Analysis - The Institute for Southern Studies

Onsite landfills:
Onsite impoundments:
311 plants operate onsite CCR landfills (this RIA refers to these as “onsite” landfills although some may be
located off plant property). This estimate consists of two sources (i.e., 212 plants + 99 plants):
• 212 plants: dentified through actual data reporting of 363 coal-fired electric plants in size >100 MW
contained in the 2005 EIA-767 database, out of the total 495 plants identified using the 2007 EIA-
860 database (as described in the previous section above).
• 99 plants: This estimate is based on the remainder 132 electric utility plants (i.e., 495 minus 363
plants = 132 plants) between 1 MW and 100 MW size for which there is no CCR disposal data in the
EIA-767 database, and for which the CCR disposal engineering control cost model used in this RIA
assigned the lowest-cost of three landfill options: (1) onsite dug landfill, (2) onsite pile landfill, or
(3) offsite landfill. The cost model assignment was dependent upon the level of baseline engineering
controls assumed required by each plant’s state location and annual CCR disposal tonnage. The cost
model estimated that 99 of the 132 plants without data dispose CCR in onsite landfills.
158 plants operate onsite CCR surface impoundments (aka “ponds,” “embankments,” “dams,” “dikes,” “wet
dumps,” “constructed wetlands”). This RIA assumes that all impoundments are “onsite” although some may
be located off plant property.
The non-duplicative count of plants using onsite landfills and/or onsite impoundments is 383 plants.
Offsite disposal:
149 plants assigned as sending CCR offsite for disposal to commercial landfills (of which 84 plants solely
ship CCR for offsite disposal). Off-site landfills receiving CCR are assumed to already be in compliance
with EPA’s RCRA Subtitle D guidance. The 149 plants assigned as using offsite landfills consist of the
following assignments according to data sources (i.e., 116 plants + 33 plants):
• 116 plants: Electric utility plants >100 MW size (source: 2005 EIA-767 database): Final disposition
of wastes is reported as either (a) company-owned landfill, (b) company-owned disposal pond, (c)
on-site use & storage, (d) sold, or (e) off-site disposal. This RIA assumes that off-site disposal
means offsite commercial landfill. Plants could have reported offsite minefill in this category if it
was not "sold" (e.g., they paid to dispose it in a mine or it was used as minefill and no payment was
made to the electric utility). However, it is unknown the sub-quantity of “offsite disposal” which
includes plants reporting tonnages for non-sold uses as offsite minefill. 35
35 In July 2009, ORCR contacted the DOE-EIA Form 767 questionnaire contact person (Natalie Ko, Electric Power Division) to clarify this RIA’s assignment of all “offsite
disposal” tonnages as commercial landfills. The DOE-EIA contact person responded with additional information from four 2005 Form EIA-767 questionnaires regarding
how electricity plant respondents optionally characterized the fly ash and bottom ash reported in the Form EIA-767 survey questionnaire as “Off Site Disposal” :
· “This quantity of fly ash was given away at no cost”
· “The fly ash was sent off site for beneficial use”
· “The fly ash is injected into the nearby mines for recharging the mines”
· “Ash is recycled as a beneficial re-use product for flowable fill in the construction industry”
34