CCR costs are at least
$50 billion over 100 years for U.S. power plants
With
the big potential to beneficiate impounded flyash the gross cost could be much
higher than $50 billion but byproduct sales could put the net cost at less than
$50 billion.
One
estimate of costs was provided several years ago by Sam Yoder, P.E., and Robynn
Andracsek, P.E., Burns & McDonnell (see Mcilvaine recorded interview with Robynn)
Compliance costs are significant for short-term and long-term. EPA estimated
that the rule would impose 12 regulatory costs: (1) Groundwater monitoring; (2)
bottom liner installation; (3) leachate collection system installation and
management; (4) fugitive dust controls; (5) rain and surface water
run-on/run-off controls; (6) disposal unit location restrictions (including
water tables, floodplains, wetlands, fault areas, seismic zones, and karst
terrain); (7) closure capping to cover units; (8) post- closure groundwater
monitoring requirements; (9) impoundment structural integrity requirements; (10)
corrective actions (CCR contaminated groundwater cleanup); (11) paperwork
reporting/recordkeeping; and (12) impoundment closures and conversion to dry
handling. According to EPA, the rule may affect 414 coal-fired electric utility
plants and calculates the cost of the rule over a 100-year period in part
because a CCR unit's life spans 40 to 80 years. EPA's estimate of nationwide
compliance is an average annualized cost of approximately $509 million per year.
However, since these values are for all affected facilities combined, this is of
little comparison value for understanding the costs at an individual pond or
facility.
One
compliance solution is to undergo a wet to dry conversion for which costs can
vary drastically, depending on the footprint available at each plant ($30
million to $90 million). Similarly, the closure of a pond can vary greatly from
depending on the size and quantity of CCR material in the pond. Some have seen
costs as high $80 million to $100 million; however, most have been in the $30
million to $50 million range.
Potential corrective actions, such as a pump and treat system or in situ
technology, have significant unknown and critically important costs. As
utilities are considering future closure options, the possibility of groundwater
impacts should be taken into account for those impoundments that remained active
after October 19, 2015. For these impoundments, clean closure could be more cost
effective in the long run than a cap-in-place option, which has the potential
for years of corrective action. Feasibility studies evaluating the potential for
groundwater impacts may be useful at this point in time, for strategic cost
savings down the road.
Given
the short time frame for executing projects associated with the CCR rule, the
best information on compliance costs will only be available after the fact.