September 25, 2015 Abt Associates | Wastestream Control Technologies Cost-Effectiveness | pg 1 Date 

### September 25, 2015

To 

### Steam Electric ELGs Record

From 

### Isabelle Morin
Subject 

### Compliance Costs, Loading Reductions, and Cost-Effectiveness by Wastestream Control Technologies



### 1 Introduction This memorandum presents the estimated compliance co sts, pollutant loadings, and cost-effectiveness of each wastestream and technology option analyzed as components of the regulatory options. The data supplement information presented in Appendix F of th e Regulatory Impact Analysis (RIA) document for the final rule (U.S. EPA, 2015a). All results are based on the scenario that accounts for the impacts of the Clean Power Plan rule. Refer to the RIA doc ument for details on methodologies for estimating compliance costs and cost-effectiveness. Refer to the Technical Development Document (TDD) for the final rule for details on load ing estimates (U.S. EPA, 2015b).



### 2 Results

2.1 Compliance Costs
Table 2-1 presents estimated annualized costs for each w astestream and technology option analyzed by EPA.

Table 2-1: Total Annualized Pre-Tax Co mpliance Costs (in millions, $2013, at 2015)

Wastestream Technology Option Number of Plants with Costs Total Costs (million 2013$) Incremental Costs a (million 2013$) FGD Chemical Precipitation 69 $112.5 $112.5 Chemical Precipitati on + Biological 69 $194.8 $82.3 Chemical Precipitation + Evaporation 69 $994.6 $799.7 Fly Ash Dry Handling 16 $9.4 $9.4 Bottom Ash Dry Handling for Units > 400 MW 103 $195.9 $195.9 Dry Handling for Units > 50 MW 61 $292.0 $96.1 Landfill Leachate Chemical Precipitation 60 $57.7 $57.7 Source: U.S. EPA Analysis, 2015. a Incremental costs calcula ted relative to the next less stringent technology option for the wastestream.



### 2.2 Loading Reductions
Table 2-2 presents estimated pollutant removals for each wastestream and technology option analyzed by EPA on both a total pounds basis and toxic-we ighted pound equivalent (TWPE) basis. 

# Memorandum Environment and ResourcesSeptember 25, 2015 Abt Associates | Wastestream Control Technologies Cost-Effectiveness | pg 2 Table 2-2: Total Annual Pollutant Removals

Wastestream Technology Option Pollutant Removals (TWPE/year) Incremental Pollutant Removals (TWPE/Year) FGD Chemical Precipitation 706,133 706,133 Chemical Precipitation + Biological 825,753 119,620 Chemical Precipitation + Evaporation Not estimated Not estimated Fly Ash Dry Handling 185,090 185,090 Bottom Ash Dry Handling for Units > 400 MW 251,051 251,051 Dry Handling for Units > 50 MW 344,014 92,964 Landfill Leachate Chemical Precipitation 29,574 29,574 Source: U.S. EPA Analysis, 2015.



### 2.3 Cost-Effectiveness
Table 2-3 presents estimated cost-effectiveness by wastestream and technology option analyzed by EPA. Incremental cost effectiveness is calculated relative to the next least stringent technology option (or the baseline in the case of the least stringent technology option).

Table 2-3: Total Annual Pollutant Removals

Wastestream Technology Option Total Costs (million 1981$) a Cost Effectiveness (1981$/TWPE) Incremental Cost Effectiveness (1981$/TWPE) FGD Chemical Precip itation $41.7 $59.0 $59.0 Chemical Precipitation + Biological $72.1 $87.4 $254.7 Chemical Precipitation + Evaporation $368.3 Not calculated b Not calculated b Fly Ash Dry Handling $3.5 $18.7 $18.7 Bottom Ash Dry Handling for Units > 400 MW $72.5 $288.9 $288.9 Dry Handling for Units > 50 MW $108.1 $314.3 $382.8 Landfill Leachate Chemical Pr ecipitation $21. 4 $722.8 $722.8 Source: U.S. EPA Analysis, 2015.

a Costs restated in 1981 dollars based on the Construction Cost Index (CCI 1981 /CCI 2013 = 0.370) b Pollutant removals for chemical precipitation + evaporation technology is not available and therefore cost effectiveness was not calculated.



### 3 Sensitivity Analysis on Treatment of Non-Detects For the purposes of calculating pollutant loadings unde r this action, EPA handled non-detect values in the reported data by replacing them with a value equal to one-half of the detection level for the measurement method that yielded the non-detect. This methodology is standard procedure for the ELG program as well as other CWA applications, and has been c onsistently followed in previous ELGs. The detection methods used to sample ash transport water vary in sensitivity between samples and across plants, and also vary accordingly in their non-detect levels across pollutants. In response to the proposed rule, commenters raised concerns that for some po llutants the loadings calculations (particularly for bottom ash, but also for fly ash) were biased high as a result of high non-detected values in the reported data, and that assigning one half of the detection level to these results could overstate the average pollutant loadings. To assess this concern, EPA explored an alterna tive method for treating non-detects. The alternative method provides an upper bound on the effect of non-de tects on the pollutant loadings. Details of the revisions are provided in the TDD for the final rule. The impact of this alternative calculation on costeffectiveness on a technology-speci fic basis is summarized below.September 25, 2015 Abt Associates | Wastestream Control Technologies Cost-Effectiveness | pg 3 

### The results show that the alternative treatment of non-detects increases cost effectiveness ratios for dry handling slightly for fly ash ($19/TWPE to $20/TWPE) and more markedly for bottom ash ($314/TWPE to $456/TWPE; based on a 50 MW threshold). Ratios for the FGD and landfill leachate wastestreams are unaffected. See Table 3-2 below for details.
3.1 Compliance Costs Compliance costs for the technology options are not affected by the treatment of non-detects and the relevant costs are therefore the same as reported in Table 2-1 above.
3.2 Loading Reductions
Table 2-2 presents estimated pollutant removals for each wastestream and technology option when revising loadings using an altern ative treatment of non-detects.

Table 3-1: Total Annual Pollutant Removals

Wastestream Technology Option Pollutant Removals (TWPE/year) Incremental Pollutant Removals (TWPE/Year) FGD Chemical Precipitation 706,133 706,133 Chemical Precipitation + Biological 825,753 119,620 Chemical Precipitation + Evaporation Not estimated Not estimated Fly Ash Dry Handling 171,398 171,398 Bottom Ash Dry Handling for Units > 400 MW 172,835 172,835 Dry Handling for Units > 50 MW 236,402 63,567 Landfill Leachate Chemical Precipitation 29,574 29,574 Source: U.S. EPA Analysis, 2015.



### 3.3 Cost-Effectiveness
Table 2-2 presents estimated cost-effectiveness by wastestream and technology option analyzed by EPA for the sensitivity analysis.

Table 3-2: Total Annual Pollutant Removals

Wastestream Technology Option Total Costs (million 1981$) a Cost Effectiveness (1981$/TWPE) Incremental Cost Effectiveness (1981$/TWPE) FGD Chemical Precip itation $41.7 $59.0 $59.0 Chemical Precipitation + Biological $72.1 $87.4 $254.7 Chemical Precipitation + Evaporation $368.3 Not calculated b Not calculated b Fly Ash Dry Handling $3.5 $20.2 $20.2 Bottom Ash Dry Handling for Units > 400 MW $72.5 $419.6 $419.6 Dry Handling for Units > 50 MW $108.1 $457.3 $559.8 Landfill Leachate Chemical Pr ecipitation $21.4 $722.8 $722.8 Source: U.S. EPA Analysis, 2015.

a Costs restated in 1981 dollars based on the Construction Cost Index (CCI 1981 /CCI 2013 = 0.370) b Pollutant removals for chemical precipitation + evaporation technology is not available and therefore cost effectiveness was not calculated.



### 4 References U.S. Environmental Protection Agency (U.S. EPA). 2015a. Regulatory Impact Analysis for the Effluent Limitations Guidelines and Standards for the Stea m Electric Power Generating Point Source Category (RIA) (DCN SE05976).September 25, 2015 Abt Associates | Wastestream Control Technologies Cost-Effectiveness | pg 4 

### U.S. Environmental Protection Agency (U.S. EPA). 2015b. Technical Development Document for the Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category (TDD) (DCN SE05904).