Analysis - The Institute for Southern Studies

electric utility plants in the data year, extrapolated to plants for which there is no CCR tonnage data in the
EIA database (in the case of this RIA’s estimation methodology) and in the case of the ACAA estimates,
extrapolated to plants not covered by ACAA’s annual utility industry survey by supplementing with EIA
data.
The estimate of CCR generation developed in this RIA consists of the following breakout of generation estimates according to two electric
utility plant size categories, which correspond to the CCR tonnage disposition data reporting cut-off requirement in the EIA-767 database:
>100 MW plants:
Exhibit 3E below presents CCR disposition data for a sub-total of 120.9 million tons CCR generated per year as
reported by plants with annual electricity generation >100 MW from Schedule 3A of the 2005 EIA-767 database for
each plant.
Ash generation data (fly ash and bottom ash) were available for 385 plants.
FGD sludge generation data were available for 72 plants.
Gypsum generation data were available for 31 plants.
Other byproduct generation data were available for 40 plants.
If plants > 100 MW reported either company landfill, company disposal ponds, sold for beneficial use, or off-site
disposal of CCR in the EIA-767 database, these final disposition practices are assumed in this RIA for the baseline. A
total 179 plants with company-owned CCR landfills and 158 plants with company-owned CCR surface
impoundments were reported in the 2005 EIA-767 database (i.e., 337 of the 495 electric plants). 40 112 of the 495
plants reported 8.2 million “on-site use and storage” which this RIA assigned as beneficial use not as disposal. This
assumption is supported by (a) DOE’s August 2006 report 41 “Coal Combustion Waste Management at Landfills and
Surface Impoundments 1994-2004” which interpreted the entire "onsite use & storage" quantity as beneficial use, and
(b) the American Coal Ash Association (ACAA) which indicates that 49.6 million tons of coal ash were beneficially
used in 2005 42 . However, the beneficial use estimate in Exhibit 3E below is much less at 38.8 million tons which is
based on the EIA-767 “Sold” (i.e., beneficial use) CCR tonnage category. But adding the 8.2 million tons reported as
"onsite use & storage" yields an estimate of 47.0 million tons (Exhibit 3G), which nearly matches the ACAA
beneficial use estimate of 49.6 million tons. This suggests it is valid to assign the tonnage reported in the EIA-767
database as "onsite use & storage" to beneficial use rather than to disposal.
40 In the 2005 DPRA Report, an additional step was included after step 1 that identified additional disposal practices using landfill and surface impoundment as reported in
the 1995 EPRI Comanagement Survey. This data source was not used to identify CCR management units in this RIA given it dates back to 1995. The data source is only
used to identify existing engineering controls for the units identified in the 2005 EIA 767 database. In the 2005 DPRA Report, 14 additional landfills and 10 surface
impoundments were identified using this information source.
41 Source: Footnote c of Table 1 on page 6 of DOE’s August 2006 report at http://www.ead.anl.gov/pub/dsp_detail.cfm?PubID=2008
42 Source: ACAA’s 2005 beneficial use data are available at http://acaa.affiniscape.com/associations/8003/files/2005%20CCP%20Survey%20%2809-19-06%29Corrected-
11-09-07.pdf
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