Analysis - The Institute for Southern Studies

costs for each type of disposal (note: the sum of plant counts for each disposal category below exceeds 467 because some plants use more than
one type of CCR disposal method):
o 311 plants with active onsite CCR landfills
o 158 plants with active onsite CCR surface impoundments
o 149 plants which offsite dispose (assumed all involve offsite landfills)
For this RIA, the “baseline” is defined as existing conditions plus projection of future conditions over the 50-year future period-of-analysis
2012 to 2061 applied in this RIA (this RIA assumes year 2012 represents the first year when the final rule could take effect, if promulgated).
Baseline engineering controls were estimated using the following 2-step method which is based on two alternative and complementary sources
of information:
Step 1: If the plant reported controls in the 1995 EPRI Comanagement Survey, 1996 CIBO Survey, or the 1994-2004 DOE-EPA Study,
the stricter of these controls or state-specified controls are assumed for the baseline. These studies contained control data for 89 plants with
CCR landfills and 50 plants with CCR impoundments (i.e., 139 of the 495 electric utility plants). State regulations added additional
controls at 69 of the 89 landfill plants and 43 of the 50 impoundment plants with plant specific information (e.g., the EPRI Survey data may
have indicated that the unit had a liner only but state regulations required groundwater monitoring and capping so these additional controls
were added).
Step 2: Controls specified under state regulations for 34 states are assumed for all other plants in those 34 states for the baseline if no
1995 EPRI Comanagement Survey data, 1996 CIBO Survey data, or 1994-2004 DOE-EPA Study data are available for that plant. This
step resulted in assigning state-required controls to 201 plants with CCR landfills and 55 plants with CCR impoundments (i.e., 256 of the
495 plants). Overall state regulations were added to 270 plants with CCR landfills and 98 plants with CCR impoundments.
For the 100 plants (i.e., 47 plants with landfills and 53 plants with impoundments) for which there are no data from the three
studies, and no state-regulatory data on controls from Step 1, no controls are assumed under baseline for on-site landfills and
impoundments; this represents a worst case (i.e., high cost) assumption.
The associated data sources and findings for each baseline characterization step are described below.
Step 1: Baseline Installed CCR Disposal Engineering Controls Identified in Prior Industry Surveys (1995, 1996, 2004)
The controls identified through the Step 1 prior studies were more stringent than the state government requirements discussed in Step 2 for:
o Landfills: Voluntary controls for 25 plants with landfills (9% of 227 plants landfills) receiving 6.4 million tons per year (i.e.,
9% of total landfill CCR quantity) in 12 states (some are identified as voluntary because state regulations were not reviewed for
the state): AR, AZ, CA, IA, IN, KS, MD, MN, NE, SD, SI, WV.
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