Analysis - The Institute for Southern Studies

Exhibit 4B
Summary of “Ancillary Cost” Estimates Associated with RCRA Regulation of CCR Disposal
($millions average annualized; 2009$)
State Government
Applicability to Electric Utility RCRA-Authorized
Row Total
Cost
Ancillary Cost Element
CCR Regulatory Options Industry Cost Program Cost
11. Ancillary offsite disposal costs Subtitle C $76.35 $0.63 $76.98
12. Impoundment structural integrity inspections Subtitle C and Subtitle D $0.96 $0.054 $1.01
13. RCRA facility-wide investigations (RFIs) Subtitle C $6.9 $0.7 $7.6
14. RCRA facility-wide corrective action Subtitle C Not estimated –
historical
average cost =
$5.4 million per
facility
Not estimated
Not est.
15. RCRA TSDF waste disposal permits Subtitle C $5.8 $22.3 $28.1
16. RCRA enforcement inspections Subtitle C $0 $0.063 $0.063
17. Future disposal unit failure cleanup
Subtitle C
Not est. – case Not est. – case Not est.
remediation as RCRA hazardous waste
study example study example
18. EPA administrative reporting & recordkeeping
18a. EPA regulated waste notification
18b. RCRA TSDF general facility standards
18c. RCRA haz waste biennial report
18d. CERCLA RQ reporting
Subtitle C Subtotal= $11.13
$0.005
$9.01
$1.45
$0.0042
Subtotal= $1.81
$0.0008
$1.47
$0.24
$0.0007
$12.94
$0.0058
$10.48
$1.69
$0.0049
Column Totals for the three options of the October 2009 draft RIA :
Subtitle C hazardous waste $100.4 $25.6 $126.7
Subtitle D (version 1) $0.96 $0.05 $1.0
Hybrid C&D* $7.9 $7.7 $15.6
* Hybrid C&D costs for ancillary cost items 13, 14, 15, 16, 17, 18 are proportioned only to the 158 plants with impoundments that would be
regulated under Subtitle C for this option, by the proportionate multiplier: (158 plants w/impoundments) / (495 total plants) = 0.319
82