Analysis - The Institute for Southern Studies

State government average cost per waste disposal permit:
Average cost for state government review of RCRA Subtitle C permits consists of four activities: 68
(1,215 pre-application activities) + ($27,063 application review) + ($26,846 permit issuance) + ($3,110 permit maintenance) =
$58,200 per permit
(149 offsite CCR landfills) x ($58,200 per Subtitle C permit) = $8.67 million
Amortized state cost with a capital recovery factor of 0.07246 (@7% discount rate & 50-years) = $0.63 million/year
Total Subtitle C permit cost (industry + state government) = $2.9 million per year
Total cost for item 11 (11a + 11b + 11c):
Industry share of cost =
State government share of cost =
Total (industry + states) =
$76.35 million per year
$0.63 million per year
$76.98 million per year
12. Regulatory structural integrity inspection cost
Assumptions:
EPA assumed that the residual 18% of the non-inspected plants require inspection over the 82% baseline inspection coverage.
The per-plant cost for inspections is estimated in the Chapter 3 baseline above.
Cost Calculation:
Industry cost: ($10,829/year per facility) x (18% not inspected) x (495 plants) = $0.96 million per year
State government cost: ($599/year per facility) x (18% not inspected) x (495 plants) = $0.054 million per year
Total (industry + state) = $1.01 million per year
13. Regulatory RCRA facility-wide investigation (RFI) cost
Industry RFI cost:
As of 2008, state government corrective action covers 64% of electric utility industry impoundments and 78% of landfills. Thus,
assume that 57 plants with impoundments (i.e., 36% x 158 plants with impoundments) plus 74 plants with landfills (i.e., 22% x 337 plants
with landfills) may require RFIs, for a total of 131 RFIs.
The purpose of an RFI is to obtain information to fully characterize the nature, extent and rate of migration of releases of hazardous
waste or constituents to determine whether interim corrective measures and/or a Corrective Measures Study may be necessary for other
waste units at the facility (source: EPA 530/SW-89-031, May 1989, Vol.I). RFIs may include: rapid field screening using portable field
instruments, drilling in soils, excavating test pits, ground-water monitoring, waste testing, biomonitoring, and site surveying, site
photography, site mapping.
RFI average cost:
$0.75 million average cost for RFIs involving captive industrial landfills
68 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
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