Analysis - The Institute for Southern Studies

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Exhibit 3C State-by-State Electric Utility Plant Counts by Type/Size of Owner Entity (2007) Count of Plants Owned by Non-Small Entities Count of Plants Owned by Small Entities Item State Federal government State Government Non-small municipal Non-small company Non-small cooperative County government Small municipal Small company Small cooperative Row total plants 1 AK 2 2 2 AL 2 7 1 10 3 AR 3 3 4 AZ 2 3 1 6 5 CA 6 6 6 CO 1 2 11 14 7 CT 2 2 8 DC 0 9 DE 3 3 10 FL 5 9 1 15 11 GA 10 1 11 12 HI 2 2 13 IA 1 13 3 2 19 14 ID 0 15 IL 2 21 2 25 16 IN 21 5 26 17 KS 2 6 8 18 KY 2 1 14 3 1 21 19 LA 4 4 20 MA 4 4 21 MD 8 8 22 ME 1 1 23 MI 2 13 5 2 22 24 MN 1 10 5 16 25 MO 5 10 2 2 1 20 26 MS 3 1 1 5 27 MT 4 1 5 28 NC 19 3 22 29 ND 2 5 7 30 NE 4 3 7 31 NH 2 2 32 NJ 1 6 7 33 NM 3 3 34 NV 2 2 35 NY 11 1 1 13 36 OH 2 20 4 26 37 OK 1 4 1 6 38 OR 1 1 30
Exhibit 3C State-by-State Electric Utility Plant Counts by Type/Size of Owner Entity (2007) Count of Plants Owned by Non-Small Entities Count of Plants Owned by Small Entities Item State Federal government State Government Non-small municipal Non-small company Non-small cooperative County government Small municipal Small company Small cooperative Row total plants 39 PA 32 2 34 40 RI 0 41 SC 4 10 14 42 SD 2 2 43 TN 7 7 44 TX 1 2 14 1 1 19 45 UT 1 4 1 6 46 VA 15 1 16 47 VT 0 48 WA 1 1 49 WI 12 3 2 17 50 WV 16 16 51 WY 8 1 9 Column totals= 11 13 27 372 20 1 33 12 6 495 The annual amount of coal burned by these 495 operating plants is 1.036 billion tons per year as reported in the 2007 EIA-923 database, according to the following five types of coal fuel categories: Bituminous coal (DOE-EIA data code = BIT): 330 plants (67% of 495 plants) Lignite coal (LIG): 21 plants (4%) Coal-based synthetic fuel (SC): 19 plants (4%) Sub-bituminous coal (SUB): 201 plants (41%) Waste/other coal (WC): 33 plants (7%) Many plants use more than one coal fuel type so the above percentages exceed 100%. Appendices B & C present the quantity of coal burned and the types of coal burned for the list of 495 plants. As displayed in the state-by-state Exhibit 3D below, 47 states have coal-fired electric utility plants (3 states --- ID, RI, VT --- and DC do not have electric utility plants). The top-5 state coal-fired electric utility plant counts are: 1. PA 34 plants 2. IN & OH 26 plants each 3. IL 25 plants 4. MI & NC 22 plants each 5. KY 21plants 31
Page 1 and 2: Regulatory Impact Analysis For EPA
Page 3 and 4: Table of Contents Executive Summary
Page 5 and 6: Executive Summary This RIA evaluate
Page 7 and 8: impoundments, the relative number t
Page 9 and 10: Summary Exhibit 3 Induced Effect of
Page 11 and 12: Summary Exhibit 6 Comparison of Reg
Page 13 and 14: Chapter 1 Problem Statement: The Ne
Page 15 and 16: Bevill Amendments 10 which exempted
Page 17 and 18: Just three weeks after the TVA’s
Page 19 and 20: 2. Waste & Environmental Management
Page 21 and 22: This RIA did not discover similar d
Page 23 and 24: Exhibit 2A Identity of Other Indust
Page 25 and 26: Require review of surface impoundme
Page 27 and 28: Chapter 3 Baseline CCR Management i
Page 29: Exhibit 3C below, these 495 coal-fi
Page 33 and 34: 3B. Types of CCR Disposal Units Es
Page 35 and 36: 92 plants Offsite landfill fly ash
Page 37 and 38: electric utility plants in the data
Page 39 and 40: Exhibit 3E Annual CCR Disposition f
Page 41 and 42: 3D. Size of CCR Disposal Units The
Page 43 and 44: costs for each type of disposal (no
Page 45 and 46: annual sampling for surface impound
Page 47 and 48: o Of the 25 state regulations revie
Page 49 and 50: Exhibit 3I Baseline Compliance with
Page 51 and 52: Baseline CCR Disposal Cost Estimati
Page 53 and 54: Before-tax costs: 50-year period:
Page 55 and 56: Baseline “Engineering Control”
Page 57 and 58: assume that the same water trucks w
Page 59 and 60: memorandum to George Garland, EPA,
Page 61 and 62: Exhibit 3K Summary of Industry & St
Page 63 and 64: ($80,000 per year average Subtitle
Page 65 and 66: Validity Check of Baseline Cost Est
Page 67 and 68: Chapter 4 Estimated Cost for RCRA R
Page 69 and 70: B. Ancillary costs for CCR disposal
Page 71 and 72: location restriction mitigation inv
Page 73 and 74: o Impoundment berms: The average su
Page 75 and 76: State government average cost per w
Page 77 and 78: corrective action remedies usually
Page 79 and 80: Exhibit 4A Two Case Studies: Possib
Page 81 and 82:
Biennial Report”). According to E
Page 83 and 84:
4B.3 Land Disposal Restriction Cost
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The TVA cost study did not estimate
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Using the EPA ORCR 2009$ 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
Page 109 and 110:
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
Page 149 and 150:
5C. Induced Effect of RCRA Regulati
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Exhibit 5C-1 Estimate of Annual Mat
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Exhibit 5C-3 below presents a 2004
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To avoid double-counting of economi
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5C2. Potential Effect of RCRA Regul
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Others take a different view on how
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Exhibit 5C-7 EPA Extrapolation of E
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Based on the most recent CCR benefi
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Beneficial uses of CCR have been co
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Exhibit 5C-12 Beneficial Use Trend
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Increases due to increased disposal
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“Using [coal] fly ash in building
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Exhibit 5C-14 Historical Annual Per
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Hypothetical expansion of CCR custo
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Step 6: Apply Estimated Induced Eff
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Exhibit 5C-16 Scenario #1: Increase
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Exhibit 5C-17 Scenario #2: Decrease
Page 183 and 184:
Exhibit 5C-18 Beneficial Use Trends
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Exhibit 5C-19 Scenario #1: Benefit
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Exhibit 5C-21 Scenario #2: Cost of
Page 189 and 190:
Step 10: Quantify Potential Capacit
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Chapter 6 Comparison of Regulatory
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Exhibit 6B Comparison of Regulatory
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Exhibit 6D Comparison of Regulatory
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Exhibit 6F Comparison of Regulatory
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Exhibit 6F Scaling Factors (Extrapo
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Exhibit 6G Estimate of Subtitle D (
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detect contamination early and thus
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Step 1: Downloaded the annual milli
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Exhibit 7A State by State Breakout
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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
Page 231 and 232:
Comparison of Child Populations Liv
Page 233 and 234:
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
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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