Analysis - The Institute for Southern Studies

Baseline CCR Disposal Cost Estimation
This section presents baseline cost estimates for both onsite and offsite CCR disposal units (i.e., landfills and impoundments) for 467 of the 495
electric utility plants which dispose CCR (CCR from the remainder 28 of the 495 plants is solely beneficially used).
Cost Estimation Framework
Cost calculations: This RIA contains three types of cost estimates (with decreasing relative degrees of expected accuracy):
o Data-based estimates: Based on a landfill and impoundment engineering controls cost estimation model using relatively
robust and recent data inputs (e.g., 2005 or newer) pertaining to CCR quantities and disposal methods for individual
electric utility plants. The cost model was first developed by EPA in 1988 to support EPA’s 1991 final criteria for
municipal solid waste RCRA Subtitle D landfills, and EPA’s 1999 proposed rule cement kiln dust landfill requirements. 45
The cost model consists of two software components; Appendix G to this RIA provides additional details about the
model:
• 1 st of 2 cost model components: Unit Cost Component: The first component is a Fortran computer programmed
cost model which dates back to 1988. This model specifies the various steps and physical units (e.g., square
footage sizes and associated quantities of labor, equipment and materials for the specified sizes) involved in
designing, constructing, operating, and closing a landfill or impoundment. Then it combines the physical
component data inputs, with input data on the prices/ costs/ fees for the physical components to estimate as model
outputs, the capital and annual O&M costs of specified sizes of landfills and impoundments. The unit prices/
costs/fees used as input data include a wide range of items, such as the per-acre cost of land, clearing, excavation,
equipment, labor, bottom liner materials, and cover materials. For this RIA, the model was run multiple times to
generate individual cost estimates for a series of five alternatively-sized CCR landfills and impoundments with
varying types of engineering controls to represent the range of sizes and engineering controls in the population of
495 electric utility plants. The size categories are defined in tons per day of CCR disposed. Each CCR landfill or
45 The 1988 cost model is documented in the “User’s Manual for the Subtitle D Municipal Landfill Cost Model” draft report prepared for EPA’s Office of Solid Waste by
DPRA Inc, Sept 1988, 129 pages which is available from the Federal docket as document ID nr EPA-HQ-RCRA-2006-0796.
EPA previously publicly referenced this cost model in the following six publications: (a) “Draft Regulatory Impact Analysis for Proposed Revisions to Subtitle D
Criteria for Municipal Solid Waste Landfills,” prepared for US EPA Office of Solid Waste by Temple, Barker & Sloane, Inc., ICF Incorporated, Pope-Reid Associates (now
DPRA Inc.) and American Management Systems, Inc., 05 Aug 1988 (this document includes about a 4-page summary of the cost model); (b) “Regulatory Impact Analysis
for the Final Criteria for Municipal Solid Waste Landfills,” prepared for US EPA Office of Solid Waste by Temple, Barker & Sloane/Clayton Environmental Consultants,
ICF Inc, DPRA Inc, and American Management Systems, Inc., Dec 1990 (this document includes about a 4-page summary of the cost model); (c) “Addendum to the
Regulatory Impact Analysis for the Final Criteria for Municipal Solid Waste Landfills,” prepared for US EPA, Office of Solid Waste by Temple, Barker & Sloane/Clayton
Environmental Consultants and ICF Inc, August 1991; (d) “40 CFR Parts 257 and 258 Solid Waste Disposal Facility Criteria: Proposed Rule,” Federal Register, Vol.53,
No.168, pp.33314-33422, 30 Aug 1988; (e) “Revised Criteria for Municipal Solid Waste Landfills,” Federal Register Volume 56, pp. 50978, 09 Oct 1991; (f) “Technical
Background Document: Compliance Cost Estimated for the Proposed Land Management Regulation of Cement Kiln Dust,” prepared for the US EPA, Office of Solid
Waste by DPRA Inc, 10 April 1998.; and (g) “40 CFR Parts 259, 261, 266, and 270 Standards for the Management of Cement Kiln Dust; Proposed Rule,” Federal Register
Vol.64, No.161, pp. 45632-45697, 20 Aug 1999.
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