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 INTRODUCTION

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 promulgated 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 for the Proposed Effluent Limitations Guidelines and Standards 

for the Steam Electric Power Generating Point Source Category (TDD), on June 21, 2010, EPA proposed 

regulations under RCRA to regulate coal combustion 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 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 

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 compliance costs and pollutant reductions (as well as 

other related analyses, such as economic and environmental impacts) attributable to any final action taken 

in this ELG rulemaking. 

EPA chose to conduct sensitivity analyses (consistent with the two approaches EPA proposed under 

RCRA) to provide a better understanding of the effects of these operational changes because the CCR 

Rule has not been promulgated in final form and, therefore, it cannot be factored with certainty into many 

of the analyses for the proposed ELGs. The sensitivity analyses are supplemental to the primary analyses 

of the proposed ELGs (including costs, loads, impacts, etc.), which reflect current baseline conditions and 

do not factor in the operational changes that could 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 systems 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 promulgated prior to the selection of any ELG final action, 

EPA has assessed the possible effects of the CCR Rule as though it were finalized under various 

scenarios. EPA then used these possible alternate “baseline conditions” to reevaluate its ELG analyses 
2

(e.g. costs, loadings, economic impacts1

). 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 Proposed 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 Effluent 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 UNIVERSE OF PLANTS

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, plants 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 proposing new limitations or standards. For each of these plants, EPA 

used plant-specific information, 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 loading reductions associated with the technology bases 

included in the ELG regulatory options from the baseline condition (i.e., reference case). The plantspecific baseline conditions include information 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 plants included in its reference case. 

3.0 ELG REGULATORY OPTIONS EVALUATED

For this sensitivity analysis, EPA evaluated ELG Regulatory Options 3 and 4. Table 1 summarizes the 

technology basis for the wastestreams included in these two regulatory options. EPA has determined that 

a plant’s response to a final CCR Rule would not likely affect its approach to complying with ELG 

requirements for gasification, flue gas mercury control (FGMC) wastewaters, or nonchemical metal 

cleaning wastewater and EPA therefore only re-evaluated 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 APPROACHES EVALUATED

The sensitivity scenarios match the two proposed approaches 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 wastes (these approaches are referred to in this 

memo as “Special Waste” and “Non-Hazardous Waste”). These two approaches 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 continue operating, while clay-lined and unlined 

impoundments would likely close or retrofit with a composite 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 electric 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 retrofit 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 would 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 impoundments as well as whether the impoundment is 

lined or unlined. However, EPA does not have specific 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, for this sensitivity analysis, EPA assumed that all 

“lined” surface impoundments reflect composite liners and 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, EPA 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 multiple 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 specific 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 that 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 are 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, all 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, all 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 will continue current operations. 

5.0 COSTS AND POLLUTANT REDUCTIONS ANALYSIS 

Once EPA identified the status of each surface impoundment (or surface impoundment series) at a steam 

electric plant subject to the proposed ELGs as closed, retrofitted, or unchanged for a specific CCR 

approach, it then needed to determine how an applicable change in baseline would affect the ELG costs 

and pollutant loading reductions. For these sensitivity analyses, EPA used the same methodology to 

estimate plant-specific costs and pollutant reductions as was done for the reference case, which are 

described in Sections 9 and 10 of the TDD. Additionally, 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 Standards 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 costs 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 retrofit in response to any final CCR Rule, the ELG 

costs and pollutant reductions would be unchanged 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 transport 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 the bottom ash impoundment is also used to treat other wastes, such as 

FGD wastes, and the impoundment closure results in the 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 handling 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 reductions 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 same 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 transport 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 would 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 would 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 eliminated the costs associated with conversion to a 

remote mechanical drag system but included costs associated with complete recycle. 

EPA determined which of the two approaches 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 transport water for the ELGs, EPA evaluated the costs for 

plants to convert to a system that completely eliminates the generation of bottom ash transport water (i.e., 

mechanical drag system) or a system that still generates 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 would likely install a dry system or a tank based system 

in response to the CCR Rule2

. 

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. Therefore, 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 Component 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-based FGD wastewater treatment system capable of 

treating the FGD wastewater to the same level as the existing surface impoundment (i.e., remove 

suspended solids to meet the existing ELG BPT discharge 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 pollutant loading reductions associated with this 

discharge for the ELG Options would not change because the discharge would not change (both the preCCR surface impoundment and the post-CCR tank-based system are designed to remove suspended solids 

and not dissolved metals and other pollutants). However, 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 comply 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 addition 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 closed-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 plant 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 associated 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 impoundment for treatment prior to discharge. In order 

to close such a surface impoundment to respond to a specific 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 the 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 clarifiers to meet the existing ELG BPT discharge 

requirements. Because the resulting discharge would essentially be the same as the ELG baseline 

condition under either approach, the ELG baseline 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 wastestream, EPA reevaluated the incremental costs and 

pollutant reductions for Regulatory Options 3 and 4 using the alternative baselines based on the various 

sensitivity scenarios. The incremental compliance costs calculated for these sensitivity analyses are 

summarized in Table 4, which presents the incremental annualized compliance costs for ELG Options 3 

and 4 without the CCR Rule (Reference Case) 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 Options 3 and 4, by Sensitivity Scenario (millions 

2010$, at 2014)a

Sensitivity Scenario 

Pre-Tax Compliance Costs After-Tax Compliance Costs 

Capital 

Technology 

Other 

Initial OneTimeb

Total O&M Total Capital 

Technology

Other 

Initial OneTimeb

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 methodology 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 ECONOMIC IMPACTS AND SOCIAL COSTS

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 electric 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 following the methodology described in Chapter 11 in the Benefits 

and Costs Analysis for the Proposed Effluent Limitations 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 Compliance to Society (Table 11). 

Table 6: Plant-Level Cost-to-Revenue Analysis Results for ELG Options 3 and 4, by Sensitivity 

Scenarioa

ELG 

Option Sensitivity Scenario Total Number 

of Plants No Revenueb

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 methodology used to conduct this analysis. 

b. EPA does not have revenue for 3 steam electric plants (5 on a weighted basis); however, 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 (with CCR Rule) have lower compliance costs 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 sensitivity scenarios would show similarly small incremental 

effects on the electricity market and steam electric plants. 
10

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

Scenarioa

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% Unknownc 0%b 0% 

and 

<1% 

≥1% 

and 

<3% 

≥3% Unknownc

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 number of firms owning steam electric plants. Case 2 assumes that steam electric plants 

represented by sample weights are owned by different firms than those owning the sample plant; 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 revenues 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 Small Parent Entities for ELG Options 3 and 4, by 

Sensitivity Scenarioa,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 

Entitiesc

Number of 

Small 

Entities 

% of Small 

Entitiesc

Number of 

Small 

Entities 

% of Small 

Entitiesc

Number of 

Small 

Entities 

% of Small 

Entitiesc

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 plants. 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 estimate of number of firms owning 

steam electric plants. See RIA Chapter 8 for a detailed discussion of the methodology 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 ratios 

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 methodology used to conduct 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 

Scenarioa

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 methodology used to conduct 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 Scenarioa

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 methodology used to conduct this analysis. 

Source: U.S. EPA Analysis, 2012