Analysis - The Institute for Southern Studies

power plant location, using commercial landfill tipping fees ($2009) for contaminated soil, which range widely from $11 per-ton to
$135 per-ton, with a national average of $50 per-ton. For example, commercial landfill tipping fees for contaminated soil for some of
the high coal usage states are: TN = $11.19/ton, IN = $32.73/ton, OH = $35.48/ton, and PA = $57.96/ton. The baseline cost
estimation method of this RIA then added a CCR offsite transportation and loading cost of approximately $33 per-ton based on the
RACER cost estimation tool. For the estimated 15.0 million tons per-year of CCR disposed in offsite landfills, the estimated baseline
cost is $1,193 million per-year, which is equivalent to $79.53 per-ton over the 50-year time period of the RIA cost analysis which
assumes increasing coal usage (0.73% per-year) by electric utilities and subsequent offsite landfill disposal over the 50 year time
period. It is unknown what cost elements are included in the high-end of the ACAA reported cost range (e.g., transportation cost
and/or landfill tipping fee cost). In addition, electric utility companies likely have annual or multi-year contracts with offsite landfill
operators that offer lower tipping fees than the state-average off-site contaminated soil tipping fees used in this RIA.
o Validity Test #2 of 2: Comparison to CCR Disposal Costs Contained in the EIA Form 767 Database
The 2005 Energy Information Administration (EIA) Form 767 database (Schedule 3, Part B) indicates $5,890 million in annual capital and
O&M cost reported by steam electric plants with nameplate capacity of 100 MW or greater, including (a) $0.314 million per year for water
pollution controls, (b) $0.193 million per year for solid waste disposal, (c) $0.185 million per year for other pollution controls, (d) $3,627
million per year capital expense for air pollution abatement, and (e) $1,546 million per year for collection and disposal O&M costs for fly ash,
bottom ash, and FGD. This last cost element --- $1,546 million per year for CCR disposal --- is only 28% of the $5,556 million per year
estimate displayed in Exhibit 3L above. However, the 2005 EIA Form 767 cost data are associated with only 179 coal-fired electric utility
plants, which represent only 36% of the 495 coal-fired electric utility plants addressed by this RIA. Therefore, to facilitate a direct comparison,
the $1,546 million per year cost from the data in EIA Form 767 may be extrapolated to all 495 plants by multiplying by the factor 2.765 (i.e.,
495 / 179), which produces an estimated extrapolated cost for all 495 plants of $4,275 million per year (i.e., 2.765 x $1,546 million per year).
This extrapolated cost is 23% lower than the $5,556 million per year baseline cost estimated in this RIA. This comparison suggests the
baseline cost estimated in this RIA may be an over-estimate, but it is not clear whether the cost data in the EIA Form 767 database include
baseline costs to the electric utility plants for compliance with existing state government regulations concerning CCR disposal (e.g., the
annualized cost for obtaining and maintaining state government disposal permits and the annualized cost for impoundment structural integrity
inspections), as does this RIA.
66