Analysis - The Institute for Southern Studies

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Table of Appendices Note: Because of its large number of pages (>400 pages), the Appendix is provided as a separate companion document to this RIA. Appendix A Chronology of EPA’s Regulatory Evaluation of CCR (1978 to March 2009) Appendix B List of Other Industries with Coal-Fired Electricity Plants Not Covered by the Proposed Rule or this RIA Appendix C List of 495 Operating Electric Utility Plants Potentially Affected by the CCR Rulemaking (2007) Appendix D Identity of 200 Entities Which Own the 495 Potentially Affected Electric Utility Plants (2007) Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K Baseline State Government Regulatory Requirements for CCR Disposal Units in Top-34 Coal Utility States Baseline Engineering Controls Installed at CCR Disposal Units in the Electric Utility Industry Description of CCR Landfill & Surface Impoundment Engineering Control Cost Model Baseline Cost Estimates for CCR Disposal by the Electric Utility Industry Geological Conditions at Electric Utility Industry CCR Disposal Unit Locations Incremental Regulatory Cost Estimates for Compliance with the CCR Proposed Rule Regulatory Options Appendices Supporting the Regulatory Benefits Evaluation Appendix L Electricity Price Impact Analysis Spreadsheet (Executive Order 13211) Appendix M Small Entity Impact Data & Analysis Spreadsheet (RFA/SBREFA) Appendix N Minority & Low-Income Population Data (Executive Order 12898) Appendix O Child Population Data (Executive Order 13045) Appendix P Appendix Q UMRA Written Statement Documentation for EPA’s Social Cost Estimate Assigned to the TVA Kingston 2008 CCR Impoundment Failure Event 4
Executive Summary This RIA evaluates the expected regulatory compliance costs, economic and environmental benefits, and potential impact on CCR beneficial use, of EPA’s proposed regulation of coal combustion residual (CCR) disposal by coal-fired electric utility plants. The CCR disposal regulatory options evaluated in this RIA are based on EPA’s statutory authority contained in the 1976 Resource Conservation and Recovery Act (RCRA). The main findings of this RIA are summarized below according to six sections: ES-1: ES-2: ES-3: ES-4: ES-5: ES-6: Regulatory Options Evaluated in this RIA Benefits of Avoided Future Groundwater Contamination (Human Health Protection & Avoided Remediation Costs) Benefits of Avoided Future CCR Impoundment Structural Failures (Avoided Cleanup Costs) Economic and Environmental Benefits from Future Increase in CCR Beneficial Uses by Other Industries Regulatory Compliance Costs Comparison of Regulatory Benefits to Costs ES-1: Regulatory Options Evaluated in this RIA This RIA evaluates three options for RCRA regulation of CCR disposal at coal-fired electric utility plants. All options (a) maintain the existing Bevill regulatory exclusion for CCR beneficial uses, and (b) propose the same set of 10 custom-tailored engineering controls (i.e., technical design and operating standards) for CCR disposal units: 1. Subtitle C “Special Waste” Option: Regulate CCR landfills and impoundments as a “special waste” under Subtitle C requirements, and would require phase out of impoundments within five years. 2. Subtitle D Option (version 2): Composite liners required for all (i.e., existing and future new) CCR impoundments but only for new landfills. For any CCR landfills and impoundments that closed before the effective date, there would be no regulatory controls over those units, unless the states choose to adopt controls over such units. Also, all surface impoundments (existing and new) would need to have composite liners within 5-years of the effective date. 3. Subtitle “D prime” Option: Composite liners required only for new impoundments and landfills; unlined units could continue to operate. This approach would be the same as the Subtitle D option above, except that existing impoundments would not be required to retrofit and install a composite liner, or close. 5
Page 1 and 2: Regulatory Impact Analysis For EPA
Page 3: Table of Contents Executive Summary
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 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”
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assume that the same water trucks w
Page 59 and 60:
memorandum to George Garland, EPA,
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Exhibit 3K Summary of Industry & St
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($80,000 per year average Subtitle
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Validity Check of Baseline Cost Est
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Chapter 4 Estimated Cost for RCRA R
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B. Ancillary costs for CCR disposal
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location restriction mitigation inv
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o Impoundment berms: The average su
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State government average cost per w
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corrective action remedies usually
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Exhibit 4A Two Case Studies: Possib
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Biennial Report”). According to E
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4B.3 Land Disposal Restriction Cost
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The TVA cost study did not estimate
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Using the EPA ORCR 2009$ updated un
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Exhibit 4D Comparison of Annual O&M
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Exhibit 4E Summary of Wet Conversio
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o Recent Trend in CCR Impoundment P
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from coal to other fuels such as na
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o Result of Dry Conversion Cost Upd
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As summarized below in comparison t
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17% phase-out trend suggest the fut
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RIA 50- ye ar period Actual company
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4C. State-by-State Distribution of
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4D. Cost Estimation Uncertainty Thi
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Exhibit 4N Cost Estimation Uncertai
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In contrast to the Exhibit 5A list
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Step 2. Determine Potentially Affec
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Step 3. Apply EPA-ORCR 2009 Arsenic
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RISKn WELLREACH iRISK EDn N Where
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The constant slope allowed estimati
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Step 6. Monetize Future Avoided Can
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controls like surface-impoundment p
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Finally, for Subtitle C, there woul
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Exhibit 5A-12 Percentile of Cleanup
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Exhibit 5A-16 Per-Site Groundwater
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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.
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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
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Exhibit 5B-12 Scenario #2: Cleanup
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5C. Induced Effect of RCRA Regulati
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Exhibit 5C-1 Estimate of Annual Mat
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Exhibit 5C-3 below presents a 2004
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To avoid double-counting of economi
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5C2. Potential Effect of RCRA Regul
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Others take a different view on how
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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
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“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
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Exhibit 5C-17 Scenario #2: Decrease
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Exhibit 5C-18 Beneficial Use Trends
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Exhibit 5C-19 Scenario #1: Benefit
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Exhibit 5C-21 Scenario #2: Cost of
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Step 10: Quantify Potential Capacit
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Chapter 6 Comparison of Regulatory
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Exhibit 6B Comparison of Regulatory
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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 (
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detect contamination early and thus
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Step 1: Downloaded the annual milli
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Exhibit 7A State by State Breakout
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Small government: Based on the RFA/
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Step 3 & Step 4: Determine and docu
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Factor #2 of 2: The small business
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how much they use or indeed how muc
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Collection of Minority & Low-Income
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Comparison of Minority & Low-Income
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Exhibit 7G Minority and Low-Income
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Exhibit 7H Comparison of Minority a
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o The state-by-state range of minor
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CCR fraction #3: CCR fraction #4:
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7D. Child Population Statistics (Ex
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Comparison of Child Populations Liv
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Count of plant unique ZCTAds Exhibi
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Exhibit 7K Comparison of Child Popu
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7E. Unfunded Mandates (UMRA) & Fede
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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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