Analysis - The Institute for Southern Studies

More documents

Recommendations

Info

ES-2: Benefits of Avoided Future Groundwater Contamination (Human Health & Avoided Remediation Costs) By establishing management and permit standards for CCR disposal units under RCRA, the proposed regulatory options will reduce uncontrolled releases and cancer risks, and improve detection and, if necessary, response to future groundwater contamination. This RIA quantifies two components of groundwater protection benefits: (a) human cancer risks avoided from drinking contaminated groundwater, and (b) groundwater contamination remediation costs avoided. Summary Exhibit 1 below presents the monetized results of this evaluation. Estimate of avoided human cancer risks from avoided future groundwater contamination by CCR disposal units: o Individual skin cancer risks avoided (by eliminating the groundwater pathway for arsenic at CCR impoundments) are estimated up to 2 x 10 -2 (i.e., a probability equal to 2 individual human skin cancer incidence risks for every 100 persons exposed) using the current IRIS skin cancer slope factor for arsenic. o 30,400 people use drinking water wells within one mile of coal-fired electric utility plants; of which 8,150 (27%) are children. o Taking into account current CCR disposal unit designs, an estimated 145 (using the IRIS cancer slope factor) to 2,509 (using the NRC lung and bladder cancer slope factor 1 ) future human cancer risks are expected to occur in absence of the proposed RCRA regulation, based on drinking water exposure to arsenic in CCR. Other human health risks from CCR disposal units not quantified in this RIA: o Human non-cancer risks, including from selenium, cobalt, nitrate/nitrite, and molybdenum, which may be released to groundwater at levels above the MCL or 3 times the human hazard quotient (HQ). o Cancer and non-cancer risks from arsenic and other metals released in effluent from CCR impoundments to surface waters. Summary Exhibit 1 Future Avoided Human Cancer Risks & Avoided Groundwater Remediation Cost Benefits ($millions present value @7% discount rate over 50-years) Groundwater Protection Benefit Category Subtitle C Subtitle D special waste (version 2) Subtitle “D prime” Groundwater Remediation Costs Avoided $466 $168 $84 Monetized Value of Cancer Risks Avoided $504 $207 $104 Total = $970 $375 $188 ES-3: Benefits of Avoided Future CCR Impoundment Structural Failures (Avoided Cleanup Costs) This RIA estimated future avoided cleanup costs from catastrophic impoundment failures, like the one that occurred at TVA’s Kingston TN coal-fired electricity plant in December 2008, which would be prevented under the proposed rule. Given the increasing age of CCR 1 EPA calculated a new cancer slope factor for arsenic from data in the National Research Council report “Arsenic in Drinking Water: 2001 Update” at http://www.nap.edu/openbook.php?isbn=0309076293 6
impoundments, the relative number that present high or significant hazard potential, and the history of CCR impoundment failures to date, this RIA presents three alternative scenarios of future catastrophic failures, the result for which are displayed in Summary Exhibit 2 below: Failure Scenario #1: Extrapolation of future CCR impoundment failure probability based on the relative (a) recent historical occurrence frequency, (b) CCR quantity release magnitude, and (c) cleanup costs, associated with three recent (2005, 2008, 2009) CCR impoundment failures which exceeded 1 million gallons in release quantity each. Failure Scenario #2: Assumes 10% of CCR impoundments in the high failure risk group (i.e., above 40 feet tall and over 25 years old) fail over the next 20 years in absence of RCRA regulation. 2 Failure Scenario #3: Assumes 20% of CCR impoundments in the high failure risk group (i.e., above 40 feet tall and over 25 years old) fail over the next 20 years in absence of RCRA regulation. Summary Exhibit 2 Avoided Future CCR Impoundment Catastrophic Failure Cleanup Costs ($millions present value @7% discount rate) Impoundment Failure Scenarios Failure Scenario #1: Extrapolation of three recent (2005, 2008, 2009) CCR impoundment failure events Failure scenario #2: Assuming 10% of 96 high-risk impoundments fail Failure Scenario #3: Assuming 20% of 96 high-risk impoundments fail Subtitle C special waste Subtitle D (version 2) Subtitle “D prime” $5,285 $2,378 $1,216 $8,366 $3,795 $1,897 $16,732 $7,590 $3,795 The proposed regulation has categories of other benefits from avoiding future CCR impoundment structural failures which this RIA did not quantify and monetize, including potential avoided costs associated with a few possible benefit categories: 1. Litigation costs: Avoided litigation and related costs associated with such damage events. 2. Riparian damages: Reduction of toxic chemical contaminated effluent discharges from CCR impoundments to surface waters (i.e., rivers and lakes) through future phase-out of surface impoundments. 3 3. Non-cancer health risks: Reduction in human health risks from future reduction in human exposure to non-carcinogenic but otherwise toxic chemicals contained in CCR, such as selenium, cobalt, nitrate/nitrite, and molybdenum, which, as currently managed in CCR 2 Based on the responses to our CERCLA 104(e) information requests to utilities with impoundments, there are 96 impoundments that meet these criteria. However, this RIA estimates that 16 of these impoundments have closed or are expected to close before the CCR rule is finalized and goes into effect. Therefore, this analysis removed these 16 impoundments and based the estimated future impoundment failure cleanup costs on a subset of 80 CCR impoundments meeting the ‘at risk’ criterion. 3 EPA is developing a regulatory proposal under the Clean Water Act to revise the current effluent guidelines for steam electric utilities. Current guidelines only control pH, total chlorine, and total suspended solids (TSS). EPA’s proposed CCR rule would eliminate CCR surface impoundments, eliminating much of the risk that would be addressed under revisions to the effluent guidelines, including risks posed by arsenic, selenium, mercury, cadmium, copper, chromium, and nickel. 7
Page 1 and 2: Regulatory Impact Analysis For EPA
Page 3 and 4: Table of Contents Executive Summary
Page 5: Executive Summary This RIA evaluate
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”
Page 57 and 58:
assume that the same water trucks w
Page 59 and 60:
memorandum to George Garland, EPA,
Page 61 and 62:
Exhibit 3K Summary of Industry & St
Page 63 and 64:
($80,000 per year average Subtitle
Page 65 and 66:
Validity Check of Baseline Cost Est
Page 67 and 68:
Chapter 4 Estimated Cost for RCRA R
Page 69 and 70:
B. Ancillary costs for CCR disposal
Page 71 and 72:
location restriction mitigation inv
Page 73 and 74:
o Impoundment berms: The average su
Page 75 and 76:
State government average cost per w
Page 77 and 78:
corrective action remedies usually
Page 79 and 80:
Exhibit 4A Two Case Studies: Possib
Page 81 and 82:
Biennial Report”). According to E
Page 83 and 84:
4B.3 Land Disposal Restriction Cost
Page 85 and 86:
The TVA cost study did not estimate
Page 87 and 88:
Using the EPA ORCR 2009$ updated un
Page 89 and 90:
Exhibit 4D Comparison of Annual O&M
Page 91 and 92:
Exhibit 4E Summary of Wet Conversio
Page 93 and 94:
o Recent Trend in CCR Impoundment P
Page 95 and 96:
from coal to other fuels such as na
Page 97 and 98:
o Result of Dry Conversion Cost Upd
Page 99 and 100:
As summarized below in comparison t
Page 101 and 102:
17% phase-out trend suggest the fut
Page 103 and 104:
RIA 50- ye ar period Actual company
Page 105 and 106:
4C. State-by-State Distribution of
Page 107 and 108:
4D. Cost Estimation Uncertainty Thi
Page 109 and 110:
Exhibit 4N Cost Estimation Uncertai
Page 111 and 112:
In contrast to the Exhibit 5A list
Page 113 and 114:
Step 2. Determine Potentially Affec
Page 115 and 116:
Step 3. Apply EPA-ORCR 2009 Arsenic
Page 117 and 118:
RISKn WELLREACH iRISK EDn N Where
Page 119 and 120:
The constant slope allowed estimati
Page 121 and 122:
Step 6. Monetize Future Avoided Can
Page 123 and 124:
controls like surface-impoundment p
Page 125 and 126:
Finally, for Subtitle C, there woul
Page 127 and 128:
Exhibit 5A-12 Percentile of Cleanup
Page 129 and 130:
Exhibit 5A-16 Per-Site Groundwater
Page 131 and 132:
Multiple CCR disposal units at a si
Page 133 and 134:
5B. Benefit of Preventing Future CC
Page 135 and 136:
As displayed below in Exhibit 5B-2,
Page 137 and 138:
Where: = Observed arrival rate (0.
Page 139 and 140:
Step 3. Calculate Future Impoundmen
Page 141 and 142:
some surface impoundment regulation
Page 143 and 144:
Exhibit 5B-8 Poisson Distribution (
Page 145 and 146:
With these new distributions, EPA p
Page 147 and 148:
Exhibit 5B-12 Scenario #2: Cleanup
Page 149 and 150:
5C. Induced Effect of RCRA Regulati
Page 151 and 152:
Exhibit 5C-1 Estimate of Annual Mat
Page 153 and 154:
Exhibit 5C-3 below presents a 2004
Page 155 and 156:
To avoid double-counting of economi
Page 157 and 158:
5C2. Potential Effect of RCRA Regul
Page 159 and 160:
Others take a different view on how
Page 161 and 162:
Exhibit 5C-7 EPA Extrapolation of E
Page 163 and 164:
Based on the most recent CCR benefi
Page 165 and 166:
Beneficial uses of CCR have been co
Page 167 and 168:
Exhibit 5C-12 Beneficial Use Trend
Page 169 and 170:
Increases due to increased disposal
Page 171 and 172:
“Using [coal] fly ash in building
Page 173 and 174:
Exhibit 5C-14 Historical Annual Per
Page 175 and 176:
Hypothetical expansion of CCR custo
Page 177 and 178:
Step 6: Apply Estimated Induced Eff
Page 179 and 180:
Exhibit 5C-16 Scenario #1: Increase
Page 181 and 182:
Exhibit 5C-17 Scenario #2: Decrease
Page 183 and 184:
Exhibit 5C-18 Beneficial Use Trends
Page 185 and 186:
Exhibit 5C-19 Scenario #1: Benefit
Page 187 and 188:
Exhibit 5C-21 Scenario #2: Cost of
Page 189 and 190:
Step 10: Quantify Potential Capacit
Page 191 and 192:
Chapter 6 Comparison of Regulatory
Page 193 and 194:
Exhibit 6B Comparison of Regulatory
Page 195 and 196:
Exhibit 6D Comparison of Regulatory
Page 197 and 198:
Exhibit 6F Comparison of Regulatory
Page 199 and 200:
Exhibit 6F Scaling Factors (Extrapo
Page 201 and 202:
Exhibit 6G Estimate of Subtitle D (
Page 203 and 204:
detect contamination early and thus
Page 205 and 206:
Step 1: Downloaded the annual milli
Page 207 and 208:
Exhibit 7A State by State Breakout
Page 209 and 210:
Small government: Based on the RFA/
Page 211 and 212:
Step 3 & Step 4: Determine and docu
Page 213 and 214:
Factor #2 of 2: The small business
Page 215 and 216:
how much they use or indeed how muc
Page 217 and 218:
Collection of Minority & Low-Income
Page 219 and 220:
Comparison of Minority & Low-Income
Page 221 and 222:
Exhibit 7G Minority and Low-Income
Page 223 and 224:
Exhibit 7H Comparison of Minority a
Page 225 and 226:
o The state-by-state range of minor
Page 227 and 228:
CCR fraction #3: CCR fraction #4:
Page 229 and 230:
7D. Child Population Statistics (Ex
Page 231 and 232:
Comparison of Child Populations Liv
Page 233 and 234:
Count of plant unique ZCTAds Exhibi
Page 235 and 236:
Exhibit 7K Comparison of Child Popu
Page 237 and 238:
7E. Unfunded Mandates (UMRA) & Fede
Page 239 and 240:
Findings for UMRA Impact and Federa
Page 241 and 242:
Exhibit 7M List of 74 Coal-Fired El
show all

Analysis - The Institute for Southern Studies

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?