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Exhibit 6G Estimate of Subtitle D (version 2) Impoundment Liner Retrofit or Build New Lined Impoundment Cost A B C D E F G (D x F x 63%**) Count of existing electric utility plants with impoundments Subtitle C special waste: Dry Conversion Cost Percent existing CCR impoundments with composite liners* Percent of CCR impoundments without composite liners Subtitle D (v.2): Must Retrofit or Build New Lined Impoundments Row Year * 5.5% existing impoundments with composite liners based on EPA’s 2000 CCR regulatory determination and on the August 2006 joint EPA-DOE survey report. ** EPA estimated the capital and annual O&M costs for the Subtitle D requirement for either retrofitting or building new CCR impoundments with composite liners, by assuming that the cost for those requirements are 63% of the $23.167 billion present value cost for dry conversion under the Subtitle C option. This 63% cost scaling factor is calculated in Exhibit 6H of this RIA. Exhibit 6H Reference Data for Calculation of "63% Cost Scaling Factor" Applied in Exhibit 6G Capital cost O&M cost Row total Percent Capital cost Percent Dry Coal Ash Management (35-year lifespan cost in 1980$) 1 In-plant handling system $19,500,000 $693,100,000 $712,600,000 76% $19,500,000 23% 2 Conveyance (transport) $10,364,000 $116,996,000 $127,360,000 14% $10,364,000 12% 3 Disposal (lined landfill) $53,952,000 $39,926,000 $93,878,000 10% $53,952,000 64% Total = $83,816,000 $850,022,000 $933,838,000 100% $83,816,000 100% Wet Coal Ash Management (35-year lifespan cost in 1980$) 1 In-plant handling system $8,500,000 $302,121,000 $310,621,000 69% $8,500,000 9% 2 Conveyance (transport) $31,954,000 $42,140,000 $74,094,000 16% $31,954,000 34% 3 Disposal (lined impoundment) $52,906,000 $14,448,000 $67,354,000 15% $52,906,000 57% 63%* Total = $93,360,000 $358,709,000 $452,069,000 100% $93,360,000 100% Source: Based on cost data for an example 2600 megawatt (MW) nameplate capacity electric utility plant from pages B-8 (dry) and C-9 (wet) of the EPA/TVA joint study “Economic Analysis of Wet Versus Dry Ash Disposal Systems: Interagency Energy/Environment R&D Program Report,” report nr. EPA-600/7-81-013, January 1981: http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=20006ORT.txt * EPA estimated the capital and annual O&M costs for the Subtitle D requirement for either retrofitting or building new CCR impoundments with composite liners, by assuming that the cost for those requirements are 63% of the $23.167 billion present value cost for dry conversion under the Subtitle C option. This 63% cost scaling factor is calculated in this exhibit. 6B.2 Regulatory Benefits Scaling Factors o Groundwater contamination benefits: Percentages are based on an examination of state programs related to groundwater monitoring requirements as described in Chapter 5 of this RIA. The percentages given in Exhibit 6F above refer only to the input values to the estimation of groundwater protection benefits presented in Chapter 5 of this RIA. For the Subtitle C option, all states will be required by the rule to have groundwater monitoring in place so that 100% of facilities over the baseline would 202
detect contamination early and thus human cancers would be prevented. For the Subtitle D option, 48% of CCR are placed in surface impoundments in states with groundwater monitoring in place for new units only (or for new and existing units). It is likely that these states with some level of attention to groundwater monitoring would increase their attention (e.g., because they already have a RCRA program infrastructure) to groundwater monitoring, providing for much more effective systems, while other states would tend not to (although some individual facilities within those states would upgrade groundwater monitoring to some extent). Thus, this RIA estimates that overall, the new regulation would result in 48% of facilities detecting contamination early and 48% of cancers would be prevented. For the Subtitle D prime option, retrofitting existing units would not be required, and therefore existing and future releases would continue to occur from unlined surfaced impoundments. Currently 12% of CCR are placed in surface impoundments in states with groundwater monitoring. Some of these states would certainly upgrade their regulations, but given that surface impoundments would remain a potential source of release in all states, the Subtitle D prime option is less protective of groundwater than the Subtitle D option. Since this fraction is likely to fall between 48% and 12%, the mid-point of 30% was chosen as a best estimate for the D prime option. o Impoundment structural failure cleanup costs avoided: This factor is not based on estimates of percentages of states likely to implement the new requirements (which for subtitle D would require liners for existing surface impoundments); it is unlikely that many states will choose to implement this requirement. Instead, compliance will not be enforceable, and will be left up to self-imposed schedules of industry or citizens suits. While most impoundments may eventually close, it will be a lengthy process. As a general estimate, through delaying closures and lengthening the process, industry may be able to reduce costs by 50%. In addition, since 5.5% of surface impoundments have composite liners already, they would remain in place, and therefore would not incur costs. Taking these figures together, this RIA applies a 45% scaling factor for this benefit. o Induced impact on CCR beneficial uses: • Under Scenario #1 induced increase in beneficial use, beneficial uses are assumed to be linear with respect to total costs because increases in usage are directly proportional to the cost of the regulatory options. Therefore, under the Subtitle D option, the net reduction in total costs compared to the Subtitle C option is 40%. Under the Subtitle “D prime” option, since the dry conversion costs are 0%, a net result of 16% was applied. This percentage was derived by dividing the Subtitle “D prime” option cost by the total cost of Subtitle C. • Under Scenario #2 induced decrease in beneficial use, for the reasons described in Section 5C of this RIA, this RIA assumes that potential induced future decrease on beneficial use only applies to the Subtitle C regulatory option, not to the Subtitle D-based options. • Under Scenario #3 no change in beneficial use (relative to baseline), there is no impacts under any of the regulatory options, so no scaling assumptions are applied. 203
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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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Exhibit 5B-12 Scenario #2: Cleanup
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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 and 198: Exhibit 6F Comparison of Regulatory
Page 199 and 200: Exhibit 6F Scaling Factors (Extrapo
Page 201: Exhibit 6G Estimate of Subtitle D (
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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