Analysis - The Institute for Southern Studies

oad and refill the truck, is approximately 2.5 times that of the average hourly daytime evaporation rate. Therefore, water spray on roads will be
required 3 times per day. The water volume sprayed per road area is estimated as follows:
Water per Area = (1.5 mi)(5,280 ft/mi)(0.3048 m/ft)(10 m)(5,000 gal)(3.785 L/gal) = 0.784 L/m2
The time required for the water truck to be filled, spray along both sides of the road, and return for refilling is estimated as follows:
Time =
(1 hour) + (3 miles)/(10 miles/hour) = 1.3 hour
Therefore, the total time for one pass is assumed to be 1 hour and 15 minutes. The average rate of water spray is estimated as follows:
Spray Rate = (0.784 L/m2)(1,000 ml/L)(cm3/ml)(1,000 mm/m) = 0.6272 mm/hr
(100 cm/m)3(1.25 hr)
The average hourly daytime evaporation rate is approximately 0.25 mm/hr. Therefore, the water spray rate is approximately 2.5 times the
evaporation rate. Since the total time required for water spray (1.25 hour) times 2.5 is approximately 3, a model assumption is that water spray
on roads is required approximately every 3 hours. In order to coordinate the water truck use for road spray and ash compaction, it is assumed
that the truck alternates between these two requirements during the day. Therefore, over a nine-hour day (eight working hours plus one hour for
lunch), roads are sprayed 3 times, requiring a total of approximately 4 hours, or 50% of the operational day. Because it is assumed that FFC
facilities currently spray water on roads for dust control, the incremental cost from the baseline to the compliance scenarios is zero.
5. Baseline rain and surface water run-on/run-off controls (landfills only)
The cost estimates assume that stormwater run-on/run-off control is comprised of a ditch surrounding active area of landfill and an excavated
bermed basin for water collection.
6. Baseline financial assurance for CCR disposal unit closure and post-closure care
Financial assurance helps assure that the owners and operators of CCR landfills and impoundments have adequately planned for the future cost
of closure, post-closure care, and corrective action for known releases, and to assure that adequate funds will be available when needed to cover
these costs if the owner or operator is unwilling or unable to do so. Financial assurance helps protect future generations from paying for
damages caused by or the prevention of damages potentially created from current waste management activities. Requiring provision of
financial assurance during operation of landfills and impoundments places the cost burden on the current owner and consumer, and prevents
costs from being passed from the current generation to future generations.
The cost estimate includes the costs for selecting a financial mechanism, establishing a financial test, and establishing a letter of credit.
The differences between RCRA Subtitle C and Subtitle D financial assurance mechanisms are not assessed. This RIA assumes the same
requirements for both landfills and impoundments:
Capital cost includes selection of financial assurance mechanism, establishment of financial test, and establishment of letter of credit.
The letter of credit is assumed to be most available to utilities and will be utilized in most circumstances. This is amortized in the annual
cost.
Annual cost includes maintenance of financial test and maintenance of letter of credit. Establishment and annual maintenance of the
letter of credit is estimated to be 1% to 3% of the nominal value of the letter of credit (i.e., total cost of closure and post closure). This RIA
applied the 2% midpoint of this range. Implementation costs are estimated on the assumption that an outside consulting firm and legal
assistance will assist in obtaining and maintaining the letter of credit ($692 per year in 1995 dollars or $1,051 per year inflated to 2009
dollars). Estimate obtained from Mohammad Iqbal and John Collier, ICF, Inc., “Local Government Financial Test Economic Analysis,”
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