Analysis - The Institute for Southern Studies

impoundment is assumed to operate 300 days per year (average number of operating days for coal-fired boilers
based on 2005 DOE EIA 767 database). The size categories are 10,000, 50,000, 200,000, 500,000 and 2,000,000
tons of CCR per year. Size is the primary determinant of overall cost; however, landfills and impoundments
exhibit increasing returns to scale: the larger the landfill or impoundment, the lower the cost per ton of CCR
managed. The cost equations generated by these unit cost model runs are used as inputs in the second component
of the cost model to compute landfill and impoundment cost curves (equations) based on size for each combination
of engineering controls, so that a unique cost estimate may be assigned to each of the 495 electric utility plants
according to each plant’s unique annual CCR disposal tonnage.
• 2 nd of 2 cost model components: Plant-by-Plant & Aggregate Cost Component: The second component of the
model is an Excel spreadsheet with Visual Basic programming used to estimate unique baseline (i.e., current) and
regulatory option costs for each electric utility plant. The spreadsheet is populated with plant-by-plant data
including plant location, known disposal and beneficial reuse practices, known or estimated baseline engineering
controls on CCR disposal units, annual CCR disposal tonnages, and known or estimated CCR landfill and
impoundment future closure years. The spreadsheet is also populated with the cost equations generated by the first
component of the model for the various engineering controls (e.g., groundwater monitoring and safety inspections)
and for off-site landfill disposal costs. The Visual Basic programming is used for this RIA to estimate engineering
control costs for both the (a) baseline and (b) regulatory options for each plant over a 50-year future period-ofanalysis
(i.e., 2012 to 2061). The plant-by-plant estimated costs are then aggregated in this second component of
the model on an average annualized basis.
o Assumption-based estimates: These are based on relatively limited data, and/or older data (e.g., older than 2005), or metaanalysis
transfer of results from other studies, or data from case studies, or based mostly on professional judgment
assumptions rather than data, for some of the major factors used in cost calculations.
o Scenario-based estimates: These are applied in absence of data, case studies, or assumptions for purpose of illustrating
potential lower- and upper-bound costs (i.e., bounding estimates). EPA defines “scenarios” as qualitative projections of
possible future conditions based on variations in key drivers of change, including social, technological, economic and
institutional drivers. Scenario construction is a futures analysis method; as such, scenario-based estimates do not strive to
predict the future with absolute certainty, but to explore uncertainties, possible consequences, and possible outcomes. 46
2009 price level: Costs are normalized to beginning-of-year 2009 dollars using inflation factors developed by Engineering News-
Record (ENR) Construction Cost Index, and using regional cost adjustment factors applied to each plant cost
estimate involving on-site construction. These regional factors account for the variability between states in site work
and landscape construction costs. Cost adjustment factors are derived from the Means Building Construction Costs
Year 2003 city factors. All the cities for each state were averaged together to derive a state average.
46 “Source: EPA Office of Science Policy, “Shaping Our Environmental Future: Foresight in the Office of Research & Development,” report nr. EPA 600/R-06/150, 2006
at: http://www.epa.gov/osp/futures/FuturesHandbook.pdf
52