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13. Baseline RCRA facility-wide investigations (RFI) Baseline cost assumed to be $0 because this RIA assumes that all baseline CCR disposal units used by electric utility plants are not regulated under RCRA Subtitle C. 14. Baseline facility-wide corrective action Because CCR is not regulated as Subtitle C hazardous waste, there are no existing facility-wide (i.e., CCR disposal units plus other waste units also located at the same plant) corrective action requirements, although some state governments have the following unit-specific corrective action requirements affecting CCR disposal units. State regulations for the top 25 coal usage states (for electricity) were reviewed for correction action requirements in 2000. These regulations were not updated as part of this RIA. Corrective action requirements were identified in 21 of the 25 states. Surface impoundments: 71% of CCR impoundments representing 67% of CCR impoundment annual tonnage have state government baseline corrective action requirements: o AZ, IN, and IA establish a corrective action alert level and response action in site-specific state permits o CO requires corrective action for new units o 9 states (FL, GA, KY, MI, NC, ND, PA, UT, WI) require corrective action o IL, MN, TX, WV, WY do not allow groundwater degradation, but specific enforcement mechanisms are not specified in state regulations o MO requires corrective action for units closed with waste in place, otherwise, corrective action may be established under a permit o NM requires an abatement plan. Landfills: 66% of CCR landfills with 81% of CCR landfill annual tonnage have state government corrective action requirements: o AZ establishes corrective action alert level and response action in site-specific state permits o 15 states (CO, FL, GA, IL, KY, MI, NC, ND, OH, OK, PA, UT, WV, WI, WY) require corrective action o MN, TX do not allow groundwater degradation, but, specific enforcement mechanisms are not specified in state regulations o MO, TN require assessment only o NM requires an abatement plan 15. Baseline waste disposal permit cost Assumptions: o 93% of CCR landfills have a state government non-hazardous waste disposal permit and 12% of CCR impoundments have such permits. Source: page 28, Table 9 of “Coal Combustion Waste Management at Landfills and Surface Impoundments, 1994-2004”, August 2006 at http://www.ead.anl.gov/pub/dsp_detail.cfm?PubID=2008 Industry waste disposal permit cost: o ($5,000 RCRA Part A permit) + ($50,000 RCRA general facility permit requirements) + ($25,000 average RCRA Part B for impoundment or landfill) = $80,000 per Subtitle C permit o Assume RCRA Subtitle D (40 CFR 257, 258) waste permitting activities are less burdensome than RCRA Subtitle C waste permits. Based on factor of 3.3 times more technical standards listed in RCRA Subtitle C (40 CFR 264/265, 268, 270) compared to Subtitle D (40 CFR 257, 258), assume Subtitle D permitting costs are lower by the 3.3 factor: 62
($80,000 per year average Subtitle C waste disposal permit cost) / (3.3) = $24,300 per non-haz waste disposal permit [((93% landfills w/permit) x (337 landfills)) + ((12% impoundments w/permit) x (158 impoundments))] x ($24,300 per permit) = $8.1 million Amortized industry cost with a capital recovery factor of 0.07246 (@7% discount rate & 50-years) = $0.59 million/year State government waste disposal permit cost: o Build estimate based on the following four RCRA Subtitle C permit-related state government activities associated with RCRA Subtitle C waste disposal permits: 51 (1,215 pre-application activities) + ($27,063 application review) + ($26,846 permit issuance) + ($3,110 permit maintenance) = $58,200 average cost per Subtitle C waste disposal permit. o Assume RCRA Subtitle D (40 CFR 257, 258) waste permitting activities are less burdensome than RCRA Subtitle C waste permits. Based on factor of 3.3 times more technical standards listed in RCRA Subtitle C (40 CFR 264/265, 268, 270) compared to Subtitle D (40 CFR 257, 258), assume Subtitle D permitting costs are lower by the 3.3 factor: ($58,200 per year average Subtitle C waste disposal permit cost) / (3.3) = $17,600 per non-haz waste disposal permit o State Cost Calculation: [((93% landfills w/permit) x (337 landfills)) + ((12% impoundments w/permit) x (158 impoundments))] x ($17,600 per permit) = $5.85 million Amortized state cost with a capital recovery factor of 0.07246 (@7% discount rate & 50-years) = $0.42 million/year Total baseline permit cost (industry + state government) = $1.01 million per year 16. Baseline enforcement inspection Not estimated in this RIA. 17. Baseline remediation of environmental releases Not estimated in this RIA. 51 Source: Based on cost data from page 84 of January 2007 ASTSWMO report “State RCRA Subtitle C Core Hazardous Waste Management Program Implementation Costs Final Report” at: http://www.astswmo.org/files/publications/hazardouswaste/Final%20Report%20-%20RCRA%20Subtitle%20C%20Core%20Project.pdf 63
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Regulatory Impact Analysis For EPA
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Table of Contents Executive Summary
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Executive Summary This RIA evaluate
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impoundments, the relative number t
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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: Exhibit 3K Summary of Industry & St
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
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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
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Exhibit 7M List of 74 Coal-Fired El
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Analysis - The Institute for Southern Studies

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