decrease Scenario #3: No change 100% 100% Not relevant 40% None (0%) Not relevant 16% None (0%) Not relevant The following two sub-sections (6B.1 and 6B.2) provide explanation and documentation of the scaling factors displayed in Exhibit 6F above. 6B.1 Regulatory Cost Scaling Factors o Engineering control costs: For both RCRA subtitle C and subtitle D, the engineering control costs would be identical under both options. However, state governments are not required to develop comparable programs under RCRA Subtitle D rules, and states cannot enforce Federal subtitle D rules. In addition, because of the nature of subtitle D authority, individual requirements (e.g., groundwater monitoring, impoundment closure) will be more generic, allowing industry great latitude in complying. Thus, actual costs under Subtitle D options will be lower than under Subtitle C, because facilities would not be expected to comply to the same extent. In estimating future annual tons of CCR that might be managed under new standards, and the extent to which they would be similar under the Subtitle C option, this RIA applies the percentage of tons of CCR disposed in states with groundwater monitoring requirements as a way to estimate the likely costs incurred by industry for the other options. Although the engineering control cost category consists of 10 cost elements as defined in this RIA, the percentage of states with groundwater monitoring programs is a reasonable surrogate indicator because states imposing groundwater monitoring requirements indicates which states will generally address specific units, and which are likely to upgrade their programs under subtitle D, if EPA were to issue a national subtitle D rule. In those states, management standards may significantly improve, although not to the level of subtitle C for the reasons discussed above. On the other hand, certainly some facilities in states without programs will choose to comply with the national regulation (taking full advantage of the more generic nature of the federal D standards). Taking these two factors together, using the percentage of CCR disposed in states with groundwater monitoring programs provides a reasonable estimate of the extent to which facilities will take steps to comply with the national standards, and therefore of the costs of compliance. For the federally-enforceable subtitle C option, the cost recognizes that all states (100%) will be required by the CCR rule to install groundwater monitoring (and all other engineering controls). For both the non-federally enforceable subtitle D and the “D prime” options, the cost estimates assume that the 48% of waste disposed of in states that currently require surface impoundments to have groundwater monitoring (either for new units only or for new and 199
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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
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As displayed below in Exhibit 5B-2,
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Where: = Observed arrival rate (0.
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Step 3. Calculate Future Impoundmen
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some surface impoundment regulation
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Exhibit 5B-8 Poisson Distribution (
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With these new distributions, EPA p
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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
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: Exhibit 6F Comparison of Regulatory
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
Page 237 and 238: 7E. Unfunded Mandates (UMRA) & Fede
Page 239 and 240: Findings for UMRA Impact and Federa
Page 241 and 242: Exhibit 7M List of 74 Coal-Fired El
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Analysis - The Institute for Southern Studies

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