### 1 DATE: January 9, 2013

FROM: Ron Jordan, OW James Covington, OW

TO: Steam Electric ELG Record

SUBJECT: Consideration of the Proposed CCR Rule on the Analyses for the Steam Electric Effluent Limitations Guidelines and Standards (ELGs) Rulemaking



### 1.0 I NTRODUCTION


### EPA conducted a series of “sensitivity” analyses to assess how the actions taken by the industry to comply with any CCR Rule (assuming it is promulgate d before the Agency takes final action on this Steam Electric ELG rulemaking) might affect the costs, pollutant reductions, economic and environmental/non-water quality impacts associated with the proposed ELGs. As described in Section 1 of the Technical Development Document fo r the Proposed Effluent Limita tions Guidelines and Standards for the Steam Electric Power Ge nerating Point Source Category (TDD), on June 21, 2010, EPA proposed regulations under RCRA to regulate coal combusti on residuals (CCR) generated from coal-fired power plants (75 FR 35128). This proposed rule, referred to in this memo as the “CCR Rule,” laid out two approaches for managing CCR wastes that are dispos ed: one would regulate CCR under RCRA Subtitle C as “special wastes,” while the other would regulate CCR under RCRA Subtitle D as non-hazardous wastes. These two approaches under the CCR proposal differ significantly in how they would likely affect the operation of surface impoundments, and thus would likely affect the way steam electric power plants manage CCR in the future. In particular, included in the proposed CCR Rule were regulatory options that likely would result in the closure of some or all surface impoundments containing CCR. These changes in operations could alter the expected incremental co mpliance costs and pollutant reductions (as well as other related analyses, such as economic and environmen tal impacts) attributable to any final action taken in this ELG rulemaking.

EPA chose to conduct sensitivity analyses (consiste nt with the two approaches EPA proposed under RCRA) to provide a better understanding of the e ffects of these operational changes because the CCR Rule has not been promulgated in final form and, ther efore, it cannot be factored with certainty into many of the analyses for the proposed ELGs. The sensitivity analyses are s upplemental to the primary analyses of the proposed ELGs (including costs, loads, impact s, etc.), which reflect current baseline conditions and do not factor in the operational changes that c ould occur under any final CCR Rule. Depending on the option selected for any final CCR Rule, EPA expects that some plants may take actions to transform their operations, such as converting to dry ash handling sy stems and closing surface impoundments in order to comply with such a CCR Rule. Therefore, in order to better inform the ELG rulemaking concerning the effects of any final CCR Rule that might be promulga ted prior to the selection of any ELG final action, EPA has assessed the possible eff ects of the CCR Rule as though it were finalized under various scenarios. EPA then used these possi ble alternate “baseline conditions” to reevaluate its ELG analyses

### 2 (e.g. costs, loadings, economic impacts 1 

### ). This memorandum details the sensitivity analysis. It describes the ELG and CCR scenarios evaluated, the methodology used to develop the alternate baseline conditions, and the results of the various analyses with these alternate baseline conditions.

The following documents describe the methodologies used in EPA’s analyses in more details:

 Technical Development Document for the Pr oposed Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category (TDD)

 Regulatory Impact Analysis for the Proposed Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category (RIA)

 Benefits and Costs Analysis for the Proposed E ffluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category (BCA) In the discussion below, the analysis of the proposed ELGs without the CCR Rule in place is referred to as the “reference case”. The analysis of the proposed ELGs with a CCR Rule in place is the sensitivity scenarios.



### 2.0 U NIVERSE OF 

### P LANTS


### EPA identified a universe of 1,079 steam electric power plants currently subject to the existing ELGs. As described more fully in Chapter 9 of the TDD, plan ts that EPA estimates would incur compliance costs (and associated pollutant reductions, impacts, etc.) as a result of any of the proposed regulatory options are a subset of these steam electric plants. These plants are generally those that generate and discharge the wastestreams for which EPA is pr oposing new limitations or standards. For each of these plants, EPA used plant-specific inform ation, largely from the 2010 Questionnaire for the Steam Electric Power Generating Effluent Guidelines (steam electric industry survey), to identify existing or baseline conditions and to evaluate incremental costs and pollutant lo ading reductions associated with the technology bases included in the ELG regulatory options from the ba seline condition (i.e., reference case). The plantspecific baseline conditions include informati on on surface impoundments and the types of waste managed in these surface impoundments. As the purpose of this sensitivity analysis is to evaluate how baseline changes that may result from a plant’s response to any final CCR Rule could affect EPA’s estimates of the ELG costs and pollutant loadings, EPA is similarly conducting this sensitivity analysis on a plant-specific basis for the same plan ts included in its reference case.



### 3.0 ELG R EGULATORY 

### O PTIONS 

### E VALUATED


### For this sensitivity analysis, EPA evaluated ELG Regulatory Options 3 and 4. Table 1 summarizes the technology basis for the wastestreams included in th ese two regulatory options. EPA has determined that a plant’s response to a final CCR Rule would not lik ely affect its approach to complying with ELG requirements for gasification, flue gas mercury c ontrol (FGMC) wastewaters, or nonchemical metal cleaning wastewater and EPA therefore only re-evaluat ed costs and pollutant loading reductions for the following wastestreams as applicable to Option 3 or 4: FGD wastewater, fly ash transport water, bottom ash transport water, and leachate.

1 EPA did not run the Integrated Planning Model (IPM) to assess the impacts of the proposed ELG on the electricity market with the CCR Rule.

### 3 Table 1. Summary of Regulatory Options 3 and 4 for the Steam Electric ELG Revisions

Wastestream Technology Option Regulatory Option 3 4

FGD Wastewater Chemical Precipitation + Biological Treatment   Fly Ash Transport Water Dry Handling  
Bottom Ash Transport Water Impoundment (Equal to BPT)  Dry Handling/Closed Loop 

Leachate Impoundment (Equal to BPT)  Chemical Precipitation  Gasification Wastewater Chemical precipitation + Evaporation   FGMC Wastewater Dry Handling   Nonchemical Metal Cleaning Wastewater Chemical Precipitation  



### 4.0 CCR A PPROACHES 

### E VALUATED


### The sensitivity scenarios match the two proposed ap proaches for managing CCR wastes described in EPA’s proposed CCR Rule. EPA laid out two key approaches for managing CCR wastes that are disposed: one would regulate CCR under RCRA Subtitle C as “special wastes,” while the other would regulate CCR under RCRA Subtitle D as non-hazardous wast es (these approaches are referred to in this memo as “Special Waste” and “Non-Hazardous W aste”). These two approach es for the proposed CCR Rule differ significantly in how they are likely to affect the operation of surface impoundments at steam electric generating plants. In particular, under the proposed Special Waste approach, all CCR surface impoundments would likely cease operating and close. Under the Non-Hazardous Waste approach, all composite-lined surface impoundments would likely con tinue operating, while clay-lined and unlined impoundments would likely close or retrofit with a co mposite liner (which could include replacing the unlined/clay-lined impoundments with a composite-lined impoundment).



### 4.1 Regulation of CCRs as Special Wastes

For purposes of this sensitivity analysis, EPA assumed that, under this approach, all surface impoundments containing CCRs located at the steam el ectric plants subject to the proposed ELGs will cease operations and close.



### 4.2 Regulation of CCRs as Non-Hazardous Wastes

This approach would require plants to retrof it CCR surface impoundments that do not have composite liners or cease receiving CCRs and close. Ideally, for purposes of this analysis, EPA would assume that all surface impoundments with composite liners w ould continue to operate and all other surface impoundments would either close or retrofit under this approach. Each plant that responded to the steam electric industry survey provided information on im poundments as well as whether the impoundment is lined or unlined. However, EPA does not have speci fic information on the liner type for all surface impoundments reported by plants in the survey. The ICR conducted for the proposed CCR Rule also lacks liner information for each impoundment. Therefore, fo r this sensitivity analysis, EPA assumed that all “lined” surface impoundments reflect composite liners a nd would not have to retrofit or close in response to this CCR approach.

The next step was to identify whether or not an unlined surface impoundment would likely close or retrofit. In the analysis for the proposed CCR Rule, EP A calculated costs of closure and costs to retrofit

### 4 each surface impoundment and chose the less expensive alternative. However, EPA does not have plantspecific CCR costing information that is applicable to the ELG universe. Therefore, for conducting this sensitivity analysis, EPA evaluated the following two bounding cases:

 All unlined surface impoundments would close (upper bound analysis); and

 All unlined surface impoundments would retrofit (lower bound analysis). This analysis, however, is complicated when multip le surface impoundments at a plant are operated in series and the series contains both lined and unlined surface impoundments. An additional complication is that each impoundment within the surface impoundment series at a plant may contain a different subset of wastes associated with multiple ELG wastestreams. To account for these complicating factors, where a plant indicated it has multiple surface impoundments in its survey response, EPA assigned their “series” status using the following assumptions:

 All surface impoundments at a plant containing a spec ific waste are considered to be in series (e.g., all surface impoundments at the plant that have fly ash are in series); and

 If a surface impoundment contains multiple wastes, then all surface impoundments containing those wastes are considered to be in series (e.g., if a plant has two surface impoundments that only receive fly ash, three surface impoundments th at only receive bottom ash, and one surface impoundment that receives both fly ash and bottom ash, then all six surface impoundments are considered to be in series because the wastes ar e ultimately combined in one of the surface impoundments).

EPA then assigned the status of each impoundment series as follows:

 Upper bound case:

- If all impoundments in a series are lined, a ll impoundments continue current operations,

- If all impoundments in a series are unlined, all impoundments will close, and

- If a series consists of lined and unlined impoundments, all impoundments will close.

 Lower bound case:

- If all impoundments in a series are lined, a ll impoundments continue current operations,

- If all impoundments in a series are unlined, all impoundments will close, and

- If a series consists of lined and unlined impoundments, the unlined impoundments will retrofit and the lined impoundments w ill continue current operations.



### 5.0 C OSTS AND 

### P OLLUTANT 

### R EDUCTIONS 

### A NALYSIS



### Once EPA identified the status of each surface im poundment (or surface impoundment series) at a steam electric plant subject to the proposed ELGs as cl osed, retrofitted, or unchanged for a specific CCR approach, it then needed to determine how an appli cable change in baseline would affect the ELG costs and pollutant loading reductions. For these sensitiv ity analyses, EPA used the same methodology to estimate plant-specific costs and pollutant reducti ons as was done for the re ference case, which are described in Sections 9 and 10 of the TDD. Additio nally, EPA used the same methodology to calculate the annualized compliance costs, which are described in Section 3 of the Regulatory Impact Analysis for

### 5 the Proposed Effluent Limitations Guidelines and St andards for the Steam Electric Power Generating Point Source Category (RIA). The following sections describe, for each ELG wastestream being evaluated, the changes applied to the ELG co sts and loads if a surface impoundment (or surface impoundment series) would likely close in response to any final CCR Rule. For surface impoundments (or surface impoundment series) that would likely re trofit in response to any final CCR Rule, the ELG costs and pollutant reductions would be unc hanged for the associated wastestreams.



### 5.1 Fly Ash Transport Water

In order for a surface impoundment containing fly ash transport water to close to respond to a specific CCR approach, the generating units transferring the fly ash transport water to the surface impoundment would be converted to dry fly ash handling systems. The conversion to a dry fly ash handling system would result in the elimination of the fly ash trans port water. Therefore, there would be no costs or pollutant loading reductions associated with proposed ELG Option 3 or 4. As a result, any costs and load reductions EPA had attributed to the ELGs in its reference case analysis for this surface impoundment discharge would be eliminated.



### 5.2 Bottom Ash Transport Water

As presented in Table 1, ELG Option 3 does not include additional requirements for bottom ash discharges. Therefore, bottom ash closure as a result of the CCR Rule has no effect on Option 3 costs and loads (except in instances where th e bottom ash impoundment is also used to treat other wastes, such as FGD wastes, and the impoundment closure results in th e plant installing separate treatment for the other wastes).

In order for a surface impoundment containing bottom ash transport water to close to respond to a specific CCR approach, the generating units transferring the bottom ash transport water to the surface impoundment would be converted to a bottom ash hand ling system that eliminates the use of surface impoundments (e.g., completely dry system, mechanical drag system, remote mechanical drag system, dewatering bin system with tank-based flow collection) . The conversion to a completely dry system or a mechanical drag system would result in the elimination of the bottom ash transport water. In this case, all conversion costs and pollutant re ductions would be associated with the CCR Rule and none would be attributed with ELG Option 4.

However, to respond to a specific CCR approach, that sa me plant could also elect to convert to a remote mechanical drag system or dewatering bin system with tank-based flow collection/treatment. This approach would not eliminate the bottom ash transpor t water and would only alter the location of the current discharge. In this case, the plant would incur the majority of the conversion costs including the tank based system in response to the CCR Rule. Further, the plant would design its system to meet the existing ELG bottom ash discharge requirements. As such, the bottom ash wastestream would not be affected by this plant’s response to CCR. In this case, EPA’s estimation of pollutant loading reductions associated with ELG Option 4 for this discharge w ould not change. However, the ELG compliance costs would be reduced because the plant would not need to install the same technology to comply with ELG Option 4 as was estimated under the ELG reference case for this plant. Under this CCR response, to respond to ELG Option 4 requirements, the plant woul d likely alter its tank based system to achieve complete recycle and incur the associated costs (i .e., pH adjustment feed system, chemicals, and

### 6 recirculation pumps). Therefore, in this case, EPA el iminated the costs associated with conversion to a remote mechanical drag system but included costs associated with complete recycle.

EPA determined which of the two a pproaches described above a plant would likely elect in response to a specific CCR approach based on the methodology it used to calculate incremental costs for elimination of bottom ash discharges for the proposed ELGs. As part of its methodology for estimating costs associated with eliminating the discharge of bottom ash trans port water for the ELGs, EPA evaluated the costs for plants to convert to a system that completely elim inates the generation of bottom ash transport water (i.e., mechanical drag system) or a system that still ge nerates bottom ash transport water but operates as a complete recycle system (i.e., remote mechanical drag system with complete recycle). EPA estimated the costs on a plant level for each system and then chose the least expensive alternative. EPA similarly used this information to determine whether the plants woul d likely install a dry system or a tank based system in response to the CCR Rule 2



### . Table 2 summarizes the effect to Option 4 costs and loadings associated with bottom ash surface impoundment closure as a result of the CCR Rule. As mentioned above, ELG Option 3 does not include additional requirements on bottom ash discharges. Th erefore, bottom ash closure as a result of the CCR Rule has no effect on Option 3 costs and loads.

Table 2: Summary of Changes to Option 4 ELG Costs Resulting from Bottom Ash Surface impoundment Closure to Respond to CCR CCR Response Option 4 ELG Cost Compon ent Option 4 ELG Pollutant Reductions Completely Dry System or Mechanical Drag System Changed; No costs associated with ELGs Changed; no removals associated with ELGs Remote Mechanical Drag System or Dewatering Bin System Changed; cost for recycle system only (ELG costs reduced) No change to ELG removals



### 5.3 FGD Wastewater

In order for a surface impoundment containing FGD wastewater to close to respond to a specific CCR approach, the plant would likely install a tank-b ased FGD wastewater treatment system capable of treating the FGD wastewater to the same leve l as the existing surface impoundment (i.e., remove suspended solids to meet the existing ELG BPT disc harge requirements). For purposes of these analyses, EPA assumed this type of treatment system would include equalization tanks , a clarifier, polymer addition, filter presses, and a collection tank. Therefore, the plant would incur these costs to comply with the CCR Rule. In this case, EPA’s estimation of po llutant loading reductions associated with this discharge for the ELG Options would not change b ecause the discharge would not change (both the preCCR surface impoundment and the post-CCR tank-based syst em are designed to remove suspended solids and not dissolved metals and other pollutants). Ho wever, the ELG compliance costs would be reduced because the plant would not need to install the same technology to comply with the ELGs as was estimated under the ELG baseline condition. To comp ly with ELG regulatory requirements, the plant would need to upgrade its newly installed tank-based treatment system. For purposes of this sensitivity analysis, with respect to the chemical precipitation portion of the ELG technology basis, EPA assumed the plant would install reaction tanks, chemical additi on feed systems, sand filters, and begin adding lime,

2 As explained above, however, EPA assumed that all plants expected to install a remote mechanical drag system would continue to discharge under the compliance options for the CCR Rule because the existing ELG allows for this discharge and it is less expensive than operating a cl osed-loop system.

### 7 organosulfide, and ferric chloride to the system. Under this scenario, for the ELGs, EPA assumed the plant would still incur 50 percent of the ELG capital and O&M chemical precipitation costs it would have incurred under the reference case. Additionally, the plan t would still incur the entire costs to install and operate the biological portion of the treatment system.

Table 3 summarizes the effect to Option 3 and 4 costs and loadings associ ated with FGD surface impoundment closure as a result of the CCR Rule. As summarized in Table 1, ELG Options 3 and 4 have the same FGD discharge requirements. Therefore, FGD closure as a result of CCR affects Option 3 and Option 4 costs and loads the same.

Table 3: Summary of Changes to ELG Costs Resulting from FGD Surface impoundment Closure to Respond to CCR Rule
CCR Response Options 3 and 4 ELG Cost Component Options 3 and 4 ELG Pollutant Reductions Close Surface impoundment; Install tank based system to treat wastewater to existing ELG requirements Changed; Reduce capital and O&M costs for chemical precipitation by 50 percent No Change to ELG removals



### 5.4 CCR Leachate

Some plants send their CCR leachate to a surface imp oundment for treatment prior to discharge. In order to close such a surface impoundment to respond to a sp ecific CCR approach, the plant could either build a new lined impoundment to handle the leachate, or install a concrete sump or basin to treat the leachate. In either case, the plant would need to achieve th e same level of treatment as the existing surface impoundment (i.e., remove suspended solids to meet the existing ELG BPT discharge requirements). The influent TSS in leachate is low, therefore, EPA doesn’t expect that either of these potential systems would need chemical addition (e.g., polymers) or clar ifiers to meet the existing ELG BPT discharge requirements. Because the resulting discharge w ould essentially be the same as the ELG baseline condition under either approach, the ELG baselin e conditions (and associated costs and pollutant loadings) would not change as a result of a CCR Rule.



### 5.5 Results of Costs and Pollutant Reductions Analysis

Using the assumptions described above for each wast estream, EPA reevaluated the incremental costs and pollutant reductions for Regulatory Options 3 and 4 using the alterna tive baselines based on the various sensitivity scenarios. The incremental compliance costs calculated for these sensitivity analyses are summarized in Table 4, which presents the incremen tal annualized compliance costs for ELG Options 3 and 4 without the CCR Rule (Reference C ase) and for each sensitivity scenario.

The incremental pollutant reductions calculated for these sensitivity analyses are summarized in Table 5, which presents the incremental pollutant reductions for ELG Option 3 and 4 without the CCR Rule and for each sensitivity scenario, by wastestream.

### 8 Table 4: Annualized Compliance Costs for ELG Opti ons 3 and 4, by Sensitivity Scenario (millions 2010$, at 2014) a

Sensitivity Scenario Pre-Tax Compliance Costs After-Tax Compliance Costs Capital Technology OtherInitial OneTime b Total O&M Total Capital Technology OtherInitial OneTime b Total O&M Total

Option 3 Without CCR Rule (Reference Case) $209.6 $0.0 $351.8 $561.4 $147. 9 $0.0 $241.0 $389.0

CCR Special Waste $133.6 $0.0 $154. 8 $288.4 $94.8 $0.0 $109.6 $204.3

CCR Non-Hazardous Waste Upper $162.4 $0.0 $216.9 $379.3 $114. 1 $0.0 $149.8 $263.9

CCR Non-Hazardous Waste Lower $175.8 $0.0 $255.3 $431.1 $123. 3 $0.0 $174.9 $298.3
Option 4 Without CCR Rule (Reference Case) $568.5 $0.0 $804.7 $1,373.3 $382.3 $0.0 $534.6 $916.9

CCR Special Waste $183.0 $0.0 $203.7 $386.7 $128.0 $0.0 $142.6 $270.6

CCR Non-Hazardous Waste Upper $278.6 $0.0 $348.6 $627.2 $191.4 $0.0 $237.1 $428.5

CCR Non-Hazardous Waste Lower $362.0 $0.0 $477.5 $839.5 $245.1 $0.0 $318.7 $563.8

a. See RIA Chapter 3 for a detailed discussion of the methodol ogy used to conduct this analysis. Source: U.S. EPA Analysis, 2012

Table 5. Baseline Pollutant Loadings and Incremental Pollutant Reductions for ELG Options 3 and 4, by Sensitivity Scenarios and Wastestream (TWPE)

ELG Option Sensitivity Scenario FGD Wastewater Fly Ash Transport

Water Bottom Ash Transport

Water Leachate Total

Annual Baseline Pollutant Loadings 3,026,296 2,521,986 2,716, 059 56,504 8,320,845 Annual Pollutant Loading Reductions

Option 3 Without CCR Rule (Reference Case) 2,615,339 2,488,469 0 0 5,103,808 CCR Special Waste 2,615,339 0 0 0 2,615,339 CCR Non-Hazardous Waste Upper 2,615,339 442,457 0 0 3,057,796 CCR Non-Hazardous Waste Lower 2,615,339 927,387 0 0 3,542,726

Option 4 Without CCR Rule (Reference Case) 2,615,339 2,488,469 2,705, 159 37,863 7,846,830 CCR Special Waste 2,615,339 0 3,388 37,863 2,656,590 CCR Non-Hazardous Waste Upper 2,615,339 442,457 2,081, 554 37,863 5,177,213 CCR Non-Hazardous Waste Lower 2,615,339 927,387 2,369, 432 37,863 5,950,021



### 6.0 E CONOMIC 

### I MPACTS AND 

### S OCIAL 

### C OSTS


### Using the incremental compliance costs calculated for each sensitivity scenario, EPA reevaluated the economic impacts of compliance on the steam electric industry (plants and plant owners) and electricity consumers. For these sensitivity analyses, EPA used the same methodology used to assess screening-level economic impacts of the proposed ELGs on steam elect ric plants and entities that own plants and to

### 9 estimate impacts on households and electricity consumers (see Chapter 4 in the RIA ). 3 

### EPA also calculated the social costs of the rule followi ng the methodology described in Chapter 11 in the Benefits and Costs Analysis for the Proposed Effluent Limitati ons Guidelines and Standards for the Steam Electric Power Generating Point Source Category (BCA) report.

The following tables summarize selected results for ELG Options 3 and 4:

 Plant-Level Cost-to-Revenue Analysis Results (Table 6);

 Entity-Level Cost-to-Revenue Analysis Results (Table 7);

 Estimated Cost-To-Revenue Impact on Small Parent Entities (Table 8);

 Projected 2014 Price (Cents per KWh of Sales) and Potential Price Increase Due to Compliance Costs (Table 9);

 Average Annual Cost per Household in 2014 (Table 10); and

 Summary of Costs of Complian ce to Society (Table 11).

Table 6: Plant-Level Cost-to-Revenue Analysis R esults for ELG Options 3 and 4, by Sensitivity Scenario a

ELG Option Sensitivity Scenario Total Number of Plants No Revenue b Number of Plants with a Ratio of

0% c  0% and <1% ≥ 1% and <3% ≥ 3%

Option 3 Without CCR Rule (Reference Case) 1,079 5 920 102 38 14 CCR Special Waste 1,079 5 959 89 20 6 CCR Non-Hazardous Waste Upper 1,079 5 957 88 20 9 CCR Non-Hazardous Waste Lower 1,079 5 953 88 24 9

Option 4 Without CCR Rule (Reference Case) 1,079 5 798 111 117 48 CCR Special Waste 1,079 5 844 193 28 9 CCR Non-Hazardous Waste Upper 1,079 5 832 176 48 18 CCR Non-Hazardous Waste Lower 1,079 5 821 164 67 22 a. See RIA Chapter 4 for a detailed discussion of the methodo logy used to condu ct this analysis. b. EPA does not have revenue for 3 steam el ectric plants (5 on a weighted basis); howe ver, only 1 of these 5 plants is expected to incur compliance cost under each of the ELG regulatory options. c. These plants already meet discharge requirements for the wastestreams addressed by a given regulatory option and are therefore not expected to incur any compliance technology costs. Source: U.S. EPA Analysis, 2012

3 Because the sensitivity scenarios (w ith CCR Rule) have lower compliance co sts than the reference scenario (without CCR Rule), and since Integrated Planning Model analyses of the reference case for BAT and PSES Options 3 and 4 showed minimal impacts on the electricity market and on steam electric plants, EPA did not analyze the sensitivity scenarios using IPM. EPA expects that the sens itivity scenarios would show similarly small incremental effects on the electricity mark et and steam electric plants.

### 10 Table 7: Entity-Level Cost-to-Revenue Analysis Results for ELG Options 3 and 4, by Sensitivity Scenario a

Sensitivity Scenario Case 1: Lower Bound Estimate of Number of Entities Owning Steam Electric Plants Case 2: Upper Bound Estimate of Number of Entities Owning Steam Electric Plants

Total #

of Entities Number of Parent Entities with a Ratio of Total # of Entities Number of Parent Entities with a Ratio of

0% b  0% and <1% ≥ 1% and <3% ≥ 3% Unknown c 0% b  0% and <1% ≥ 1% and <3% ≥ 3% Unknown c

Option 3 Without CCR Rule (Reference Case) 243 168 49 7 5 14 507 416 49 7 5 30

CCR Special Waste 243 173 48 4 4 14 507 421 48 4 4 30

CCR NonHazardous Waste Upper 243 173 47 5 4 14 507 421 47 5 4 30

CCR NonHazardous Waste Lower 243 172 47 6 4 14 507 420 47 6 4 30

Option 4 Without CCR Rule (Reference Case) 243 137 64 21 7 14 507 385 64 21 7 30

CCR Special Waste 243 144 73 7 5 14 507 392 73 7 5 30

CCR NonHazardous Waste Upper 243 141 71 12 5 14 507 389 71 12 5 30

CCR NonHazardous Waste Lower 243 141 70 13 5 14 507 389 70 13 5 30

a. Case 1 assumes that steam electric plants represented by sample weights are owned by the same firm that owns the sample plant; this is a lower-bound estimate of numbe r of firms owning steam electric plants. Ca se 2 assumes that st eam electric plant s represented by sample weights are owned by different firms th an those owning the sample plan t; this is an upper-bound estimate of number of firms owning steam electric plants. See RIA Chapter 4 for a detailed discussion of the methodology used to conduct this analysis. b. These entities own only those plants that already meet discharge requirements for the wastestreams addressed by a given regulatory option and are therefore not expected to incur any compliance technology costs. c. EPA was unable to determine revenue s for 14 and 30 parent entities under Case 1 and Case 2, respectively. Source: U.S. EPA Analysis, 2012

### 11 Table 8: Estimated Cost-To-Revenue Impact on Sma ll Parent Entities for ELG Options 3 and 4, by Sensitivity Scenario a,b

Sensitivity Scenario Case 1: Lower Bound Estimate of Number of Entities Owning Steam Electric Plants Case 2: Upper Bound Estimate of Number of Entities Owning Steam Electric Plants Cost > 1% of Revenue Cost > 3% of Revenue Cost > 1% of Revenue Cost > 3% of Revenue Number of Small Entities % of Small Entities c Number of Small Entities % of Small Entities c Number of Small Entities % of Small Entities c Number of Small Entities % of Small Entities c Option 3 Without CCR Rule (Reference Case) 5 5.2% 3 3.1% 5 2.9% 3 1.8%

CCR Special Waste 4 4.1% 3 3.1% 4 2.4% 3 1.8%

CCR Non-Hazardous Waste Upper 5 5.2% 3 3.1% 5 2.9% 3 1.8%

CCR Non-Hazardous Waste Lower 5 5.2% 3 3.1% 5 2.9% 3 1.8% Option 4 Without CCR Rule (Reference Case) 12 12.4% 4 4.1% 12 7.1% 4 2.4%

CCR Special Waste 5 5.2% 4 4.1% 5 2.9% 4 2.4%

CCR Non-Hazardous Waste Upper 8 8.3% 4 4.1% 8 4.7% 4 2.4%

CCR Non-Hazardous Waste Lower 8 8.3% 4 4.1% 8 4.7% 4 2.4% a. Case 1 assumes that plants represented by sample weights are owned by the same firm that owns the sample plant; this is a lower-bound estimate of number of firms owning steam electric p lants. Case 2 assumes that plants represented by sample weights are owned by different firms than those owning the sample plant; this is an upper-bound estim ate of number of firms owning steam electric plants. See RIA Chapter 8 for a detailed discussion of the met hodology used to conduct this analysis. b. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with such ratio s exceeding 1 percent. c. Percentage values are calculated relative to the total of 97 (Case 1) and 170 (Case 2) small entities owning steam electric plants. Source: U.S. EPA Analysis, 2012

Table 9: Projected 2014 Price (Cents per KWh of Sales) and Potential Price Increase Due to Compliance Costs for ELG Options 3 and 4, by Sensitivity Scenario ($2010) a

Sensitivity Scenario Compliance Cost (¢/KWh) Residential Commercial Industrial Transportation All Sector Average Baseline

Price % Change Baseline Price % Change Baseline Price % Change Baseline Price % Change Baseline Price % Change Option 3 Without CCR Rule (Reference Case) 0.015 10.95 0.13% 9.23 0.16% 6.03 0.24% 10.10 0.14% 9.03 0.16%

CCR Special Waste 0.008 10.95 0.07% 9.23 0.08% 6.03 0.12% 10.10 0.07% 9.03 0.08%

CCR NonHazardous Waste Upper 0.010 10.95 0.09% 9.23 0.11% 6.03 0.16% 10.10 0.10% 9.03 0.11%

CCR NonHazardous Waste Lower 0.011 10.95 0.10% 9.23 0.12% 6.03 0.19% 10.10 0.11% 9.03 0.12%

### 12 Table 9: Projected 2014 Price (Cents per KWh of Sales) and Potential Price Increase Due to Compliance Costs for ELG Options 3 and 4, by Sensitivity Scenario ($2010) a

Sensitivity Scenario Compliance Cost (¢/KWh) Residential Commercial Industrial Transportation All Sector Average Baseline

Price % Change Baseline Price % Change Baseline Price % Change Baseline Price % Change Baseline Price % Change Option 4 Without CCR Rule (Reference Case) 0.036 10.95 0.33% 9.23 0.39% 6.03 0.59% 10.10 0.35% 9.03 0.40%

CCR Special Waste 0.010 10.95 0.09% 9.23 0.11% 6.03 0.17% 10.10 0.10% 9.03 0.11%

CCR NonHazardous Waste Upper 0.016 10.95 0.15% 9.23 0.18% 6.03 0.27% 10.10 0.16% 9.03 0.18%

CCR NonHazardous Waste Lower 0.022 10.95 0.20% 9.23 0.24% 6.03 0.36% 10.10 0.22% 9.03 0.24%

a. See RIA Chapter 7 for a detailed discussion of the methodo logy used to condu ct this analysis. Source: U.S. EPA Analysis, 2012; U. S. DOE, 2010b; U.S. DOE, 2009c

Table 10: Average Annual Cost per Household in 2014 for ELG Options 3 and 4, by Sensitivity Scenario a

Sensitivity Scenario Total Annual Compliance Cost (at 2014; million 2010$) Total Electricity Sales (at 2014; MWh) Compliance Cost per Unit of Sales (2010$/MWh) Residential Electricity Sales (at 2014; MWh) Number of Households

(at 2014) Residential Sales per Residential Consumer

(MWh) Compliance Cost per Household

(2010$) Option 3 Without CCR Rule (Reference Case) $561.3 3,831,895,945 $0.15 1,346,997 ,293 123,983,263 10.86 $1.59

CCR Special Waste $288.4 3,831,895,945 $0.08 1,346,997 ,293 123,983,263 10.86 $0.82

CCR NonHazardous Waste Upper $379.3 3,831,895,945 $0.10 1,346,997 ,293 123,983,263 10.86 $1.08

CCR NonHazardous Waste Lower $431.1 3,831,895,945 $0.11 1,346,997 ,293 123,983,263 10.86 $1.22

Option 4 Without CCR Rule (Reference Case) $1,373.2 3,831,895,945 $0.36 1,346, 997,293 123,983,263 10.86 $3.89

CCR Special Waste $386.7 3,831,895,945 $0.10 1,346,997 ,293 123,983,263 10.86 $1.10

CCR NonHazardous Waste Upper $627.1 3,831,895,945 $0.16 1,346,997 ,293 123,983,263 10.86 $1.78

CCR NonHazardous Waste Lower $839.5 3,831,895,945 $0.22 1,346,997 ,293 123,983,263 10.86 $2.38

a. See RIA Chapter 7 for a detailed discussion of the methodo logy used to condu ct this analysis. U.S. EPA Analysis, 2012; U.S. DOE, 2010b; U.S. DOE, 2009c

### 13 Table 11: Summary of Annualized Costs of Compliance to Society for ELG Options 3 and 4, by Sensitivity Scenario a
ELG Option Sensitivity Scenario Annualized Costs (millions; 2010$) 3% Discount Rate 7% Discount Rate

Option 3 Without CCR Rule (Reference Case) $572.1 $545.3 CCR Special Waste $283.1 $278.9 CCR Non-Hazardous Waste Upper $377.9 $368.4 CCR Non-Hazardous Waste Lower $432.9 $418.1

Option 4 Without CCR Rule (Reference Case) $1,381.2 $1,323.2 CCR Special Waste $378.8 $372.2 CCR Non-Hazardous Waste Upper $622.1 $605.3 CCR Non-Hazardous Waste Lower $837.5 $808.9 a. See BCA Chapter 11 for a detailed discussion of the met hodology used to conduct this analysis. Source: U.S. EPA Analysis, 2012