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1MW to 100 MW Exhibit 3F below presents an additional sub-total of 20.3 million tons per year of CCR generated by 132 electric utility plants between 1 MW and 100 MW in capacity which had no CCR management information in the EIA767 database, because plants less than 100 MW are not required to report their CCR management annual tonnages in the EIA-767 database. Therefore, this RIA formulated an estimate for this size category of plants based on the following approach. Coal use and percent ash content data from Schedule 4A of the 2005 EIA-767 database were used to estimate ash generation quantities for 102 plants within this smaller size category. For 5 plants for which EIA-767 coal use data were unavailable for 2005, coal use data from Schedule 4A of the 2007 EIA-923 database were used to estimate CCR generation quantities for those 5 plants. FGD sludge generation data obtained from Schedule 8 43 of the 2005 EIA-767 database were used for 115 plants. Landfill (either on-site or off-site whichever is more economical) is the assumed CCR disposal practice. No gypsum or other byproduct generation quantities were estimated. For plants between 1 MW and 10 MW, ash generation quantities estimated using generator nameplate capacity rating data from the 2007 DOE Form 860 database. This 1 MW to 100 MW subtotal of 132 plants consists of two sub-categories: 10 MW to 100 MW: 5.4 million tons of CCR for 110 plants estimated by multiplying the quantity of coal they burned by the percent CCR content of the coal data from Schedule 4A of the 2005 EIA-767 database and 2007 DOE EIA 923 database, or using generator nameplate rating data from the 2007 EIA-860 database and an average percent ash content. 1 MW to 10 MW: 14.9 million tons of FGD sludge reported for 22 plants in Schedule 8 of the 2005 EIA-767 database that did not report any FGD sludge in Schedule 3A of the 2005 EIA-767 database. 43 In general, data obtained from Schedule 8 of the 2005 EIA-767 database reflects information reported by plants between 10 MW and 100 MW. However, if a plant greater than 100 MW reported no final disposition quantities for FGD sludge in Schedule 3A of the 2005 EIA-767 database, the reported FGD sludge quantity in Schedule 8 is assumed in this RIA to be placed in a landfill for that plant. 38
Exhibit 3E Annual CCR Disposition for NAICS 22 Electric Utility Plants >100 MW Capacity (tons per year as of 2005) Item CCR Category A B C D E F (A+…+E) Company-Owned Company-Owned Onsite Use & Sold for Offsite Disposal Row Totals Landfill (Dry Disposal) Disposal Ponds (Wet Disposal) Storage (assumed as beneficial use) Beneficial Use (assumed offsite landfills) 1 Fly Ash 21,324,280 15,212,590 3,744,370 20,760,230 9,314,540 70,356,010 2 Bottom Ash 5,707,740 4,311,630 3,487,660 5,453,717 1,907,480 20,868,227 3 Flue Gas Desulfurization Sludge 9,526,400 1,886,200 465,600 408,910 2,506,540 14,793,650 4 Gypsum (salable) 54,620 872,100 372,100 8,437,400 782,800 10,519,020 5 Other CCR 226,510 82,900 108,830 3,729,400 247,680 4,395,320 6 Totals 36.8 million 22.4 million 8.2 million 38.8 million 14.8 million 120.9 million Item Exhibit 3F Annual CCR Disposition for NAICS 22 Electric Utility Plants 1 MW to 100 MW Capacity (tons per year as of 2005) A B C D (A+B+C) Fly Ash Disposed in Off-site Landfill (Plants 1 MW to 100 MW) Fly Ash Disposed in Company-owned Landfill (Plants 1 MW to 100 MW) FGD Disposed in Company-Owned Landfill (Plants >10 MW) CCR Category Row Totals 1 Fly Ash 274,917 5,147,468 NA 5,422,385 2 Bottom Ash Included under Fly Ash Included under Fly Ash NA Included under fly ash 3 Flue Gas Desulfurization Sludge NA NA 14,852,300 14,852,300 4 Gypsum (salable) NA NA Included in row 3 Included in FGD 5 Other Byproducts Included under Fly Ash Included under Fly Ash NA Included under fly ash 6 Totals 0.3 million 5.1 million 14.9 million 20.3 million Item Exhibit 3G Annual CCR Disposition for NAICS 22 Electric Utility Plants All Sizes (tons per year as of 2005) (Source: Exhibit 3E + Exhibit 3F) A B C D E (A+B+C+D) Company-Owned Beneficial Use Offsite Disposal Disposal Ponds (onsite BU + offsite (assumed offsite (Wet disposal) BU + storage for BU) commercial landfills) Row Totals Company-Owned Landfill (Dry disposal) CCR Category 1 Fly Ash 26,471,748 15,212,590 24,504,600 9,589,457 70,356,010 2 Bottom Ash 5,707,740 4,311,630 8,941,377 1,907,480 20,868,227 3 Flue Gas Desulfurization Sludge 24,378,700 1,886,200 874,510 2,506,540 14,793,650 4 Gypsum (salable) 54,620 872,100 8,809,500 782,800 10,519,020 5 Other CCR 226,510 82,900 3,838,230 247,680 4,395,320 6 Totals 56.8 million 22.4 million 47.0 million 15.0 million 141.2 million Percentages 40% 16% 33% 11% 100% 39
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 and 34: 3B. Types of CCR Disposal Units Es
Page 35 and 36: 92 plants Offsite landfill fly ash
Page 37: electric utility plants in the data
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
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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
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RISKn WELLREACH iRISK EDn N Where
Page 119 and 120:
The constant slope allowed estimati
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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
Page 133 and 134:
5B. Benefit of Preventing Future CC
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As displayed below in Exhibit 5B-2,
Page 137 and 138:
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 (
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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
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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
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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
Page 171 and 172:
“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
Page 181 and 182:
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
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
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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 (
Page 203 and 204:
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
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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
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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