Coal Combustion Waste Management at - DOE - Fossil Energy ...

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(NRECA) and the American Public Power Association (APPA) are members of USWAG, these
trade associations distributed the questionnaire to their member companies, and their responses
are included in the analysis. Rural electric cooperatives are private, independent electric utilities
that supply electricity in rural areas. They include generation, transmission, and distribution
systems, and they are generally much smaller than investor-owned facilities. The 70 NRECA
coal-fired plants represent about 24 GW, or 7% of total coal-fired generating capacity, and range
in size from 15 to 1,180 MW, with an average of 353 MW. APPA utilities are not-for-profit,
community, and state-owned electric utilities that also represent about 24 GW of coal-fired
capacity. The 177 publicly owned coal-fired power plants range in capacity from less than 1 to
820 MW, with an average of 137 MW. The 279 investor-owned USWAG coal-fired plants range
in capacity from 11 to 3,564 MW, with an average of 804 MW. USWAG, NRECA, and APPA
requested that their member companies return completed questionnaires for all units permitted,
built, or laterally expanded between 1994 and 2004, and provide copies of all permits issued for
these units.
Because a response (in the form of a returned, completed survey) was requested only if a
company had new units, a lack of response was assumed to mean that the member company had
no new units. In January 2006, USWAG contacted members that did not respond to the 2004
survey to verify that assumption. As explained in detail in Section 3.1.1, the results of the
December 2004 survey combined with the January 2006 follow-up resulted in responses from
100% of USWAG’s coal-fired utilities. To verify independently the assumption that a lack of
response meant that the utility had no new units, and to obtain information on units that may
have been missed by the 2004 USWAG survey, as well as on units owned by non-USWAG,
non-NRECA, and non-APPA members, the EPA asked State regulators from nine selected
States 8 for information on new units that may not have been identified in the USWAG survey.
Appendix C contains additional details on the approach taken to ensure that as many new units as
possible were captured for the analysis.
The EPA obtained information on the locations of these units, date of permit,
construction and/or lateral expansion, and whether they had liners and groundwater monitoring.
However, the EPA did not ask States identifying these new units to have operators of these units
complete the questionnaire and, therefore, no additional information about unit operations was
collected for these units.
The completed questionnaires and the data provided to the EPA by the State regulators
were reviewed to verify that (1) all units were, in fact, surface disposal units (i.e., landfills or
surface impoundments and not minefills), (2) all units were permitted, built or laterally expanded
between 1994 and 2004, and (3) there were no duplications between the USWAG survey and the
EPA verification units. The data for the resulting units were then entered into a database
developed specifically to store, sort, and query the disposal unit data. Finally, the disposal unit
8 The EPA’s selected States were those that top the list of consumption of coal for electricity generation and/or
CCW generation. The selected states, however, do not include those States with extensive coal-mining
operations where significant portions of the CCWs are inferred to be disposed of as minefill, and those that do
not require permits for disposal of dry ash and, therefore, lack pertinent records. The selected states were
Georgia, Illinois, Indiana, Michigan, Missouri, North Carolina, North Dakota, Ohio, and Texas.