Analysis - The Institute for Southern Studies

o Impoundment berms: The average surface impoundment size for existing units in the cost model is 343 acres. Assuming a
square impoundment and that the berm would be constructed on three sides of the impoundment the average berm length is 11,594
feet. Therefore, the cost to construct a berm around an average-size impoundment is $4.3 million. 64
o Landfill berms: Similarly, the average landfill size for existing units in the cost model is 278 acres. Assuming a square landfill
and that the berm would be constructed on three sides of the landfill (leaving one side open for truck access), the average berm
length is 10,447 feet, and the cost to construct a berm surrounding an average-size landfill is $3.9 million.
Using the 3-mile buffer karst zone finding of 177 plants, the potential cost for constructing berms at those plants plus future plants is:
o Existing units: ($4.1 million average berm cost) x (177 disposal units) = $726 million total cost
Amortized with a capital recovery factor of 0.07246 (@7% discount rate & 50-years) = $53 million/year equivalent
o New units: Apply 0.73% average annual growth rate in future CCR generation (cited elsewhere in this RIA) to estimate the count
of future new or expanded disposal units over 50-years, and assume 36% (i.e., 177/495) will need berms:
(495 existing disposal units) x (1.0073% growth rate)^(50 years) = 712 existing plus new units over 50-years
(712 units over 50-years) – (495 existing units) = 217 future new disposal units
(217 future new units) x (36% needing berms) x ($4.1 million average berm cost) = $318 million total cost
Amortized with a capital recovery factor of 0.07246 (@7% discount rate & 50-years) = $23 million/year equivalent
Average annualized berm cost for existing + new units = $76 million/year equivalent
8. Regulatory closure cost
Same cost estimation formula applied above in Chapter 3 for baseline cost estimation.
9. Regulatory post-closure monitoring cost
Same cost estimation formula applied above in Chapter 3 for baseline cost estimation.
10. Storage design and operating standards for tanks, containers, and containment buildings
Not estimated in this RIA due to lack of baseline information about the count and condition of these units at electric utility plants
4B.2 Ancillary Regulatory Requirement Costs
For estimating most of the “Other Ancillary Costs” in this section, this RIA distinguishes between RCRA Subtitle C and RCRA Subtitle D
requirements according to the respective basis of each regulatory option, as well as between costs to electric utility plants and costs to state
government RCRA-authorized regulatory programs.
64 For purpose of comparison to the $4.3 million (per impoundment) and $3.9 million (per landfill) location restriction mitigation cost estimates above, in 2005 the TVA
estimated an “assumed” cost of $500,000 for karst mitigation and $250,000 for floodplain mitigation for a potential new CCR disposal site involving 1,300 linear feet for
mitigation. Extrapolation of TVA’s $750,000 cost estimate to 11,594 feet (impoundment) yields $6.7 million (i.e., (11,594 feet / 1,300 feet) x ($750,000)), and to 10,447
feet (landfill) yields $6.0 million (i.e., 10,447 feet / 1,300 feet) x ($750,000)). Source for TVA cost estimate: page 10 of “Kingston Fossil Plant Decision Matrix: Pond or
Peninsula?”, 27 January 2005 Plant Managers Conference, http://www.tva.gov/kingston/tdec/pdf/TVA-00007487.pdf
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