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Exhibit 4H Lists of Coal-Fired Electric Utility Plants With Active CCR Impoundments (as of 2005) Which are Either Voluntarily Planning to Convert to Dry Disposal or Voluntarily Planning to Close or Switch Away from Coal to Another Fuel Source (e.g., Natural Gas) Coal-Fired Electric Utility Plants Closing Plants With CCR Impoundments Soon Converting to Dry Disposal* or Switching Away From Coal Fuel with CCR Impoundments** A B C D E F G H Company Name Plant Name State 2005 CCR Pond Tons (1,000s)** * Company Name Plant Name State 2005 CCR Pond Tons (1,000s)*** 1. PSI Energy Inc (Duke Energy) Cayuga IN 210.9 1. Progress Energy Cape Fear NC 101.3 2. PSI Energy Inc (Duke Energy) Edwardsport IN 11.5 2. Progress Energy Lee NC 106.1 3. PSI Energy Inc (Duke Energy) R Gallagher IN 125.6 3. Progress Energy L V Sutton NC 166.0 4. PSI Energy Inc (Duke Energy) Wabash River IN 192.1 4. Progress Energy W H Weatherspoon NC 47.0 5. PSI Energy Inc (Duke Energy) Gibson IN 897.8 5. Duke Energy Company Buck NC 121.9 6. Tennessee Valley Authority Colbert TN 29.2 6. Duke Energy Company Dan River NC 28.5 7. Tennessee Valley Authority Widows Creek TN 852.8 7. Northern States (Xcel Energy) High Bridge MN 0.01 8. Tennessee Valley Authority Paradise TN 517.9 8. Northern States (Xcel Energy) Riverside MN 6.7 9. Tennessee Valley Authority Shawnee TN 61.1 10. Tennessee Valley Authority Bull Run TN 22.4 11. Tennessee Valley Authority Gallatin TN 180.5 12. Tennessee Valley Authority John Sevier TN 10.0 13. Tennessee Valley Authority Johnsonville TN 53.7 14. Tennessee Valley Authority Kingston TN 325.9 15. Southern Indiana Gas & F B Culley IN 35.6 Electric Company (Vectren) 16. Southern Indiana Gas & A B Brown IN 165.8 Electric Company (Vectren) 17. Hoosier Energy R E C Inc Frank E Ratts IN 39.8 18. Westar Energy Jeffrey Energy KS 184.1 Center Subtotal impoundment tons for 18 plants listed above = 3,916.7 Subtotal for 8 plants listed above = 577.51 % of 22.4 million tons 2005 wet disposal tonnage by 158 plants = 17% % of 22.4 million tons 2005 wet disposal tonnage by 158 plants = 3% Notes: * EPA-ORCR identified the 18 plants with recent plans to convert from wet to dry CCR landfill disposal for electric utility plants operated by the Duke Energy Company, the Vectren Company, and the Hoosier Electric Cooperative, from the 24 October 2009 news report by Mark Wilson of the Courier Press “Coal Ash Disposal Varies From Company to Company.” . The Westar Energy plant was identified by an EPA-ORCR staff person based on knowledge of that specific plant or company. ** EPA identified the 8 plants switching from coal from SourceWatch websites: http://www.sourcewatch.org/index.php?title=Coal_plant_conversion_projects and http://www.sourcewatch.org/index.php?title=Existing_U.S._Coal_Plants *** Source: Based on the 2005 DOE-EIA data. 96
o Result of Dry Conversion Cost Update The result of this dry conversion cost update is displayed below in comparison to the initial conversion cost estimate. The adjusted cost incorporates the average annual 1.1% decrease in CCR impoundment disposal tonnage calculated based on the 1996-2005 EIA data trend as presented in Exhibit 4G above, relative to the 2005 base year impoundment disposal tonnage of 22.4 million tons over the same 50-year period (i.e., 2012 to 2061) applied in the RIA. This adjustment provides a declining future CCR impoundment tonnage trend which would be impacted by the CCR proposed rule when it is implemented, rather than simply assigning to the rule a dry conversion cost for the entire 2005 impoundment tonnage (i.e., 22.4 million tons) as was done in the initial cost estimate. The cost adjustment using this trend involved two steps: Step 1: Assign a dry conversion cost to the extrapolation phase-out trend (i.e., 2006 to 2061) representing what the electric utility industry could be expected to incur in the future in absence of the CCR rule. The results of this 1 st step are displayed in columns A1 to A4 of Exhibit 4I below. Step 2: Re-estimate the phase-out cost under this same industry trend but by adding the requirement under the CCR rule that all remaining CCR impoundment tonnage that is not projected to be voluntarily phased-out within 5-years of the final rule’s adoption must be phased-out. This step incorporates three assumptions: (a) EPA promulgates the final rule at the start of 2012, (b) state governments adopt the final rule 2-years later at end of 2013, and (c) the final rule allows a 5-year phase-out period which spans 2014 to 2018. The results of this 2 nd step are displayed in columns B1 to B4 of Exhibit 4I below. 97
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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
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Summary Exhibit 6 Comparison of Reg
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Chapter 1 Problem Statement: The Ne
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Bevill Amendments 10 which exempted
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Just three weeks after the TVA’s
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2. Waste & Environmental Management
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This RIA did not discover similar d
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Exhibit 2A Identity of Other Indust
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Require review of surface impoundme
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Chapter 3 Baseline CCR Management i
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Exhibit 3C below, these 495 coal-fi
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Exhibit 3C State-by-State Electric
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3B. Types of CCR Disposal Units Es
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92 plants Offsite landfill fly ash
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electric utility plants in the data
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Exhibit 3E Annual CCR Disposition f
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3D. Size of CCR Disposal Units The
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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 and 62: Exhibit 3K Summary of Industry & St
Page 63 and 64: ($80,000 per year average Subtitle
Page 65 and 66: Validity Check of Baseline Cost Est
Page 67 and 68: Chapter 4 Estimated Cost for RCRA R
Page 69 and 70: B. Ancillary costs for CCR disposal
Page 71 and 72: location restriction mitigation inv
Page 73 and 74: o Impoundment berms: The average su
Page 75 and 76: State government average cost per w
Page 77 and 78: corrective action remedies usually
Page 79 and 80: Exhibit 4A Two Case Studies: Possib
Page 81 and 82: Biennial Report”). According to E
Page 83 and 84: 4B.3 Land Disposal Restriction Cost
Page 85 and 86: The TVA cost study did not estimate
Page 87 and 88: Using the EPA ORCR 2009$ 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: from coal to other fuels such as na
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
Page 113 and 114: Step 2. Determine Potentially Affec
Page 115 and 116: Step 3. Apply EPA-ORCR 2009 Arsenic
Page 117 and 118: RISKn WELLREACH iRISK EDn N Where
Page 119 and 120: The constant slope allowed estimati
Page 121 and 122: Step 6. Monetize Future Avoided Can
Page 123 and 124: controls like surface-impoundment p
Page 125 and 126: Finally, for Subtitle C, there woul
Page 127 and 128: Exhibit 5A-12 Percentile of Cleanup
Page 129 and 130: Exhibit 5A-16 Per-Site Groundwater
Page 131 and 132: Multiple CCR disposal units at a si
Page 133 and 134: 5B. Benefit of Preventing Future CC
Page 135 and 136: As displayed below in Exhibit 5B-2,
Page 137 and 138: Where: = Observed arrival rate (0.
Page 139 and 140: Step 3. Calculate Future Impoundmen
Page 141 and 142: some surface impoundment regulation
Page 143 and 144: Exhibit 5B-8 Poisson Distribution (
Page 145 and 146: 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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