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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
92 plants Offsite landfill fly ash 76 plants Offsite landfill bottom ash 4 plants Offsite landfill gypsum 16 plants Offsite landfill FGD 7 plants Offsite landfill other CCR (i.e., coal combustion by-products) Sub-total = 116 plants (non-duplicative count) • 33 plants: This estimate is based on the 132 electric utility 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. Estimated Counts of CCR Disposal Units The methodology of this RIA does not estimate or use secondary information about the actual count of CCR disposal units (i.e., landfill units and impoundment units) used by these 467 onsite or offsite disposing plants. However, there are two sources of CCR disposal unit counts: Source #1 of 2: ASTSWMO: The February-March 2009 ASTSWMO voluntary participation survey 36 of 42 states (which is incomplete coverage of the 47 states identified in this RIA for the 495 coal-fired electric plants) estimates a total of 484 electric utility plant CCR disposal units: 227 electric utility plant CCR landfill units in 41 states 257 electric utility plant CCR impoundment units in 33 states Total electric utility plant CCR disposal units = 484 (i.e., 227 landfills + 257 impoundments) But it is not clear whether the ASTSWMO CCR disposal unit counts (a) are restricted in the ASTSWMO survey to electric utility plants in NAICS code 221112, (b) may also include counts of CCR disposal units associated with other industries which generate coal-fired electricity in the surveyed states, (c) may include inactive/abandoned as well as active CCR disposal units, or (d) may include landfills or impoundments operated by electric utility plants which contain other types of waste streams (e.g. waste water treatment ponds without co-mingled CCR). Source #2 of 2: EPA: In March 2009 EPA sent letters 37 to 210 coal-fired electric plant facilities and owner companies in order to identify the location of CCR impoundments and evaluate their structural integrity in the wake of the December 2008 CCR impoundment collapse and 36 Source: Association of State and Territorial Solid Waste Management Officials (ASTSWMO), 01 April 2009 letter to Matt Hale, Director, EPA Office of Resource Conservation and Recovery: http://www.astswmo.org/files/publications/Positionpapers/ASTSWMO-CCB-letter-attachments.pdf 35
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 and 30: Exhibit 3C below, these 495 coal-fi
Page 31 and 32: Exhibit 3C State-by-State Electric
Page 33: 3B. Types of CCR Disposal Units Es
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: ($80,000 per year average Subtitle
Page 65 and 66: Validity Check of Baseline Cost Est
Page 67 and 68: Chapter 4 Estimated Cost for RCRA R
Page 69 and 70: B. Ancillary costs for CCR disposal
Page 71 and 72: location restriction mitigation inv
Page 73 and 74: o Impoundment berms: The average su
Page 75 and 76: State government average cost per w
Page 77 and 78: corrective action remedies usually
Page 79 and 80: Exhibit 4A Two Case Studies: Possib
Page 81 and 82: Biennial Report”). According to E
Page 83 and 84: 4B.3 Land Disposal Restriction Cost
Page 85 and 86:
The TVA cost study did not estimate
Page 87 and 88:
Using the EPA ORCR 2009$ updated un
Page 89 and 90:
Exhibit 4D Comparison of Annual O&M
Page 91 and 92:
Exhibit 4E Summary of Wet Conversio
Page 93 and 94:
o Recent Trend in CCR Impoundment P
Page 95 and 96:
from coal to other fuels such as na
Page 97 and 98:
o Result of Dry Conversion Cost Upd
Page 99 and 100:
As summarized below in comparison t
Page 101 and 102:
17% phase-out trend suggest the fut
Page 103 and 104:
RIA 50- ye ar period Actual company
Page 105 and 106:
4C. State-by-State Distribution of
Page 107 and 108:
4D. Cost Estimation Uncertainty Thi
Page 109 and 110:
Exhibit 4N Cost Estimation Uncertai
Page 111 and 112:
In contrast to the Exhibit 5A list
Page 113 and 114:
Step 2. Determine Potentially Affec
Page 115 and 116:
Step 3. Apply EPA-ORCR 2009 Arsenic
Page 117 and 118:
RISKn WELLREACH iRISK EDn N Where
Page 119 and 120:
The constant slope allowed estimati
Page 121 and 122:
Step 6. Monetize Future Avoided Can
Page 123 and 124:
controls like surface-impoundment p
Page 125 and 126:
Finally, for Subtitle C, there woul
Page 127 and 128:
Exhibit 5A-12 Percentile of Cleanup
Page 129 and 130:
Exhibit 5A-16 Per-Site Groundwater
Page 131 and 132:
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.
Page 139 and 140:
Step 3. Calculate Future Impoundmen
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some surface impoundment regulation
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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
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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
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Others take a different view on how
Page 161 and 162:
Exhibit 5C-7 EPA Extrapolation of E
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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
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Hypothetical expansion of CCR custo
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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
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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
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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