PB81-118395
The Cost of Alternative Flue G33 Desulfurization
(FGD) Sludge Disposal Regulations
SCS Engineers
Long Beach, CA
Prepared for
Municipal Environments! Research Lab.
Cincinnati, OH
Nov CO
I
I
(
I
k
I
-------
TECHNICAL REPORT DATA
(Phase read /miuvcuohs on the reverse before completing)
1. REPORT NO. '2.
EPA-600/2-R0-178
3. flETLfjENT'S ACCESSiO^NO.
ml 11889 5
4. TITLE AND SUBTITLE
The Cost of Alternative Flue Gas Desulfurization (FGD'
Sludge Disposal Regulations
5. REPOK .* DATE
November 1980
6. PERFORMING ORGANIZATION CODE
7. AUTHOFKS)
John P. Woodyard
Howard L. Rishel
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
SCS Engineers
4014 Long Beach Boulevard
Long Beach, California 90807
10. PROGRAM ELEMENT NO.
C73DIC
11. CONTRACT/GRANT NO.
68-03-2471
12. SPONSORING AGENCY NAME AND ADORESS
Municipal Environmental Research Laboratory—Cin., OH
Office of Research and Development
U.S. Environmental .'rotertian Agency
Cincinnati, Ohio 45268
13. TYPE OF REPORT AND PERIOD COVERED
Sept t.fl flnri ] 1 OKf)
1*."SPONSORING AGtViCY CODE
EPA/600/14
15. SUPPLEMENTARY NOTES
Project Officers: Donald E. Sanning, (513) 684^7871
Oscar W. Albrecht, (513) 684-4216
16. ABSTRACT
In this report, the state of FGD acceptance in the utility industry is
described. The various sludge treatment and disposal opticus are ueliiieateu.
Current federal and state regulations affecting FGD disposal are discussed, and
then placed in a conceptual framework from which regulatory scenarios are
developed. The scenarios are then applied to the current (1980) and projected
(1985) FGD capacity to estimate what changes, if any, would need to be made -
in current utility operations to achieve compliance. Using the best available
cost data base for these disposal alternatives, region-specific cost estimates are
developed for 10 model power plants for each of five disposal options. Applying
each regulatory scenario, the cost impact on the utility industry is then estimated
for the £0 different situations.
17. KEY WORDS ANO OOCUMt NT ANALYSIS
¦< DESCRIPTORS
b. IDENTIFIE RS/OPEN ended terms
c. COSATl 1 idilT.toup
flue gases
desulfurization
utility industry
sludge disposal
regulations
cost estimates
power plants
flue gas desulfurization
sludge treatment
cost data base
FGD sludge disposal
13B
TJ. UIS rsiBUTION STATEMENT
Release to Public
19 SFCUHITY CLASS film Itcpnrtt
^.classified.
21. NO Of PAC.eS ""
135
20 SECURITY CLASS iTlux iu$e)
Unclassified
22. PRICE
CPA Farm 2230-1 (» JJ) }
9
-------
PflRl-118895
EPA-600/2-80-178
November 1980
THE COST OF ALTERNATIVE
FLUE GAS DESULFURIZATION (FGD) SLUDGE
DISPOSAL REGULATIONS
by
John P. Woodyard
Donald E. Sannlng
Oscar W. Albrecht
Solid and Hazardous Waste Research Division
Municipal Environmental Research laboratory
Cincinnati. Ohio 45268
MUNICIPAL ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U. S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
Howard L. Rishel
SCS ENGINEERS
Long Beach, California 90807
Contract Number-
68-03-2471
Project Officers
-------
DISCLAIMER
This report has been reviewed by the Municipal Environmental
Research Laboratory, U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify chat the
contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names
or commercial products constitute endorsement or recommendation
for use.
U
-------
FOREWORD
The Environmental Protection Agency was created because of
Increasing public and governmental concern about the dangers of
pollution to the health and welfare of the American people. Nox-
ious air, foul water, and spoiled land are tragic testimony to
the deterioration of our natural environment. The complexity of
that environment and the Interplay between its components require
a concentrated and integrated attack on the problem.
Research and development constitute that necessary first
step in a solution of the problem, and Involve a definition of
the problem, the measurement of Its impact, and a search for
solutions. The Municipal Environmental Research Laboratory de-
velops new and improved technology and systems for the preven-
tion, treatment, and management of wastewater and solid and haz-
ardous waste pollutant discharges from municipal and community
sources; for the preservation and treatment of public drinking
water supplies; and to minimize the adverse economic, social,
health, and aesthetic effects of pollution. This publication 1s
one of the products of that research; a most vital communications
link between the researcher and the user community.
This report presents the technical cost Impact analysis of
several conceptual flue gas desulfurlzatlon (FGD) sludge disposal
scenarios within the utility industry. The scenarios are struc-
tured to demonstrate the incremental cost of increasingly strin-
gent technical requirements, and are not intended to parallel any
proposed EPA regulations for FGD sludge disposal. The results
provide a valuable tool to policy makers in both the regulatory
agencies and utility industry.
FGD sludges have been classified as "special wastes" under
Section 3004 of the proposed Resource Conservation and Recovery
Act (RCRA) regulations. As such, a given sludge wilt be classi-
fied as either hazardous or nonhazardous according to the Section
3001 criteria, and Its disposal will be regulated accordingly.
Specific technical and administrative requirements for nonhazard-
ous FGD sludge disposal have not been proposed, although final
111
-------
regulations under Section 4004 of RCRA apply to disposal of non-
hazardous waste. The technical and economic impact assessments
1n support of specific disposal regulations for the utility in-
dustry are being contracted by EPA and should be completed by
mid-1982.
Francis T. Mayo
D1rector
Municipal Environmental Research
Laboratory - Cincinnati
iv
-------
ABSTRACT
In this report, the state of FGD acceptance in the utility
industry 1s described. The various sludge treatment and disposal
options are then delineated. Current federal and state regula-
tions affecting FGD sludge disposal are discussed, and then
placed in a conceptual framework from which regulatory scenarios
are developed. The scenarios are then applied to the current
{1 *>80) and projected (1985) FGO capacity to estimate what
changes, if any, would need to be made in current utility opera-
tions to achieve compliance. Using the best available cost data
base for these disposal alternatives, region-specific cost esti-
mates are developed for 10 model power plants for each of five
disposal options. Applying each regulatory scenario, the cost
impact on the utility Industry is then estimated for the 50
different situations.
This report was submitted 1n fulfillment of Contract No. 68-
03-2471 by SCS Engineers under the sponsorship of the U.S. Envi-
ronmental Protection Agency. This report covers a period from
September 1976 to April 1980.
v
-------
CONTEXTS
01 scl aimer 11
Foreword... . .... 111
Abstract v
Figures 1x
Tables x
Ac know! edgements xv
1. Introduction 1
Purpose........ 2
Scope 2
2. Concl uslons.. 4
3. Recommendations 8
4. Profile of the Utility Industry and Its FGD
Capacity. 10
Introductl on .10
History of utility industry....... 10
Utility power generation and sales 11
Environmental considerations 1n power
generation. 12
5. The Technology Available for FGD Sludge
D1 spnsal 16
FGD sludge generation 16
FGD sludge treatment and disposal
al ternatlves .. .19
6. The Regulation of FGD Sludge 39
General 39
Clean A1r Act and amendments 39
Federal Water Pollution Control Act
(PL 92-500) 40
Resource Conservation and Recovery Act
of 1976 (PL 94-580) 40
The Marine Protection, Research, and
Sanctuaries Act of 1972 (PL 92-532).. 42
Disposal to mines. 44
State FGD disposal regulations 46
Regulatory scenarios discussions .....46
7. Development of Hodel Power Plants and Associated
FGD Sludge Disposal Costs.
Introduction
v11
-------
CONTENTS (continued)
Mods'' plant attributes 51
Unit cost development. 58
Discussion of unit cost result .63
Industry application of unit costs 63
8. Utility Industry Response to Regulatory
Scenarios 73
Methodology and assumptions for the cost
Impact analysis 73
Estimated industry response to more
stringent regulations. 73
Cost Impact of the utility industry
response. 76
9. Analysis of Estimated Utility Industry Impacts 110
References lib
vi1<
-------
FIGURES
Number Page
1 Overview of available FGD sludge management
options, Including example ranges of sludge
solids content. .........23
2 Description of iU Conversion Systems' Poz-O-Tec
process vor FGD sludge stabilization 31
3 Dravo process flow diagram showing three
possible disposal options 33
4 Status of wet FGD sludge disposal 34
5 Trends 1n predominance of FGD sludge disposal
practices among utilities .36
6 Alternatives for federal regulation of FGD
sludge disposal under the Resource Conservation
and Recovery Act 43
-------
TABLES
Number Page
1 Generating Capacity by Ownership for all
Electric Utilities in the United States, 1970 10
2 Electrical Sales by Customer, 1970.. 11
3 United States Electrical Generating Capacity
In Mid-1977 12
4 Existing and Projected Generating Capacity by
Plant Type 13
5 Committed and Projected Honregenerable FGO
Capability, 1975-1935 (MW> 15
6 Estimated FGD Sludge and By-Product Production
Rates for Coal-Fired Facilities 17
7 Examples of Typical Engineering Properties of
FGD Sludge 20
8 Concentration of Constituents in Scrubber
Liquors 21
9 Companies Providing Commercial Fixation or
Disposal Service...... 29
10 Alternative Disposal Practices Available for
Utility-Generated FGO Sludge 38
11 State Solid Waste Regulations Pertaining to
Selected FGD Systems 47
12 Alternate Regulatory Scenarios for Flue Gas
Cleaning Sludge Oisposal .....49
13 Manifestation of Regulatory Scenarios 50
14 Model Plant Location and Fuel Characteristics si
15 Model Plant Regional Characteristics.... 53
15 Regional Land Prices.... 54
x
-------
TABLES (continued)
Number Page
17 Regional Construction Cost Indices 55
18 Operating and Maintenance Regional Cost Indices......56
19 Summary of Model Plant Attributes 57
20 Example Annual Revenue Requirements 59
21 Adaptation of TVA Conceptual Design Costs: An
Example for Western Urban Unllned Ponding ..61
22 Example of Model Plant Lifetime Revenue
Commitments (in K$)..... C2
23 Estimated Capital Investment (K$) for All Model
UtH 1 ti 64
24 Estimated Capital Investment (S/kW Capacity)
for All Model Utilities 65
25 Estimated First-Year Operating Revenue
Requirements (K$) for All Model Utilities 66
26 Estimated First-Year Operating Revenue
Requirements (mllls/kWh) for All Model
Utilities
27 Estimated Total Lifetime Revenue Requirements
(K$) for All Model Plants 68
28 Estimated Total Lifetime Revenue Requirements
(mill s/KwH) for All Model Plants 69
29 Estimated Present Value Lifetime Revenue
Requirements (K$) for All Model Plants.............70
30 Estimated Present Valu* Lifetime Revenue
Requirements (mills/KwH) for All Model Plants .71
31 Distribution of Utility FGO Sludge Olsposal
Capacity, Scenario No. 1, 1980.. 74
32 Distribution of Utility FGO Sludge Disposal
Capacity, Scenario I!o. 1, 1985 75
33 Distribution of Utility FGO Sludge Olsposal
Capacity, Scenario No. 2, 1980 77
xl
-------
TABLES (continued)
Number Page
34 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario No. 3, 1980 ..... 78
35 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario Ho. 4, 1980 79
36 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario Ho. 5, 1980 .....80
37 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario Ho. 2, 1985 81
38 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario Mo. 3, 1985 82
39 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario No. 4, 1985 83
40 Distribution of Utility FGD Sludge Disposal
Capacity, Scenario No. 5, 1985 84
41 Regulatory Scenario No. 1, Year 1980, Totat
Future Revenue Commitments 85
42 Regulatory Scenario No. 2, Year 1990, Total
Future Revenue Commitments .86
43 Regulatory Scenario No. 3, Year 1980, Total
Future Revenue Commitments 87
44 Regulatory Scenario No. 4, Year 1980, Total
Future Revenue Commitments....... .... 88
45 Regulatory Scenario No. 5, Year 1980, Total
Future Revenue Commitments. ...89
46 Regulatory Scenario No. 1, Year 1985, Total
Future Revenue Commitments.............. ......90
47 Regulatory Scenario No. 2, Year 1985, Total
Future Revenue Commitments.... 91
48 Regulatory Scenario No. 3, Year 1985, Total
Future Revenue Commitments.. ..92
49 Regulatory Scenario No. 4, Year 1985, Total
Future Revenue Commitments.... 93
xii
-------
TABLES (continued)
Number Page
50 Regulatory Scenario No. 5, Year 1985, Total
Future Revenue Commitments 94
51 Regulatory Scenario No. 1, Year 1980, Total
Capital Investments 95
52 Regulatory Scenario No. 2, Year 1980, Total
Capital Investments... 96
53 Regulatory Scenario Ho. 3, Year 1980, Total
Capital Investments 97
54 Regulatory Scenario No. 4, Year 1980, Total
Capital Investments 98
55 Regulatory Scenario No. !>, Year 1980, Total
Capital Investments 99
56 Regulatory Scenario No. 1, Year 1985, Total
Capital Investments... .100
57 Regulatory Scenario No. 2, Year 1985, Total
Capital Investments 101
58 Regulatory Scenario No. 3, Year 1985, Total
Capital Investments 102
59 Regulatory Scenario No. 4, Year 1985, Total
Capital Investments 103
60 Regulatory Scenario No. 5, Year 1985, Total
Capital Investments .104
61 Regulatory Scenario No. 2, Year 1980, Total
Displaced Capital Investments 105
62 Regulatory Scenario No. 3, Year 1980, Total
Displaced Capital Investments 106
63 Regulatory Scenario No. 4, Year 1980, Total
Displaced Capital Investments
64 Regulatory Scenario No. 5, Year 1980, Total
Displaced Capital Investments ...108
65 Summary of Regulatory Scenario Impacts
for 1980 HI
xiii
-------
TABLES (continued)
Number Page
66 Summary of Regulatory Scenario Impacts
for 1985... 112
67 Summary of Regulatory Scenario Impacts
to Consumers (mills/kWh) 114
xlv
-------
ACKNOWLEDGEMENTS
This document 1s the result of an extensive technology re-
view and cost analysis, based upon Information produced as part
of the EPA FGC waste disposal research program. The guidance and
assistance provided by the Project Officers, Mr. Donald Sanning
(technology) and Mr. Oscar Albrecht {economics), of the Municipal
Environmental Research Laboratory, U.J. Environmental Protection
Agency, Cincinnati, Ohio, is gratefully acknowledged. Messrs.
Julian Jones of IERL/RFP and Timothy Fields, John Heffelf1nger,
and Michael Shannon of OSW also made valuable contributions to
the project.
Special thanks go to the industry review committee, who con-
tributed their time and knowledge to the review of all major
project outputs. Members of the committee are listed below:
• J. Wayne Barrier, Tennessee Valley Authority.
t James J. Crowe, Tennessee Valley Authority.
• Gary Merrltt, Pennsylvania Department of Environmental
Resources.
• Robert D. 0*Kara, Duquesne Light Company.
• Randall Rush, Southern Company Services.
• Robert Van Ness, Louisville Gas and Electric.
SCS project participants were: Curtis J. Schmidt, Project
Director; John P. Woodyard, Project Manager; Howard L. Rishel,
Project Economist; and Brian West, Project Engineer.
The assistance of Howard W. Pifer and Robert L. Hayes, of
Putnam, Hayes, and Bartlett, If also gratefully acknowledged.
xv
-------
SECTION 1
INTRODUCTION
The Clean A1r Act (CAA) of 1970 and Its amendments have
placed air pollutant emission limits on a variety of stationary
source categories. Under Subpart 0 of the regulation, emission
standards were established for the sulfur Oxides formed from the
combustion of fossil fuels (specifically coal and oil) in steam
electric power plants. The only commercially available means of
meeting sulfur dioxide emission limits are by use of low-sulfur
fuels or tail-end scrubbing of power plant flue gases to remove
sulfur dioxide.
Vast reserves of low-sulfur coal are being mined in the
Western United States for use by utilities nationwide. Many
power plants in the Eastern and Western United States have never-
theless been retrofitted with tail-end flue gas desulfurlzation
(FGD) systems due either to the rising price and high transporta-
tion cost of low-sulfur coal from the West, or to stringent state
S02 emission regulations. The trend toward FGD was further rein-
forced by amendments to the CAA of 1977, which ultimately require
FGD on all new coal-fired power plants.
Currently, the predominant technology for FGD is wet scrub-
bing with a Hme-, limestone-, or sodium-based sorbent. A major
drawback to this method involves disposal of large volumes of by-
product sludge. In 1973, the U.S. Court of Appeals remanded por-
tions of the New Source Performance Standards (NSPS) for power
plants to EPA for more information on FGD sludge disposal. EPA
acknowledged the potential for adverse environmental effects from
FGD sludge disposal, and recommended chemical fixation as the
most acceptable method of treatment and disposal.
In order to further quantify potential envlronmental prob-
lems and Identify possible solutions, EPA Initiated a ssjor re-
search program 1n 1972, entitled, "Control of Waste and Water
Pollution from Flue Gas Cleaning Systems." The five principal
area* of investigation were as follows:
• Environmental assessment of FGD waste disposal.
• FGD waste disposal economics.
» Alternate disposal methods.
• FGD waste utilization.
» Power plant water use.
1
-------
A 1977 report by SCS Engineers (25' summarized the FGi)
sludge disposal data base established thus far. The SCS study
also recommended that any regulation of FGO sludge disposal be
flexible enough to account for the effect of site- and sludge-
specific variables on environmental impact potential.
The regulation of FGD sludge disposal to date has been per-
formed on the state and local level through the interaction of
solid waste, water quality, and other appropriate agencies. In
the absence of specific federal guidance, the regulation of FGO
sludge disposal has, by necessity, been site-specific. The pro-
mulgation of the Resource Conservation and Recovery Act (RCRA) of
1976, however, has posed the possibility of certain power plant
wastes being defined as "hazardous." Should FGO sludge. In par-
ticular, be defined as a hazardous waste, sludge disposal opera-
tions would be subject to uniform stringent regulations for stor-
age, handling, and disposal.
The physical and chemical properties of FGU sludges do, how-
ever, establish a need for regulation. The question of how to
regulate FGD sludge still remains. Such management on the fed-
eral level could take a variety of forms, ranging from legisla-
tive control of state-permitting procedures to legislation and
enforcement of minimum treatment and disposal requirements. Any
approach which differs in severity from the current approach will
have an associated economic impact on the utility Industry.
PURPOSE
This study was initiated to assess the cost Impacts of vari-
ous degrees of hypothetical FGD sludge disposal regulations on
the utility Industry. It was noted in a previous study (25) that
the potential environmental Impact from waste disposal (in gen-
eral) to land will vary according to many site-specific factors
other than the waste characteristics. The specific purpose of
this study is, therefore, to quantify the incremental cost of
different degrees of regulation. The hypothetical regulatory
scenarios presented In this report imply various degrees of envi-
ronmental protection; however. It is not within the scope of this
report to define the degree of environmental protection achieved
by each of these scenarios.
SCOPE
The study was approached as a conceptual cost Impact analy-
sis rather than as a traditional economic impact analysis. Util-
ities electing to install wet FGD systems do so with the under-
standing that FGD sluu'^e disposal will be an integral part of the
FGD system. FGD sludgr. disposal typically accounts for 5 to 20
percent of the total annual cost of an FGD system (1). Recogniz-
ing the high cost and "emerging technology" status of sludge
treatment and dlsposa', FGD has rlready been rejected by some
utilities as an economically unacceptable tftttnology. A more
stringent FGD sludge disposal regulation need not, by itself,
2
-------
result in a major shift toward alternative desulfurization
technologles.
In this report, the state of FGD acceptance in the utility
industry is described. The various sludge treatment and disposal
options are then delineated. Current federal and state regula-
tions affecting FGD sludge disposal are discussed, and placed in
a conceptual framework from which regulatory scenarios are devel-
oped. The scenarios are then applied to the current (1980) and
projected (1985) FGO capacity to estimate what changes, if any,
would need to be made in current utility operations to achieve
compliance. Using the best available cost data base for these
disposal alternatives (4), region-specific cost estimates are de-
veloped for 10 model power plants for each of five disposal op-
tions. Applying each regulatory scenario, the cost impact on the
utility industry 1s then estimated for the 50 different situa-
tions.
3
-------
SECTION 2
CONCLUSIONS
1. The CAA and Its amendments have prompted the widespread im-
plementation of wet FGD systems by utilities 1n effort to meet
sulfur dioxide emission limitations. This tren' as been further
enhanced by the current U.S. energy policy fav- j the use of
native coal reserves. The end result is a project»d substantial
Increase In FGD Implementation in the United States through 1985.
2. The predominant available FGD technologies generate large
volumes of by-product sludges requiring disposal. These sludges
have been and will continue to be disposed of to land, either to
ponds as a slurry or to landfills as a dry material. Ponding Is
currently the most common method of FGD sludge disposal; sludge
ponds are typically lined with 1n-s1tu soils, although synthetic,
and Imported natural liners (particularly clay) have begun to
find application. The disposal of treated and/or dewatered
sludge to landfill 1s rapidly gaining favor, and should account
for a majority of new sludge disposal capacity by the early
1980's. FGD sludge landfills are currently used to dispose of
mechanically dewatered sludqe, dewatered sludge mixed with dry
ash, and chemically stabilized sludge.
3. The data base established thus far for FGD sludge indicates a
need to regulate its disposal, primarily due to the potential for
ground water contamination and land degradation (waste instabil-
ity) resulting from the disposal of large volumes of this mater-
ial to land. The regulation of FGD sludge disposal to date has
been performed on the state level, typically involving state
solid waste and water quality agencies In a site-specific permit-
ting process.
4. The federal regulation of FGD sludge disposal is specifically
considered. Current federal laws which may Impact on the future
regulation of FGD sludge disposal include the RCRA of 1976 (PL
94-580), the CAA amendments of 1977, the Marine Protection, Re-
search, and Sanctuerles Act of 1972 (PL 92-532), the Federal Wa-
ter Pollution Control Act (PL 92-500), and the Federal Surface
Mining Control and Reclamation Act of 1977 (PL 95-87). The dis-
posal of FGD sludge Is specifically addressed only 1n RCRA.
5. The Impact of federal FGD sludge disposal regulations on the
utility Industry would of course depend on the severity of t'te
regulation. Recent research and current regulatory practice
4
-------
Indicate that ground water protection and the prevention of
permanent land degradation are the principal environmental
concerns when disposing of FGD sludge. The degree of protection
which is necessary will be specific to each proposed disposal
site.
In order to assess the cost impact of a range of regulatory
approaches, a set of five regulatory scenarios was developed.
Beginning with scenario Ho. 1, each scenario represents increas-
ing severity of regulation based on (1) added protection of
ground water and (2) added sludge stability for improved site
reclamation potential, or (3) a universal requirement for sludge
treatment and disposal regardless of site-specific factors. The
five regulatory scenarios considered In this study are as fol-
1 ows:
Ho. 1. Federal Advisory-State Legislation and Enforcement:
Simple permitting; stabilization not required and not
commonly used.
No. 2. Federal Advisory-State Legislation and Enforcement:
Site-specific evaluation with stabilization sometimes
required.
Mo. 3. General Federal Legislation-State Enforcement: Physical
stabilization required; no ponding.
No. 4. Comprehensive Federal Legislation-State Enforcement upon
Approval: Chemical stabilization required 1n urban
areas.
No. S. Comprehensive Federal Legislation and Enforcement-No
Stat* Involvement: Chemical stabilization universally
required; specifications given for the stabilization
technique.
6. An accurate assessment of the cost impact of each scenario on
the utility Industry requires knowledge of the cost of each dis-
posal alternative to each FGO-equlpped plant. An approximation
of these cost Imoacts was developed using a set of 10 model
plants, representing three geographic regions, four coal types,
and urban and rural locations. For each model plant, capital
cost, annual operating cost, and lifetime revenue requlrements
were estimated for each of six disposal options. These disposal
options were defined as follows:
• Unllned ponding.
• Clay-lined ponding.
• Dry (dewater) and landfill.
• Dravo.
• IUCS.
• Dry {dewater), mix, and landfill.
S
-------
Each of the coal-fired utility generating plants projected to
be on line by 1980 and 1985 was then assigned to one of the 10
model plant categories to produce an approximate Industry profile
of waste generating capacity. The profile was subjected to each
regulatory scenario to estimate how each utility would shift from
its preferred disposal option to Its remaining least-cost dis-
posal option under the revised regulatory scenario. In this man-
ner, the cost Impacts to each utility and to the industry as a
whole were estimated as the incremental cost of complying with
each successive degree of regulation.
It should be emphasized that this approach includes only
plants that will be on line by mid-1980, or those that will be on
line by mid-1985. Although cost impacts were estimated for the
entire remaining life span of each of these plants, a declining
operating scenario was used 1n which annual generation decreases
over the life span of each plant. Thus, the plants in the 1980
group included substantially more retrofit situations than for
the predominantly younger 1985 group of plants. The result of
this shift in group composition 1s a substantial Increase 1n to-
tal remaining lifetime generation, even though coal-f1r«d genera-
tion capacity 1s expected to Increase only moderately between
1.980 and 19S5.
7. From Section 8, It appears that, In the absence of additional
regulatory constraints, the utility Industry from a post-1980
perspective will be committed to spending close to $2.6 billion
(1980 dollars), and from a post-1985 perscectlve will be commit-
ted to spending over $3.1 billion (1980 dollars) for FGO sludge
disposal. Scenarios Mo. 2 through 5 are expected to add from $18
to $972 million to those future revenue commitments for the post-
1980 estimate, aid from 135 to $2,324 million for the post-1985
estimate. This relatively modest Increase in future revenue com-
mitments 1s due to two factors: (1) older plants using high-
technology retrofits will be 5 years older by 1985, so that their
post-1985 revenue commitments will be substantially reduced; and
(2) new plants coming on line by 1985 will have their entire use-
ful life ahead of them; they will be situated on cheaper, rural
land, and will have selected the cheaper, nonretrof1t disposal
options as part of their original designs.
This post-1980 to post-1985 shift in future generation to
newer plants (combined with an absolute Increase 1n future coal-
fired generation) allows the average cost per kilowatt hour (In
terms of 1980 dollars) to decrease. The result 1s that the aver-
age future cost (1980 dollars) tc the consumer for FGD sludge
disposal Is expected to range from 1.017 mills (scenario No^ 1)
to 1.400 mills (scenario No. 5) per kilowatt hour after 1980, and
from 0.759 (scenario Mo. 1) to 1.321 (scenario No. 5) mills per
kilowatt hour after 1985. It should be emphasized again that
these cost estimates do not Include plants coming on Hire after
1985.
6
-------
8. In general, more stringent disposal requlation resulted in
(1) lower per unit capital requirements than for current disposal
practices, and (2) higher lifetime revenue requirements as a re-
sult of higher operating costs (labor and raw materials in parti-
cular).
9. The Industry profile for 1980 shows that sludqe ponding 1s
more prevalent 1n the western United States than In the East, due
in most cases to more favorable site-specific conditions. The
cost impact of more stringent regulatory scenarios (particularly
the universal stabilization requirement) in the West was propor-
tionately greater than for the Midwest or East.
7
-------
SECTION 3
RECOMMENDATIONS
Research recommendations resulting from this study may be
categorized Into two general areas: (1) incorporating the diver-
sity of local utility conditions Into the analysis, and (2) up-
dating the current data base to reflect changes 1n the regulatory
climate and che evolution of F60 technologies.
With regard to the first area, the conceptual nature of this
study required the use of many simplifying assumptions. As a re-
sult, Important cost factors Mere not accounted for which could
significantly affect the costs projected in this study. Candi-
dates for Inclusion In a more 1n-depth analysis Include thr fol-
lowing characteristics:
• Local administrative overhead rates.
t Local debt/equity ratios.
• Local Interest/return to equity rates.
• Effective Income tax rates.
• Local real estate tax rates.
• Local land cost.
t Local construction cost differentials.
• Local operating cost differentials.
• Local fuel characterlsties.
• Local regulatory climate.
In addition to addressing these factors on a local rather
than a regional basis, any subsequent research embracing these
plant-by-plant variations should also consider the effects that
current sludge disposal capital investments and remaining plant
lives have on the selection of either a sludge disposal method or
a compliance strategy for sulfur oxide control. In this study,
sunk capital costs and remaining plant life span were not allowed
to Influence this choice, as they would 1n practice.
Also, In this study, life cycle average unit costs pe** kilo-
watt hour of generation for a new 500-HW plant were appliel to
plants of all sizes and ages. Such simplifying assumptions
should be avoided 1n a more extensive analysis of economic Im-
pact. Use of FGD sludge disposal cost estimates for actual sys-
tems will also allow for Individual pltnt*sca1e economies, and
make more precise allowance for the Impact that the remaining
plant operating life has on sludge disposal land requirements.
ft
-------
«» V.'
^ofecfo
Another topic of possible interest to EPA, which could not
be explored in this study, is the important interrelationship be-
tween sludge disposal cc ts, electricity rate schedules, subse-
quent changes in electricity demand, and the ultimate incidence
(by customer type) of FGD sludge disposal costs. To expedite the
analysis, 1t was assumed that electricity demand was perfectly
Inelastic with respect to price changes, and that sludge disposal
costs became revenue requirements for the same year in which they
were Incurred. Although this approach is appropriate for a first
approximation of regulatory impacts, the pricing arid demand mech-
anisms deserve additional consideration. Sludge disposal costs
may be lagged over time and have differential impacts on various
classes of customers. Moreover, demand elasticity may vary by
customer class. The distribution of FGD sludge disposal costs
will require additional evaluation before the Impacts on various
'lasses of consumer can be adequately determined.
The other general area wliich deserves additional study 1s
the rapid evolution of FGD sludge disposal technology in response
to the changing regulatory climate, and Its resulting cost impact
on the utility Industry. Ongoing field research by EPA will fur-
ther enhance the current sludge disposal data base. EPA guide-
lines possibly resulting from this research, may lead to the de-
velopment of regulatory scenarios which could not be anticipated
here. Dry FGD technologies (spray dryers and dry injection) are
also gaining utility acceptance, and provide one more option for
compliance with both air and solid waste regulation.
Specific areas which could be enhanced 1n an update of this
study Include:
• Second-generation FGD sludge disposal technologies.
t Trends in FGD.
• Updated forecasts of FGD Implementation.
• Long-range utility power generation trends.
• Impact of RCRA and MSAA on FGD sludge management.
Consideration of the above-named technical and Institutional
changes, combined with a more exact analysis of disposal econo-
mics, would provide a solid foundation for the economic Impact
analysis required 1n conjunction with impending new federal regu-
lations for FGD sludge disposal.
9
-------
SECTION 4
PROFILE OF THE UTILITY INDUSTRY
AND ITS FGD CAPACITY
INTRODUCTION
Electric utilities provide for the generation, transmission,
and distribution of electric power. Ownership of utilities is
characterized by two distinct owner categories: publicly owned
and privately owned (investor). Publicly owned systems can be
cooperatives, or can be owned by municipal or federal agencies,
or others. Not all of tho more than 3,300 utilities in the
United States provide all three services mentioned above. Only
about 1,000 larger utilities carry out generation operations.
Many smaller utilities Instead purchase power from qenerators for
distribution to their customers. Many utilities have also en-
tered into pools with adjacent systems to provide energy to one
another under heavy load or emergency conditions.
HISTORY OF UTILITY INDUSTRY
The first utility system was established on line in 1880
with the completion of Thomas Edison's steam electric power plant
in New York City. The industry experienced consistent but re-
stricted growth for the next half-century because of limited en-
ergy demand. After World War II, consumer demand for electricity
began to Increase dramatically. Since then, per capita electri-
cal consumption has grown at an annual rate of 6 percent, and to-
tal electrical consumption at an annual rate of 7 percent. By
1977, total U.S. generating capacity was 545,364 MW. The table
below summarizes generating capacity by ownership types as of
1970 (28).
TABLE 1. GENERATING CAPACITY BY OWNERSHIP FOR ALL
ELECTRIC UTILITIES IN THE UNITED STATES, 1970
Number of Generatino Capacity Annual Generation
Ownershi p Systems Percent (MWxlOJ) Percent" (MWxlO0) Percent
Investor 250 24.6 265 76.8 1,180 77.0
Federal 2 0.4 40 11.« 190 12.4
10
-------
TABLE 1 (continued)
Number of Generating Capacity Annual ^Generation
Ownership Systems Percent (MWxlO ) PercervT" (MWxlO0) Percent
Public
700
68.6
35
10.1
140
9.1
Co-op
65
6.4
5
1.5
22
1.5
Total
1,017
100.0
345
100.0
1,532
100.0
UTILITY POWER GENERATION AND SALES
The electric utility industry is limited to the production
and delivery of one product: electricity. Electrical power can
not be practically stored, yet utilities must be capable of meet-
ing consumer demand at any time. The capability to meet consumer
needs on demand is, therefore, the design parameter upon which
generating capacity is based. Except for a small fraction of
customers with 1nterruptable service, the most important factor
in utility performance is meeting peak consumer demand.
Utility customers can be divided into industrial, commer-
cial, and residential categories. Table 2 compares the electri-
cal consumption of these customers in 1970 (28).
TABLE 2. ELECTRICAL SALES BY CUSTOMER, 1970
Number of , Annual Sales
Customers Customers (x!0°) (MW x 10 ) Percent of Total*
Industrial 0.4 575 41
Commercial 8 325 18
Residential 55 450 24
Othftr — 60 17
* The Federal Energy Regulatory Commission (FERC) reports no expected
change 1n the above distribution of sales through 1990 (28).
Utilities exist either as public services or as regulated
monopolies. As a provider of a public service, a utility is ob-
ligated to supply its product to all customers in its service
area. Additionally, its rate structure must offer customers
within each class (i.e., industrial, cw»mercial, and residential)
equal service at equal cost. Utilities are protected against
11
-------
competition. However, they cannot discontinue unprofitable oper-
ations within their service areB. Doth the level of service and
the rates charged for that service are subject to regulation by
both state and federal agencies. Utility expenses are closely
monitored by regulating commissions to determine rates for each
class of service. Except for fuel clauses that allow utilities
to immediately pass along increases in fuel costs in the form of
higher rates, the industry is limited to regularly scheduled
hearings (e.g., every 6 months), when rate increases can be ap-
proved. Demand for electric power is relatively "inelastic" with
respect to utility rates because customers (particularly residen-
tial) have few suitable alternatives.
Fossil fuel-fired electric power plants accounted for 77
percent of total U.S. generating capacity and 81 percent of total
power generated in mid-1977. Table 3 presents a breakdown cf
generating capacity by fuel type.
TABLE 3. UNITED STATES ELECTRICAL GENERATING CAPACITY
IN MID-1977 (7)
Fuel
Coal
Oil
Gas
Nuclear
Hydro
Other
Percent of
Capaci ty
38
25
14
9
12
4
Coal 1s the most abundant fossil fuel in the United States.
Proven reserves are estimated to be sufficient to supply fos«il
fuel needs for 200 to 300 years. Before 1973, government projec-
tions indicated a future decrease In coal-fueled utility power
generation. Since that time oil price Increases and nuclear
plant construction blockages have resulted in revised projections
indicating substantial Increases 1n coal generation capacity.
Total electric power generation is expected to increase by 100
percent between 1980 and 1990 (28). Table 4, which presents
electric generating capacity projections based on more recent
(1977) FEA data (7), shows an estimated 72 percent increase be-
tween 1977 and 1995.
ENVIRONMENTAL CONSIDERATIONS IN POWER GENERATION
The production of both natural gas and low-sulfur oil (frow
domestic sources) has been declining for several years. Natural
12
-------
TABLE A. EXISTING AND PROJECTED GENERATING
CAPACITY BY PLANT TYPE*
Projected New
Capacity
Existing
(1977)
(1995)
Total
Percent
Percent
Percent
Plant Type
Capacity (MW) of Total
Capacity (MW)
of Total
Capacity (MW)
of Total
Coel
206,?58
38
T'8,739
38
354,997
38
Oil
134,615
25
25,093
6
159,708
17
Gas
75,548
14
.1,919
.5
77,467
8
Nuclear
48,697
9
174,189
45
222,886
24
Hydro
66,817
12
26,999
7
93,816
10
Other
3,867
1
1 ,933
.5
5,800
1
Unknown
9.562
_2
11,722
__3
21,284
_2
Total
545,364
100
390,594
100
935,958
100
-------
gas availability in particular has been limited since the late
1960's, resulting in a major industry switch to oil in previously
gas-fired power plants. Subsequent increases in the cost of fuel
oil from foreign sources have made coal and nuclear power more
attractive near-term energy sources for most utilities.
Coal combustion produces greater volumes of air pollutant
emissions than natural gas or fuel oil combustion. Particulate,
sulfur oxide, and nitrogen oxide emission limits were established
by the CAA of 1970 and its amendments. The control technology
for particulates is considered adequate to meet those emission
limits. Combinations of cyclone separators and electrostatic
precipitators (ESP's) ire the most common control strategies
used, achieving particulate collection efficiencies in excess of
99 percent. Fabric filters and wet scrubbers are also gaining
acceptance for utility control of particulate emissions.
The choice of control strategies for sulfur oxides 1s lim-
ited to the use of scarce and costly low-sulfur fuels, conversion
of the coal to a cleaner fuel (either through gasification or
physical/chemical coal-cleaning), and/or tail-end removal of sul-
fur oxides from the exhaust gas. The selection of the first al-
ternative alone may not be acceptable as. a means of long-term
compliance with emission limits. Physical coal cleaning, al-
though capable of removing a significant percentage of pyritlc
(Inorganic) sulfur from most coal supplies, cannot generally re-
move sufficient sulfur to meet NSPS, but may allow reductions to
meet State Implementation Plans (SIP), or can be used in combina-
tion with FGO. Chemical coal-clean1ng 1s In its infancy on the
utility scale. Tail-end wet scrubbing of S02 has by necessity
gained acceptance among utilities.
The vast majority of scrubber systems installed to date are
of the nonregenerable variety. These systems produce a slurry
from which only the liquid fraction may be recycled; a portion of
the fraction Is continuously purged and disposed of. As of June
1977, 28 operational FGD units had been installed on utility
scale boilers in the United States. Table 5 displays projected
FGO capability through the year 1985, based on available Informa-
tion. As shown In the sixth column, approximately 26,000 MW of
generating capacity 1s presently committed to use of FGD systems
by 1985. In addition, approximately 74,000 MW of generating ca-
pacity is being considered for FGD systems.
14
-------
TABLE 5. COMMITTED AND PROJECTED NONREGENERABLE
FGD CAPABILITY, 1975-1985 (MW)*
L1me Limestone Lime/ Double Total Total
Scrubbing Scrubbing Limestone Alkali Commi tted Projected
1975* 475 (2) 1 ,954 (9) 20 (?) 32 (1 ) 2 ,481 (14)
1980* 9,445 (23) 12,695 (35) 270 (3) 902 (4) 23,312 (65) 35,000
1985t 11,515 (28) 13,445 (37) 797 (4) J 26,659 (73) 100,000
- .. ¦ .... 111 ... . 1 1 ¦, ¦ ¦ .. . .. .
? Ref. 16.
f Numbers in parenthesis indicate number of scrubber units.
Jf
None committed beyond 1980.
-------
SECTION 5
THE TECHNOLOGY AVAILABLE FOR
FGO SLUDGE DISPOSAL
FGD SLUDGE GENERATION
Virtually all FGD systems are designed to react sulfur oxide
gases with selected solid or dissolved sorbents to form a residue
suitable for treatment, reuse, and/or disposal to land. Since
the promulgation of the CAA In 1970, wet scrubbing systems which
use dissolved lime or limestone as the sorbent have been the pre-
dominant method of FGD. Reaction of sulfur oxide with lime or
limestone In the scrubber results 1n the formation of calcium
sulfate and sulfite precipitates, which are separated from the
liquid portion through settling and filtration. The liquid por-
tion Is then mixed with additional lime or limestone and reused
1n the scrubber; the separated solids are removed for disposal.
FGD Sludge Generation Rate
The rate at which the sludge is generated is a function of
several factors. The principal factor determining the quantity
of solid material generated 1s the sulfur content of the coal;
the rate of sulfur oxide generation dictates the stoichiometric
requirements of sorbent addition to the scrubber. The total
weight of sludge solids will vary slightly according to the sul-
fur oxide collection efficiency, the efficiency of lime or lime-
stone utilization, and the level of sulfite oxidation in the
scrubber system. In systems where the FGD system is not precede*
by an ESP, the amount of fly ash collected by the scrubber must
also be taken Into account.
Table 6 presents general sludge emission factors for commer-
cially available FGD systems. The generic emission Vactor equa-
tion presented for limestone, lime, and double alkali (sodium)
systems was developed from empirical data, and is not sensitive
to changes in collection efficiency or sulfite oxidation level.
The adjustments s*iown in the table represent some form of treat-
ment through addition; the additive rate is reflected 1n the ad-
justment factor. The treatment processes will be described in
more detail later in this chapter.
16
-------
TABLE JS . ESTIMATED FGD SLUDGE AND BY-PRODUCT PRODUCTION RATES FOR COAL-FIRED FACILITIES
Scrubbing Process
Lineston?
Sodtun carbonate
Magnesium oxide
Wei lawn-Lord
By-Product Generation Rate
23.5 S ~ .17 A* ~ 104-
12.0 gal/HW/hr (no data
available on solids in
«aste)
4.56 gat/MW/hr (no data
available on solids in
waste)
5.45 lb/MW/hr (solids)
Co-col lection
Kith Flyash
* 1.51
1.42 lb/
HG/hr
Adjustments
~ bravo IUCS
Treatment Treatment
x 1.03
n.TJ5*
x 1.04
2.7 lb/
HW/hr
Remarks
~ .B7 for 1 iw scrubbing
and double alkali
Partial recycle
By-product not
intended to be waste
By-product not
intended to be wa*te
• A • *sh content of coal, percent.
• S • Sulfur content of coal, percent, at asstmed 50^ rewoval efficiency of 90 percent.
• Corpgted from empirical data, Ib/fVhr, in cases where flyaih is collected with S02-
-------
Physical and Chemical Properties
The physical and chemical properties of FGD sludge are af-
fected by many variables inherent in the o eration of the scrub-
ber and power plant. These variables include the following:
• Characteristics of the fuel burned.
• Combustion equipment and operating parameters.
• Particulate collection mode.
• Scrubber operating parameters (liquid/gas ratio, slurry
retention time, recirculation ratio, etc.).
• FGD reagent and input water quality.
• Type of sludge treatment employed.
Both the physical and chemical properties of FGD sludge have
been the subject of extensive research. The reader is referred
to the literature (8, 11, 17, 25, 26) for the detailed findings
of these research efforts.
The data which 1s of particular Interest to this study is
that which relates to the environmental impact (and the associ-
ated regulation) of FGD sludge disposal. The two principal envi-
ronmental concerns when disposing of FGD sludge to land are (1)
the potential for ground water and surface water contamination
from contact with soluble sludge constituents, and (2) the poten-
tial for land degradation from the disposal of large volumes of
unstable material. Research to date has therefore concentrated
on Identifying the chemical composition and engineering proper-
ties of both treated and untreated FGD sludge.
The by-products of nonregenerable FGD systems are typically
composed of four major solid constituents: calcium sulfate hernl-
hydrate and/or dlhydrate (due to mixed crystallization), calcium
sulfite hemlhydrate, unreacted sorbent, and fly ash. The rela-
tive amounts of these constituents are determined by the various
scrubber and power plant operating parameters discussed previ-
ously.
The physical properties of FGD sludge which are of primary
concern during treatment and disposal are permeability, bulk den-
sity, compaction strength, and viscosity. These properties are
determined to a great extent by the crystal morphology and mois-
ture content of the sludge. Crystal morphology will vary between
the major solid phases; as a result, physical properties vary ac-
cording to the relative percentage cf calcium sulfate, sulfite,
and carbonate sol Ids and fly ash present. Crystal structure will
also control the limit to which the sludge can be dewatered by a
given operation. Moisture content Is a key factor In determining
18
-------
the rate of contaminant mass transport to the surrounding envi-
ronment, as well as the viscosity and load bearing strength of
partially dewatered sludge.
Some physical properties of FGD slud-je can be predicted
based on information about crystal morphology and moisture con-
tent using the data base established thus far. When these pro-
perties are not adequate, further treatment may be desirable to
aid In sludge management or comply with regulatory guidelines.
Table 7 presents some typical values for the engineering proper-
ties of FGO sludge.
The solid phase of FGD sludge can also contain a variety of
trace metals. Trace metals can oriqinate from several sources.
Including fly ash (collected with SO^ or added to the sludge),
sorbent, and make-up water or vapors collected from the flue gas
Itself. The trace metals contained 1n fly ash, their principal
source, generally remain In the solid phase. Those which form on
the ash surface can be dissolved in the waste slurry and enter
the liquid phase; from there, they may either precipitate as pure
compounds, such as sulfate/sulfite crystals, or else remain in
solution.
The characteristics of the llauld phase are Important due to
Its potential as a mass transport medium for trace contaminants.
FGO sludge liquors typically contain Ions of sulfate, sulfite,
chloride, calcium, magnesium, and various trace chemical species.
The total dissolved solids (TDS) concentration 1n FGO sludge is a
function of chemical operating conditions in the scrubber system,
with TDS concentration 1n excess of 20,000 ppm being quite common
1n some systems. Table 8 displays a range of contaminant concen-
trations 1n FGD sludge liquors and elutriates, based on the re-
sults of a variety of extraction procedures.
FGD SLUDGE TREATMENT AND DISPOSAL ALTERNATIVES
Utilities esu1pped with wet scrubbing FGD systea*. c*n dis-
pose of the by-product sludge 1n one of three ways: pondlnfc,
landfllUng, or sale for reuse. The latter alternative Is not
considered viable In the near term due to limited market demand
for sludge by-products (gypsum, road-base material, etc.). Ulti-
mate disposal methods of ponding and landfllllng are therefore
expected to predominate through 1990.
Within the general pond and landfill disposal methods are
several variations based upon tne type of sludge treatment em-
ployed. These variations, displayed graphically 1n Figure 1, are
composed of one or more of the following attributes:
• The disposal site is lined with a synthetic or other non-
native Hner material.
19
-------
TABLE 7 . EXAMPLES OF TYPICAL ENGINEERING PROPERTIES OF
FGD SLUDGE*
Predominant Solid Species
Property/Characteri stic
Crystal morphology
Moisture content:
• Settled
• Centrifu?ed
• Filtered
Bulk density*
Permeability*
Compressive strength
Viscosity
CaSO.
2H20
Tetrahedral
50-65%
55-75%
60-80%
1.5-1.9 gm/cc
10"3-10"6 cm/sec
2.0 x 10® dynes/cm2
9 35% moisture
10 cp G 38.5% moisture
46 cp 0 36.5% moisture
CaS03 • 1/2H20
Plate-like and/or
spherical aggregate
25-40%
40-60%
45-60%
1.2-1.8 g/cc
10~^-10~® cm/sec
2.4 x 10® dynes/cm2
0 30% moisture :
120 cp 9 40% moisture
20 cp 9 50% moisture
Jtef. §•
'Ref. jfl , function of moisture content.
"Will vary with compaction and deuatering.
eo
-------
TABLE 8. CONCENTRATION OF CONSTITUENTS IN SCRUBBER LIQUORS*
Range of Constituent Concentrations at
Potential Discharge Points
Constituents
Mg/1 (Except pH)
M
A1uminum
0.03 -
0.3
10-5.95_10-4.95
Antimony
0.09 -
2.3
10-6-13.10-4.72
Arsenic
<0.004 -
0.3
<1q-7.27_iq-5.40
Beryl!1urn
<0.002 -
0.14
<10-6.65^lc-4.81
Boron
8.0 •
46
io-3'13-io-2-37
Cadmium
0.004 -
0.11
10"7,44-10"6*01
Calcium
520
3,000
10-1.89_io-T 12
Chromium (total)
0.01 -
0.5
10"6-72.10-5.02
Cobalt
0.10 -
0.7
io-5-77-™-4-92
Copper
<0.002 •
0.2
<10-7-50-io-s-b0
Iron
0.02 •
8.1
10-6.45_iq-3.84
Lead
0.01 •
0.4
1q-7.32_iq-5.71
Magnesium
3.0
-2,750
10-3-91-io-°-95
Manganese
0.09
2.5
lo-'-^-io-4-34
Mercury
0.0004- 0.07
1q-8.70_-jq-6.46
Molybdenum
0.91
6.3
10-4-71-10-4'18
Nickel
0.05
1.5
1q-6".07_iq-4.59
Potassium
5.9
- 32
1q-3.82_iq-3.09
Selenium
< 0.001
2.2
< io"7*9®-10"*4*®®
Silicon
0.2
3.3
10-5.15_iq-3.93
21
-------
TABLE 8 (Continued)
Constituents
Silver
Sodium
Tin
Vanadium
Z1nc
Carbonate
Chloride
fluoride
Sulfite
Sulfate
Phosphate
P«
Ionic strength
Range of Constituent Concentrations at
Potential Discharge Points
Mg/1 (Except pH)
0.005 - 0.6
14 -2,400
3.1 - 3.5
<0.001 - 0.67
0.01 - 0.35
41 - 150
(as CaC03)
420 -4,800
0.07 - 10
0.8 -3,500
720 -10,000
0.03 - 0.41
3.04 - 10.7
M
10"7,33-10"5*25
10-«.58_10-4.53
-------
Figure 1. Overview of avalisble FGD sludge management options,
Including example ra.«ges of sludge solids content.
-------
• The sludge 1s mechanically dewatered to Improve Its han-
dling properties and enhance disposal site reclamation
potentlal.
• The slurried or dewatered sludge Is mixed with other ma-
terials to form a stable material with predictable engi-
neering properties and environmental Impact.
The selection of a sludge treatment and disposal system is
predicated upon the need for (1) site reclamation and (2) ground
water protection. The former need may be dictated solely by eco-
nomics, while the latter 1s based upon design criteria put forth
by the applicable regulatory agency.
To date, utility scale FGD sludge management Is being per-
formed using the following treatment and disposal combinations:
• Disposal of clarlfier underflow to ponds which have ac-
ceptable 1n-s1tu soils as liners.
• Disposal of clarifier underflow to lined ponds (synthetic
or imported clay liners).
• Disposal of mechanically dewatered sludge to landfill.
t Admixing of lime and fly ash with sludge, and disposal to
1andf111.
• Commercial stabilization (controlled admixing of fixative
materials to sludge) and disposal to landfill.
These five generic disposal systems are employed 1n the cost
Impact analysis. The following 1s a brief discussion of the con-
ceptual disposal systems. A more detailed description of these
systems and their variations 1s presented in the literature (4,
13, 25).
Ponding of FGD Sludge
FGD sludge ponds typically require embankments, although
some pond designs have employed such topographical features as
pond sides. Sludge ponds usually vary from 20 to 40 feet In
depth, Including the settled sludge and supernatant* At tjiljs
depth, a power plant will fill 0.6 to 0.75 acres of land for
every megawatt of capacity during Its 30-year life.
Sludge ponds receive mater al In one of three forms:
• A 10 to 20 percent solids slurry directly from the
scrubber system.
• A 30 to 45 percent solids underflow from a clarlfier.
• A slurry of stabilized sludge and scrubber liquor.
24
-------
In some Instances, ponds of the above variety also serve as
settling basins. Supernatant 1s recirculated.as scrubber make-up
water.
FGO sludge pond design must provide an effective barrier to
prevent contaminant migration from the site. Disposal sites are
often selected so that their in-situ soils provide such a natural
barrier. When no such site can be found within reasonable proxi-
mity to the power plant, nonnative liner materials may be em-
ployed. Clay, asphalt, cement, rubber, and plastic have served
as liners 1n various waste disposal applications. The associated
high cost has severely limited their application in the utility
industry.
Dewatering and Disposal to Landfill
Mechanical dewatering of FGD sludge will produce a sewicohe-
slve material which can be trucked to and placed in a landfill.
No additives are employed to improve handling characteristics or
decrease permeability.
Scrubber effluent typically contains about 15 percent sol-
ids. In order that sludge can be transported and placed in a
landfill, a much higher solids content must be attained. Thick-
ening the sludqe from 15 to 60 percent solids generally takes
place in two steps.
Primary dewatering usually takes place in a clarifler.
Clariflers (also referred to as settling tanks and gravity thick-
eners) are a standard unit treatment process on most full-scale
scrubber sludge treatment Installations. In addition to dewater-
ing clariflers sometimes function as mixing or preparation basins
for recirculated scrubber feedwater.
Clarifler design is based primarily on the settling charac-
teristics of the sludge, which in turn are largely dictated by
sludge constituents and particle size. Scrubber sludges, espe-
cially those generated by Hme or limestone processes, exhibit
fair settling characteristics compared to most solids encountered
in the chemical processing industry. Clarification results in •
sludge having between 35 to 45 percent solids.
Secondary dewatering 1n FGD sludge treatment may be accom-
plished by a variety of equipment. Dewatering processes~»tth de-
monstrated or potential applicability to scruM>*r sludges a*s»:
• Centrifuges.
• Vacuum f11ters.
• Solar evaporation ponds.
• Bed dryers.
• Thermal dryers.
25
-------
The first three processes listed above have been applied to
scrubber sludges, and operating experience is documented. The
other processes listed have not been applied to scrubber sludges,
but have been used successfully for other types of industrial and
municipal sewage sludges.
The use of centrifuges for sludge dewaterlng has had labora-
tory and pilot-scale analysis 1n the United States, and wide-
spread use in Japan. Centrifugation is an efficient technique
for removing unbound moisture from wetted solids; however, it en-
tails comparatively high power consumption and maintenance re-
quirements.
Several centrifuges are available commercially, differing
primarily in the design of the collection surface and the feed
and discharge mechanisms. Bowl-type centrifuges have been ap-
plied to scrubber sludges.
The vacuum filter process appears to be the best secondary
dewaterlng technique for most FGO sludges. Both the revolving
drum and belt filter designs yield tetter overall performance
(when reliability 1s considered) than the centrifuge, like other
dewaterlng methods, however, process effectiveness 1s highly de-
pendent on sludge characteristics, and is subject to operating
d1ffIcult1es.
Sludge variables that are known to affect filter performance
are concentration and nature of solids, viscosity, temperature,
and compressive strenqth. Operating variables are vacuum
strength, filter media, drum speed, degree of drum submergence,
and amount of fluid agitation. Problems encountered include cake
cracking and difficulties with cake removal from the filter me-
dia, both of which have resulted in temporary shutdown of experi-
ments.
In dewater-and-1 ar.df 111 operations, sludge clarifler under-
flow Is conveyed by pipe to the secondary dewaterlng system (usu-
ally a drum filter). The filter cake 1s then transported by
truck or conveyor to the landfill site. Placement equipment 1$
usually limited to bulldozers and similar tractors.
Lime/Fly Ash Admixing
The fixation processes described In the previous section In-
volve admixing of various materials with scr-»tfefeer sludge In a.
predetermined proportion, to obtain predictable physical and
chemical properties. The admixture ratios Have been developed as
* result of years of research, and represent tue optimal condi-
tions under which selected chemical reactions take place. Bo-
cause the minimum acceptable physical properties will be specific
to each application, 1t 1s possible that adequate strength can be
obtained using other, less sophisticated methods of treatment and
admixing.
26
-------
The addition of lime to anhydrous silica and alumlnosill-
cate, as Is found in fly ash, produces a pozzolanic reaction re-
sulting in calcium silicate or aluminate gels. The product is a
cementit1ou« material. This reaction, which is common to such
materials as Portland cement, is also the basis of most commer-
cial stabilization processes. The process ingredients include
either natural or synthetic pozzolans.
Fly ash Is a natural pozzolan, and can be used with free
lime, present in the sludge, or with the addition of lime to sta-
bilize FGD sludge. Studies by Weeter (26) and others have docu-
mented the relationship between admix proportions and resultant
physical properties. The relationship between the lime/fly ash
ratio and such properties as compressive strength, settling velo-
city, f11terabi11ty, shear stress, cohesion* bulk density, and
permeability are documented (8, 9, 13, 26). Overall, lime/fly
ash stabilization appears to greatly enhance many of these prop-
erties with regard to disposal mechanics and environmental im-
pact.
Treatment of FGD sludge using 11me and fly ash Is accom-
plished simply by dewaterlng the sludge using a vacuum filter or
centrifuge, and subsequently blending appropriate amounts of 11me
and dry fly ash 1n a mixer. The material 1s, at that point, suf-
ficiently stable for truck transport to a landfill. Lime 1s typ-
ically added on the basis of the fly ash addition rate. Fly ash
addition Is, in turn, based upon the quantity required to achieve
optimum moisture content 1n the dewatered sludge. The amount of
fly ash available will, of course, depend on the nature of the
combustion facility and the type of coal burned.
The advantages of lime/fly ash admixing are numerous. It is
perhaps the lowest cost method of stabilization available. Mix-
ing fly ash with the sludge, with or without the addition of
lime, may result 1n some stabilizing reactions due to available
free lime, or will simply increase the solids content for easier
handling. The use of power plant wastes, such as fly ash and
bottom ash, as an e.dmlx with scrubber sludge also reduces the
number of solid waste streams to be handled separately.
Chemical Stabilisation of FGD Sludge
There 1s a trend among utilities and reaulat&ry agencies to
favor dry disposal of FGD wastes. While manyutll1 ties employ
simple mechanical dewaterlng and/or ash admixing to achieve the
desired product, still others have contracted with commercial
services for operation of the disposal system and use of their
proprietary admix process.
Chemical stabilization, or "fixation," as It 1s often re-
ferred to. Is designed to provide a predictable Improvement In
sludge physical or chemical properties. In no Instance do fixa-
tion processes for FGD sludge attempt to remove contaminants from
the sludge.
27
-------
A variety of fixation processes are commercially available.
Table 9 lists most of these fixation processes and services,
along with a summary of their experience with FGD sludge. More
detailed descriptions of each process are available in the liter-
ature (13).
Of the 16 processes referred to in the table, only Dravo and
IU Conversion Systems, Inc. (IUCS) have longrterm, full-scale ex-
perience treating FGD sludge. These two processes are described
1n more detail on the following pages.
1U Conversion Systems, Inc.--
IUCS markets a system of FGD sludge stabilization using Hme
and fly ash. In the IUCS process, vacuum filtered sludge is
mixed with fly ash and lime in a pug mill. Figure 2 shows a
schematic diagram of the IUCS system. Dry fly ash Is addeo 1n
proportions varying from 50 to 100 percent of the dfy sludge
weight. Lime is added at a rate of 3 to 4 percent. IUCS calls
the finished material Poz-O-Tec®.
Disposal of the stabilized sludge is accomplished by land-
filling. The mixture is controlled to optimize compaction prop-
erties. Pozzolanic reactions between the lime and fly ash result
in a significant Increase In load-bearing strength after the ma-
terial has cured. Compared to untreated sludge, Poz-O-Tec has
\ower moisture content (15 to 25 percent), much reduced permea-
bility (10"5 to 10"° cm/sec) and compressibility, as well as in-
creased bulk density. As an alternative to landfill disposal,
Poz-O-Tec can be used as a structural or construction material.
Possible uses include road base; pond, landfill, or reservoir
lining; concrete or asphalt aggregate; and artificial reefs.
IUCS has experimented with most of these applications, and can
modify the stabilization process, as necessary, to produce an Im-
proved construction mixture.
Mechanical compaction of Poz-O-Tec Is required to obtain the
optimum strength and minimum permeability. If the compacted ma-
terial is disturbed, 1t will undergo a decrease in density.
Since the 1n-s1tu Poz-O-Tec material 1s unsaturated, disturbances
will not reslurry the material.
The IUCS stabilization system can be applied to any type of
calcium-based or calcium-regenerated dual-alkali sludge. Al-
though Poz-O-Tec depends on dry fly ash as a pozzolan, wet fly
ash can also be used; If no fly ash 1s available, other pozzo-
lanic materials might be substituted at a higher cost. Although
the IUCS process 1s not particularly sensitive to sludge chemical
characteristics, such as sulfate/sulfite ratio or pM, physical
characteristics, such as solids content, can be important para*
meters. At the IUCS Conesville, Ohio, facility, the untreated
sludge Is discharged from the scrubber loop, thickened (to about
35 percent solids), and then vacuum-filtered to 60 percent sol-
ids. After mixing, the Poz-O-Tec material can be stockpiled
28
-------
TABLE 9. COMPANIES PROVIDING COMMERCIAL FIXATION OR DISPOSAL SERVICE
Companies
Commercial
Expedience
with Other
Residues
Systm
Specific
for TOD
Sludqe
Full-Scale
Experience
with EGO
'ludqe
Bench Scale
with FfiD
Sludqe
field Tests
with rr,o
Sludqe
Aerojet Liquid Rocket
Extensive
Ves
None
Yes
None
tou> Resource Recovery System,
Inc.
Extensive
Ves
None
Yes
None
•American A«>»lxtures Company
(Formerly Chliago flyash)
No
Yes
Will County
(140 Mm)
Yes
Will County
Anefco Company
Extensive
Yes
None
None
None
Clwifli
Extensive
Yes
None
Yes
Shawnee. Will County
Che«'Nuclear Syttn, Inc.
Extensive
Yes
None
None
None
Dravo Corporation
limited
Yes
Brure
Mansfield
'1650 Mm)
Extensive
Shawnpe. Hohave, Phillip?
Environmental Technology Corp.
Iimited
Yes
Hone
Yes
None
IUCS
Extensive
Yes
rhiiiips
(400 Mm)
Elram*
(VW Mm)
Tetershurq
(S15 Mm)
Coresvl1Ir
(40J Mm)
Extensive
Shawnee, rhlllips. Mohave.
Elrama. Four Coiners
Hjrjton Associates
No
Yes
None
Yes
St. tlair
Ontario liquid Waste
Extensive
Ves
None
Yes
Hississsiiqa
Oispofal limited
-------
TABLE 9 (continued)
Con-pan ies
Coranerctal
Experience
with Other
Residues
System
Specific
for rco
Sludge
Tull-Scale
Experience
with FGD
Sludge
Bench Scale
with TGD
Sludge
Field Tests
with rr,o
Sludge
Til, Inc.
Extens*v«
Yes
None
None
None
Sludge Fixation Technology. Inc.
None
Yes
None
Yes
None
United Nuclear Industries
Extensive
Yes
None
Yes
None
Wehran Engineering Corporation
Not Known
Yes
None
Yes
None
Werner Pfleiderer Corporation
Extensive
Yes
None
None
None
* This conpany provides disposal services and operates fixation facilities at
Coononwealth Edison's HID County Plant.
t *ef. 3.
-------
Figure 2.
Description of
for FGD sludge
IU Conversion Systems'
stabilization. v
Poz-O-Tec process
-------
without ^dve^sely affecting the curing process. Temperatures be-
low 40°F will temporarily stop the stabilizing reactions, which
will again resume as the ambient temperature increases.
Dravo Corporatlon--
The Dravo stabilization process (patented) involves the ad-
dition of Calcilox a proprietary material manufactured from
blast furnace slag, to the sludge. Calcilox is a basic, pozzola-
nic additive which Improves sludge handling characteristics and
disposal properties.
Three treatment/disposal schemes are possible using Calcilox
as a stabilizing agent: permanent ponding, temporary ponding,
and direct landfllllng. These variations are shown schematically
1n Figure 3.
Permanent ponding (the variation employed at the CAPCO Bruce
Mansfield facility) involves the addition of Calcilox and hy-
drated Hme to the sludge before pumping the mixture to a holding
pond. The hydrated lime is required to adjust the pH above 10.5.
Calcilox is added at the rate of 5 to 10 percent of sludge sol-
Ids. Curing 1s completed 1n approximately 30 days. Supernatant
Is then returned to the FGD system.
Where large tracts of land are not available, temporary pon-
ding may be preferable. After the 30-day curing period, the sta-
bilized sludge is excavated from small holding ponds and trucked
to the landfill. More exact control must be exercised in order
to ensure that the sludge cures properly before excavation.
In cases where a temporary storage site is not available,
direct landfllllng can be accomplished immediately following the
addition of dry fly ash, lime, and Calcilox to filtered sludge
solids. Sludge treated in this manner can be efficiently trans-
ported to the landfill location, where only 5 to 6 days' curlr.g
is needed before spreading.
The only full-scale operational FGD facility utilizing the
Dravo stabilization system is the CAPCO Bruce Mansfield Station
in western Pennsylvania, which employs permanent sludge ponding
and supernatant recycle or discharge. This system has been in
operation since December 1975, and was rated as one of the ten
most outstanding engineering achievements of 1976 by the National
Society of Professional Engineers. The treated slurry is pumped
7 miles to a storage reservoir. A similar system Is being
planned for a West Virginia utility. An interim ponding system
was also demonstrated by Dravo at another Pennsylvania utility
from 1974 to 1^76, treating the sludge from 100 MW of FGD-con-
trolled generating capacity.
Status of FGD Sludge Disposal
Figure 4 displays the cumulative U.S. power generating ca-
pacity served by each of the above-mentioned FGD sludge disposal
32
-------
*
w
w
SCRUBBER
SLUDGE
(RAW)
THICKENER
CALCILOX
OPTION 1
PERMANANT
POND
MIXER
OPT.ON 2
TEMPORARY
POND
OPTION 3
VACUUM
FILTRATION
LIME
LAND
F ILL
FLYASH
MIXER
Figure 3. Drtvo process flow diagram showing three possible disposal options.
-------
21,000
>
oc.
Ui
in
o
<
a.
<
o
o
z
<
oc
10
z
Ui
a
LU
>
3
S
20.000
19.000
18,000
17.000
16.000
15.000
14.000
13.000
I 2.000
11.000
10.000
9000
8000
7000
6000
5000
4000
3000
2000
1000
CLAY
LINED•
PONDS
REGENERABLE
CLAY
LINED-
PONDS
DRAVO
DRY MIX
AND
LANDFILL
DRY AND
lANpriu
IUCS
ORY AND
LANOFILL
REGENER-
ABLE
.. DRAVO
ORY MIX
ANO
LANDFILL
DRY AND
LANDFILL
IUCS
7 3 AND
EARLIER
Figure 4. Status of wet FGD sludge disposal (see text
for technology description).
34
-------
technologies. Note that through 1979, each of these technologies
has found steadily Increasing application. It 1s also evident
from the graph that dry disposal (dry, mix, and landfill; dry and
landfill; and IUCS) 1s accounting for an Increasing portion of
the FGO sludge disposal capacity.
Figure 5 displays the same Information, only in terms of cu-
mulative disposal capacity by disposal practice. The graphs show
that most of the dry disposal technologies are experiencing an
Increasing rate of growth in the industry, as are all forms of
stabilization. Ponding, as a means of FGD sludge disposal, on
the other hand, shows a declining rate of growth 1n the near
term. These trends are expected to continue as the implementa-
tion of FGD continues to Increase.
The trend toward stabilization and dry disposal Is due in
part to increased acceptance by some state regulatory agencies.
While no state regulations requiring dry disposal have been pro-
mulgated to date, such a philosophy could hcve a distinct Impact
on the future of FGD sludge disposal.
In order to quantify the cost impact of several regulatory
scenarios, SMCh as the one mentioned above, a definitive set of
disposal systems was developed. These art described In Table 10.
Detailed cost estimates for each system are presented In Section
7 of this report.
35
-------
T ! ME
Figure 5. Trends In predominance of FGD sludge disposal practices among utilities.
-------
7500
5000
MW
u
2500 ¦
DRY, MIX. AND LANDFILL
73 AND
EARLIER
74,75
DRAVO
REGENERAOLE
CLAY LINED
« POND
78 , 79
Figure 5 (Continued)
-------
TABLE 10. ALTERNATIVE DISPOSAL PRACTICES AVAILABLE FOR UTILITY-GENERATED FGO SLUDGE*
Disposal
Practice
JFlue Gas Cleaning
S02
Slj '.ge Attributes
Site Attributes*
Particulate
(Jnlined pond Scrubber
Clay-lined pond Scrubber
Oewater and
landfill
I.U.C.S.
treatment
Omatcr, llae,
fly ash aikli
Scrubber
Oravo treatment Scrubber
£SP
ESP
limestone
Limestone
Limestone
Hoes tone
Linestone
Limestone
35X Solids In effluent slurry,
SOS solids settled
3SX Solids in effluent slurry,
SOX solids settled
Clarified to 35X solids,
filtered to 601
Treated slurry punped to pond
or Impoumfaient
Clarify to 35X solids, filtered
to 60X, add fly ash
Clarify to 35X solids, filtered
to COt, add fly ash
*Other alternatives, such as synthetic liners, chemflx treatment,
Oravo treatment (solids only), were not considered due to lack
of application through 1980.
Pond, with acceptable in-sltu
soli liner
Pond, with imported clay liner
Landfill, with necessary
distribution and compaction
equipavnt
Pond Impountfcient with acceptable
In-sltu liner
Landfill or backfill «ith
equipment
Landfill or backfill with
equipment
Reference to liners
-------
SECTION 6
THE REGULATION OF FGD SLUDGE
GENERAL
The major federal laws possibly affecting disposal of FGD
sludge fall into several categories:
• Solid waste disposal (including hazardous waste dis-
posal ).
• Air quality criteria.
• Water discharge regulations.
• Ocean dumping.
• Mlne dlsposal.
• Safety and health regulations.
• Water quality criteria for beneficial use.
Design of FGD disposal systems may require compliance with provi-
sions of the regulations listed above.
The major federal statutes Impacting FGD sludge disposal are
summarized In the following sections. The majority of these reg-
ulations are less than 2 years old; thus, they have not been ap-
plied extensively. It 1s expected that court rulings will more
precisely define the applicability of these laws to the problem
of FGD sludge disposal.
CLEAN AIR ACT AND AMENDMENTS
The goal of the CAA and Its amendments 1s the attainment of
national ambient air quality criteria. An Important link In the
strategy for reducing emissions to acceotable levels is the
NSPS. NSPS for fossil fuel-fired steam generators {40 CFRr Part
466, 8-17-71) resulted 1n the designation of lime/ limestone wet
scrubbers as the most practicable flue gas S0« control method.
Difficulties were encountered, however, with procedures for dis-
poslnq of the large volumes of sludge expected to be generated.
This culminated 1n a Court of Appeals judgement remanding the
question of FGD sudge disposal to EPA for further consideration,
At the time the S02 emission standard for fossil fuel-fired steam
39
-------
generators was under review by EPA, Congress passed the 1977 CAA
amendments. These amendments replaced the previous fixed
emission limitation for S02 with one based on a percent reduction
from an uncontrolled system. The new emission standard is con-
sidered more stringent, and is expected to result in greater FGD
sludge production.
Since most vehicles and machinery used in FGD sludge dispo-
sal (i.e., sludge transportation by tank truck, use of excavation
equipment at the disposal site, etc.) could result in additional
air pollutant emissions, compliance with CAA-mandated and EPA-
approved implementation plans may need to be assured before a
sludge disposal system can be initiated. Emission quantities
would normally be analyzed and compliance verified during the
normal environmental review process. The increase in air pollu-
tant loading, due to currently proposed FGD disposal activities,
would not normally be a major obstacle to compliance.
FEDERAL WATER POLLUTION CONTROL ACT (PL 92-500)
FGD sludges come under federal water quality guidelines If
they are discharged to an interstate body of water. Discharges
from FGD facilities can include untreated sludge, treated sludge,
or sludge liquor. No specific effluent limitations have been
promulgated for FGD sludges to date; however, discharged Indus-
trial wastewater streams of any kind must be subjected to the
"best practical" treatment technology. By July 1, 1983, they
must be subjected to the "best available" treatment technology.
Any discharge to navigable water is allowed only under the condi-
tions of the National Pollutant Discharge Elimination System
(NPDES). It is the Intent of PL 92-500 that NPDES act as an In-
terim policy, as a step towards the elimination of all discharges
to navigable waters by 1985.
An NPDES permit regulates parameters such as point of dis-
charge, flow rate, time of discharge, effluent limitations, com-
pll ance and monitoring schedule, and operation and maintenance
requirements. EPA enforces NPDES permit violations directly, un-
less authority has been delegated to an approved state agency.
Standards for NPDES permits are such that ultimate disposal
of any FGD wastes (treated or untreated) into navigable waters
could only be allowed on an Intermittent, low-voltm* basis, if at
all.
RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (PL 94-5801..
The RCRA of 1976 (PL 94-510) considerably altered the fed-
eral role In the regulation, treatment, and disposal pf solid
wastes. Prior to PI 94-580- federal activity In solid waste reg-
ulation was advisor); state and local officials mainttlned juris-
diction. The Solid Waste Disposal Act of 1965 and the Resource
Recovery Act of 1970 espoused this philosophy, providing only for
technical assistance and guidance in promulgating standards, in
40
-------
accordance with PL 94-580, federal solid waste management acti-
vities became centralized within EPA under the Office of Solid
Waste (OSW), directed *»y a deputy assistant administrator. Con-
sideration 1s given to maintaining coordination between state and
local agen 1es, as stated in Objective, Subtitle 0, of the act:
"Such objectives (environmentally sound disposal of solid waste)
are to be accomplished through federal, technical, and financial
assistance to state or regional authorities for comprehensive
planning pursuant to federal guidelines designed to foster co-
operation among federal, state, and local governments and private
industry." PL 94-580 and its predecessors contain several provi-
sions which Influence FGD sludge disposal.
The applicability of PL 94-580 to land disposal of FGD
sludge 1s set forth 1n the guidelines (Section 1008(a)), i.e.,
protection of the public health and welfare through: (1) pro-
tection of the quality of ground waters and surface waters from
leachates; (2) protection of the quality of surface waters from
runoff; (3) safety; and (4) aesthetics. The implementation of
these guidelines 1s dependent on whether FGD sludges are ulti-
mately defined under PL 94-580 as general hazardous wastes.
At present, PL 94-580 defines sludge from air pollution con-
trol facilities as solid waste (Section 1004(27)). Under Section
1004(5), however, hazardous waste 1s defined as a waste which can
cause or significantly contribute to m increase in mortality or
serious Illness, or one which poses a substantial present or po-
tential hazard to human health or to the environment. EPA has
issued a 11st of materials to be categorized as hazardous under
RCRA (Subtitle C). FGD sludge was not Included initially, but
was Instead categorized as a "special waste," to be classified as
hazardous or nonhazardous on an Individual basis.
The criteria for identifying hazardous wastes may include:
ignitabillty, corrosivlty, infectiousness, reactlveness, radio-
activeness, and toxicity. Wastes not on the EPA list, but meet-
ing these criteria* will also be subject to EPA regulations.
A two-phase process being considered in the identification
of hazardous wastes Includes: (1) criteria for Identifying the
characteristics of the hazardous substances; and f2) the develop-
ment of a 11st of specific hazardous wastes and a presumptive in-
dustrial process list. The latter list specifies industrial pro-
cesses which will be assumed to be producers of ttazardo«*~wastes,
unless the affected industrial facility proves otherwise. Indus-
trial processes producing S02 scrubber sludgeano ash handling
systems are among those being considered for this list.
Identification of FGD sludges as hazardous un4«r Subtitle C,
Hazardous Waste Management, would necessitate a permit system as
well as strict regulations regarding the recording, labeling,
storage, treatment, transport, and disposal of such materials,
enforcement of hazardous waste regulations would be delegated to
41
-------
Individual states, 1f they desire, through the establishment of a
state hazardous waste program.
Nonhazardous wastes are regulated only in that proper sani-
tary landfill techniques must be employed. EPA-recommended
guidelines for proper design and operation of landfills have been
published (FR 39 ( 158 ):29327-37). Particular reference is made
to procedures designed to prevent ground water contamination and
flooding, and to enhance site reclamation. Factors influencing
water quality Include:
• Background water quality.
• Water table elevation and movement.
• Site geology and soil characteristics.
• Meteorology (particularly precipitation).
Measures which should be undertaken to prevent possible deg-
radation Include:
• Installation and monitoring of ground water wells.
• Leachate, we'l, and other water testing.
In some instances, EPA recommends installation of leachate col-
lection systems. To prevent inundation during periods of flood-
ing, they recommend impervious dikes or other means to protect
against at least a 50-year design flood. To enhance the aesthe-
tics of a landfill area, replacement of vegetative cover, as .soon
as possible, is advised. These guidelines are only enforceable
by the states, and the states are not required to subscribe to
thorn.
The possibilities for federal regulations of FGD sludge are
shown In Figure 6. Only the level of control depicted in the up-
per branch of the figure would then apply.
If FGD sludge Is categorized as a hazardous waste, federal
regulations will control every phase of treatment and disposal.
THE MARINE PROTECTION, RESEARCH, AND SANCTUARIES ACT OF 1972
(PL 92-532)
Disposal of waste material (including FGD sludge) to the
oceans 1s controlled by the Marine Protection, Research, and
Sanctuaries Act of 1972 (PL 92-532). This act centralizes con-
trol of all ocean disposal under the EPA. Und«r this law, a per-
mit system was established (38 FR 28613). Certain materials,
such as radioactive wastes, chemical and biological warfare
agents, and other Infectious or particularly hazardous wastes,
are specifically excluded from any cr all ocean dumping. In gen-
eral, disposal materials must not "unreasonably degrade or endan-
ger human health, welfare, or amenities, or the marine environ-
ment, ecological systems, or economic potentialities."
42
-------
Hazardous Waste Criteria
• Toxicity
• Persistence/rate of
degradation
Accumulation In tissue
Flammabll Ity
Corroslveness
Other hazardous char*
acteristics
CPA classification
of FGO sludge
April 1978
Generation
»)
Record keeping
2)
Labeling
3)
Containers
4)
Furnishing
Information
5)
Inventory
6)
Reporting
Permit
1)
Quantity
2l
Composition
3)
Concentration
4)
Location
5)
Compliance plan
6)
Hodi f(cations
(if necessary)
Transpertation
1)
Record keeping
2)
Transporting
J)
Inventory
4)
Labeling
5
Coordination
with o:*ier
regulations
Disposal
Record keeping
Monitoring
Design and
location
4) Operations
a) Cover
b) Compaction
cj Runoff
d) Pests
• ) Aesthetics
fj Safety
g) Air qualIty
Disposal
1) Record keeping
2) Monitoring and
inspection
J) Treatment and
storage
4) Location and
design
5) Construction
6) Contingency
pi ans
7) Maintenance
8) Training
9) - Compli ance
Figure 6. Alternatives for federal regulation of FGD sludqe disposal
under the Resource Conservation and Recovery Act.
-------
Applicants for ocean disposal permits must inform the EPA of
the following:
• Quantity of material to be dumped.
• Means of conveyance.
• Anticipated dates and times of disposal.
• Proposed dump site.
£ Proposed method of disposal.
• Identification of the prrcess producing the waste.
0 Alternative methods of disposal and reasons why they
cannot be used.
In addition, wastes containing any of the following sub-
stances fall Into the "special care" category, and the permit ap-
plicant is required to prove that "the material proposed for dis-
posal, after reasonable allowance for mixing In the mixing zor.e,
will not exceed .01 of a concentration shown to be toxic to ap-
propriate sensitive marine organisms, considering the concentra-
tion of pollutants, In the waste material itse'if and the total
mixing zone available for initial dilution and dispersion."
These substances are: elements. Ions and compounds of arsenic,
lead, copper, zinc, selenium, vanadium, beryllium, chromium, and
nickel. Also included are organosllicon compounds, inorganic
processing wastes, petrochemicals, bloddrs, radioactive wastes
not otherwise prohibited, wastes high In BOD, immiscible mate-
rials and substances Included on the EPA's toxic pollutants
11st. Applicants for ocean disposal permits must determine that
no applicable w*ter quality standards will be violated by their
disposal. They must also consult with federal, state, and local
authorities and take affirmative action to inform the general
public about th* proposed dumping.
Federal ocean dumping regulations and permit procedures are
designed to discourage ocean disposal wherever possible. Pro-
posed dumping activities will be approved only after the appli-
cant has established: need; economic, aesthetic, recreational,
and marine ecosystem effects; long-term effects; and has consid-
ered alternative land-based disposal and reuse potential. FGO
sludge disposal research is continuing 1n this area.;
DISPOSAL TO MINES
Disposal of FGO sludge to mines will be regulated under the
Federal Surface Mining Control and Reclamation Act of 1977 (PL
95-87). Starting in January 1979, the act will establish crite-
ria on the types of materials to be stored and disposed of in
both surface and deep mines, during and following mining opera-
tions.
FGD sludge disposal In coal mines Is considered acceptable
under the current law (PL 95-87). Several provisions, however,
will govern storage: (I) the ability to ultimately reclaim the
surface land; (2) pollution problems caused by stored materials;
and (3) effect of the stored materials on the hydroqeology of the
44
-------
site. In addition, Individual states will be required to inspect
all coal mines to ensure their compliance with relevant federal
statutes.
The act will be administered by the Department of Interior,
Office of Surface Mining Regulations. They will coordinate their
efforts with EPA, which enforces the RCRA, PL 94-580. The regu-
lations regarding leachate control, ground water and surface wa-
ter protection, safety, and aesthetics are all equally applicable
to mine d1sposal.
As discussed 1n the section describing RCRA, the degree of
federal regulation of FGD sludges will hinge on whether they are
defined as hazardous wastes. With the enactment of the Hazardous
Waste Management Guidelines (Subtitle C of RCRA), EPA will be in-
volved in the regulation of hazardous wastes from the point of
generation to the point of disposal.
Mine disposal of FGD sludge will be partially regulated by
several federal water quality laws, notably the Federal Water
Pollution Control Act amendments and the Safe Drinking Water Act.
Although effluent guidelines h*ve not, as yet, been promulgated,
for FGD sludges, point-source effluent limitations for mines have
been completed and are being reviewed. Additional effluent limi-
tations regulate discharges to surface waters used for public wa-
ter supplies. Surface runoff, the pumping of ground water from
mines, and seepage or overflow of sludge liquor are all examples
of potential FGD mine disposal discharges which would be regu-
lated by the above laws.
The Safe Water Drinking Act (PL 93-523) pertains to mine
disposal of FGD sludge with regard to potential contamination of
aquifers used as sources for drinking water. The EPA administra-
tor has broad powers to regulate disposal activities In an emer-
gency situation, or to block federal funding of disposal projects
if potential contamination of aquifers is likely.
Several federal safety regulations can be applied to mine
disposal of FGD sludge and ash. In particular, the Dam Safety
Act, PL 92-367, could be applied In cases where dikes are con-
structed to contain waste material. Structures covered by this
law must have Impoundment capability greater than 14 acre-feet,
or have a height greater than 6 feet.
Certain Mining Safety and Health Administration (MSHA), as
well as Occupational Safety and Health Administration (OSHA),
standards and guidelines Indirectly bear upon FQP sludge disposal
activities. Customarily, OSHA monitors the disposal Industry,
and MSHA, the mining Industry. Their separate Jurisdictions with
regard to disposal 1n mines, however, are not specified in the
standards and guidelines and, therefore, jurisdictions tend to
overlap. Overall, MSHA and OSHA regulations are directed towards
the working environment of employees, rather than towards envi-
ronmental protection 1n general. Examples of regulations which
45
-------
could be applied to FGD waste disposal are: materials storing
guidelines, hazardous materials container and storage standards,
or impounding structure specifications.
STATE FGD DISPOSAL REGULATIONS
State solid waste regulations are generally directed towards
protection of ground water, site reclamation, and potential
flooding. Many states also evaluate criteria on a site-specific
basis, requiring power plants utilizing FGD to obtain disposal
site approval from the applicable state agency. None of the
states surveyed had developed specific FGD sludge disposal cri-
teria. Permit applications were evaluated based on adapted land-
fill regulations which. In many cases, were limited to c. soils
analysis. Table 11 summarizes disposal regulations for states in
which an FGD facility was located in 1977.
An FGD sludqe disposal system which produces a discharge to
surface waters (such as with treated liquor) is subject to the
requirements of the water quality standards program. Every state
operates such a proqram to monitor and restrict pollutant dis-
charges. Constituents and parameters such as DO, pH, SS, and
heavy metals are regulated. FGD sludge contains all of these as
constltuents.
Most states also limit the pollutant loading of ground water
systems. Specific criteria for such protection, however, is not
as well developed as it is for surface waters. Kansas, Maryland.
Michigan, New York, and Idaho have established contaminant limits
which require ground water discharge permits or regulate disposal
practices; however, the majority of states do not, as yet, have
quantitative guidelines affecting pollutant discharge to ground
water aquifers.
REGULATORY SCENARIOS DISCUSSIONS
Four alternative regulatory scenarios for the disposal of
flue gas cleaning sludge are conceivable, as listed below:
• Federal Advisory - State Legislation and Enforcement.
• General Federal Legislation - State Enforcement.
• Comprehensive Federal Legislation - State Enforcement
upon Approval.
• Comprehensive Federal Legislation and Enforcement - No
State Involvement.
Each scenario 1s dependent upon the authority assumed by the fed-
eral and state/local governments. The greater the role of the
federal government in the regulation of FGD sludge, the greater
the national uniformity in treatment, transport, and disposal
46
-------
TABLE 11. STATE SOLID WASTE REGULATIONS PERTAINING TO
SELECTED FGD SYSTEMS*
Stat* Groundwater
AZ General protection
CO Central protection
Fl Monitoring, possible
leachate collection
11 Monitoring, toll
analysis
KS General protection,
soil analysis
KY General protection,
soil analysts
KO Monitoring, soil
analysis, possible
leachate collection
MT General protection,
soil analysis
N* Stabilize or
neutralize
PA Monitoring, soil
, analysis, possible
leachate collection
Floods
Hone
General rainfall
protection
At>ay fro* flood
plain
General rainfall
protection
None
100 yr flood
100 yr flood
100 yr flood
None
50 yr away fro*
flood plain
»;1nfall
None
General rainfall
protection
General diversion
General rainfall
protection
None
General diversion
20 yr rainfall
20 yr rainfall
None
General diversion
Reel amat 1 on
2 ft mintrum cover
2 ft mlnlrjm cover,
33X slope (sides)
2 ft mlnln-jm cover,
50X slope (sides)
State apptoval
2 ft minlrjm cover ,
revegetat1 on
2 ft ainlrusi cover,
331 slope (sides)
revegetat1 on
2 ft Mtnlnum cover.
2 ft Blnlrjin cover,
2-4 slope
2 ft mlnfKum cover,
1-15* slope
* Ref. 2S;
-------
standards. Comprehensive federal regulations would most likely
ensure uniform enforcement also.
On the other hand, the greater the role of the *tate govern-
ment in FGD sludge disposal regulations, the greater the chances
that particular needs of a disposal facility and the surrounding
community will be recognized. Site-specific regulations would
allow the state or local regions to evaluate individual disposal
facilities. Unique situations and locations would be recognized.
Table 12 summarizes the four alternative administrative ap-
proaches to FGD sludge disposal regulations.
Eacti of the four regulatory approaches listed above may re-
sult in different compliance procedures. Based on a prior study
(25) of the development of standards/regulations for land dis-
posal of FGD sludge, the following general categories of proce-
dures were defined:
1. Simple permitting; stabilization not required and not
commonly used.
2. Site-specific evaluation with stabilization sometimes
requlred.
3. Physical stabilization required; no ponding.
4. Chemical stabilization required 1n urban areas.
5. Chemical stabilization universally required; specifica-
tions given for the stabilization technique.
Each of these five compliance requirements are further described
1n Table 13 as they relate to the four administrative alterna-
tives. In Section 7, these regulation compliance scenarios are
applied to the projected 1980 and 1985 FGD sludge dlsDOsal capac-
ity to determine their Impact on present and future disposal op-
erations.
48
-------
TABLE 12. ALTERNATE REGULATORY SCENARIOS FOR FLUE GAS CLEANING SLUDGE DISPOSAL
Scenario Federal Role State/Local Role General Description
One
Two
x>
Three
Four
Advisory
Legislative
(General)
Legislative
(Comprehensive)
Legislative
and Enforcement
Legislative and
Enforcement
Enforcement
Enforcement
None
Federal government delegates regulatory
authority to states. Type of regulation
and enforcem^nl procedures will be site
specific} therefore.no national uniformity.
Federal government promulgates regulatory
legislation and/or general pollution
abatement legislation. Enforcement of
federal legislation 1s delegated to the
Individual states. Each state would set
their Individual compliance procedures
for site design, selection, operation, etc.
Federal government promulgates specific
and comprehensive regulatory legislation.
Federal legislation would include specific
guidelines for the site design, selection,
operation, monitoring, and reclamation. States,
upon certification by federal authority,
would be responsible for enforcement of
federal legislation.
Federal government is responsible for
legislation and enforcement. State has no
rule (besides cooperation with fc' ral
authorities), federal role could range from
"cradle to grave" control of FCP to periodic
permit programs. Federal enforcement would
encourage national uniformity but m.iy slight
unique conditions of state ami Uval Utilities.
-------
TABLE 13. MANIFESTATION OF REGULATORY SCENARIOS
Compliance
Scenario
Responsibility
Federal
1,2 Advisory
State
Legislative
and
Enforcement
3 Legislative Enforcement
(general)
4 Legislative Enforcement
(comprehen-
sive)
Legislative None
and enforce-
ment
Possible Requirements
Groundwater
• General protection
Land
tisne; or
Stability (site
specific)
Specific protection •
(monitoring)
Quantify expected •
contamination
Remedial plans
Monitoring
Stability
heet or exceed
surrounding
stability
• Oe facto protection • Chemical Fixation
Surface Hater
• NPDES
• NPDES
l NPDES or
treatment
• No discharge;
dike construc-
tion standards
Site Design
• Approved enqlnrcrim)
criteria
• Specified engineering
criteria
• S^clfisd engineering
criteria
• Specified engineering
criteria
Interpreting 1 to 4 as increasing stringency.
-------
SECTION 7
DEVELOPMENT OF MODEL POWER PLANTS AND ASSOCIATED
FGO SLUDGE OISPOSAL COSTS
INTRODUCTION
The objective of this study 1s to estimate the cost impact
of various degrees of FGD sludge disposal regulation on the util-
ity indtstry. In order to make such an estimate, the following
information is required:
« One or more alternative regulatory approaches for FGD
sludge disposal, and the designation of dii^osal methods
which can meet or exceed the associated criteria.
• A set of model power plants wh.ch together represent the
utility industry.
• The cost of each disposal option to each model plant.
The cost impact assessment can then he made by (1) applying
each regulatory scenario to the model plants (industry profile),
(2) estimating the disposal method used by each plant for compli-
ance, and (3) estimating the incremental industry-wide cost of
compliance beyond that of current regulations. The technology
options and regulatory scenarios were presented in Sections 5 ard
6 respectively. This section presents the model plant and cost
data development. Section 8 combines this information for the
cost Impact assessment.
MODEL PUNT ATTRIBUTES
Although considerable sludge disposal cost information ex-
ists, mu:h of 1t 1s based on differing design and economic prem-
ises! Bscause 1t 1s important that a consistent methodology be
followed in developing all disposal cost estimates, the recent
TVa conc?ptual design study (4) of sludge disposal economics has
been selscted as a basis for the formation of the model plants.
The base case model in the TVA study described a new 500-MW
coal-fir*d plant near Chicago, with construction costs for mid-
1979 and f1rst-yecr operation costs for mid-1980, .'he coal com-
position varied from 2 percent to S percent for sulfur, and from
12 percent to 16 percent for ash.
51
-------
In developinq model plants for this report, the industry was
differentiated based on the type of coal most typically used.
Because of h i qh transportation costs and the dissimilarity of
coals mined in various parts of the country, the first stsp in
developinq model plants was to divide the industry by geographic
region. Althouqh this approach is a simplification, some gener-
alization is necessary to keep the number of model plants '•eason-
abl e.
Table 14 presents the selected model plants with their ap-
propriate fuel composition counterparts. Where possible, actual
industry data were used to characterize fuel types for each re-
gion.
TABLE 14. MODEL PLANT LOCATION AND FUEL CHARACTERISTICS
Coal Composition
Region
Name
% Sulfur
% Ash
West
Western
?.
12
Midwest
Midwest 1
3.5
12
Midwest 2
5
16
East
Eastern 1
2
12
Eastern 2
3.5
16
Table 15 lists the states within the regions selected and
the Standard Metropolitan Satistical Areas (SMSA), which presum-
ably typify the larger metropolitan areas of each region. The
SMSA's are identified to allow inclusion of urban-rural varia-
tions in land prices in the model plant descriptions. Variabil-
ity of land prices within each region is introduced by construct-
ing each model plant under two land cost criteria: (1) construct
it within a "typical" SMSA of that region, and (2) construct it
1n a non-SMSA countv which closely adjoins that SMSA.
However, because the task of selecting a "typical" SMSA 1s
difficult, Table 16 presents a more simplified methodology for
typifying urban and rural land prices within each region. In
this table, statewide jri cul tu -al land prices for states con-
taining the representatlve SMSA's were collected from Department
of Agriculture sources and projected to mid-1979. This mid-1979
projection 1s compatible with the method that TVA used for pro-
jecting capital costs. Since the most current prices on a county
basis are for 1974, statewide 1974-1979 growth factors were ap-
plied to counties within and adjoining the representative- SMSA's.
The simple averages of these estimated land values are used in
52
-------
TABLE lb. MODEL
Representatj ve
Region S.M.S.A.'s
West: Albuquerque
Denver-Boulder
Las Vegas
Phoen ix
Salt Lake City
Tucson
Midwest: Chicago
Cleveland
Call as-Ft. Worth
Detroi t
Houston
Mi nnea polis
St. Louis
East:
8 a 11 imore
Boston
Nassau-Suffolk
New York
Philadelphia
Pittsburgh
Washington, D.C.
regional characteristics
• Member States
Arizona New Mexico
Colorado Utah
Idaho Wyomlnq
Montana
Nevada
Arkansas
Illinois
Indiana
Iowa
Kansas
Loui s iana
Michigan
Minnesota
Missouri
Nebraska
North Dakota
Ohic
0 k1ahoma
South Dakota
Texas
W1 s c o n s i n
Alabama
Connecti cut
Del aware
F1ori da
Georgi a
Kentucky
Ma ine
Maryland
Massach usetts
Mi ss i ss1ppi
New Hampshire
New Jersey
New York
North Caro1ina
Pennsylvania
Rhode Island
South Caroli na
Tennessee
Vermont
Virginia
Washington , D.
West Virginia
-------
TABLE 16. REGIONAL LAND PRICES*
Statewide Land
Prices
Within SMSA
Adjoininq SMSA
Representative
Region SNSAs State
'69
Avg.
'74
Avg.
•77
Avg.
'79
Est.
'74-79 ,
Factor
Representative
County
'74
Avg.
•79
Est.
Representative
' County
'74
Avg.
'79
Est
West Albuquerque
NM
43
71
95
106
1.493
L'ernadi 1 lo
381
569
Torrance
53
79
Denver-Boulder
CO
93
1(16
262
299
1 ,608
Boulder
779
1,252
Morgan
276
441
Las Vegas
NV
54
85
94
107
1,259
Clark
433
545
Nye
76
96
Phoenix
AZ
110
in
129
129
1,162
Maricopa
700
814
Yavapai
64
74
Salt Lake City
UT
90
193
246
287
1 ,487
Salt Lake
618
919
Sutoi i t
209
311
Tucson
AZ
110
111
129
129
1,162
Pina
121
141
Cochise
108
J 26
Ratio SI'SA to Non-SMSA Averages
is 3.
76:1
Simple Averaoe
707
Simple Average:
IP, a
Hiciest Chicago
IL
490
849
1,450
1,582
1.863
Cook
2,442
4,550
Boone
929
1,731
Cleveland
OH
406
717
1,131
1,248
1,741
Cuyahoga
3,448
6.002
Wayne
764
1.130
Callas-Ft. Worth
TX
14C
277
298
355
1.282
Oallas
1,357
1,739
Jack
183
235
Detroit
HI
328
552
782
869
1,574
Wayne
1,920
3.023
Sanilac
520
819
Hot/ston
TX
140
277
298
355
1,282
Harris
890
1,141
Polk
418
536
Minneapolis
HN
229
434
664
743
1,712
Hennepin
1,187
2,032
Strarns
318
514
St. Louis
MS
240
393
529
591
1,485
St. Louis
1.118
1,660
Washington
267
396
Ratio SHSA to Non-SHSA Averages
is 3
60:1
Simple Average
2,878
Simple Average:
799
fast C.iltimore
HO
634
1,037
1.371
1,527
1.473
Ha 1timore
1.590
2.341
Frederick
1,062
1 ,564
Boston
MA
576
966
1,143
1.301
1,347
Middlesex
2.019
2,760
V/orctio'ster
7!'6
1,059
Nassau-Suffolk
NY
274
507
5)1
686
1 ,353
Suffolk
4.607
6,234
Outclass
917
1 ,241
New York
MY
274
507
591
686
1,353
Westchester
4.944
6,690
Dutchess
017
1 ,?41
Philadelphia
PA
391
756
1.000
1,145
1,515
Philadelphia
2.246
3.402
Perks
1.114
I ,6'i?
Pittsburgh
PA
391
756
i.ono
1.145
1.515
Mlegheny
1150
1,2V
Greene
307
460
Washington, O.C.
('<
634
1.137
1,371
1,527
1 ,473
Prince George
1,725
2.540
frectorick
1,062
1 ,564
Ratio SMSA to f.'on-Sf'SA Average5
is 2
.87:1
Simple Averane
:
3,608
Simple Aver,iqe:
1 ,?59
All costs are J/acre for land from farms with $2,500 plus annual nross (i.e., very small farms ate excluded). t*cfp! for '7<1 estimate'.,
1 arvj price" are from agricultural census sources.
'this estimate comes from 'inear regression of statewide prices for '89. '74. ami '77.
'ihU factor 1s the ratio of '79 estimate prices to '74 prices.
**
This estimate is product of '74 average county price and '74-'79 statewide factor. The *»*>'. t rment. prices fm li tuurify ,nr> for I'fM.
-------
the model plant descriptions as representative of the urban-rural
range of land prices most likely to be encountered when siting a
power plant within each region.
The TVA study estimated mid-1979 construction and mid-1980
operating costs for plants in the Chicago metropolitan area. To
adjust these costs to other geographic reg ions, regional cost in-
dices were used. Indices for 1975 and 1980 are not yet avail-
able, so it is assumed that relative differences between current
indices may be used as close substitutes. Table 17 presents the
Handy-Whitman electric utility construction indices for mid-1977
and the model plant regional construction cost indices for mid-
1979.
TABLE 17. REGIONAL CONSTRUCTION COST INDICES*
Region
West
Midwest
East
Handy-Whitman Index
State Grouping Index Number
PIateau
N. Central
N. Atlantic
395
403
398
Model Plant
Construction
Cost Indext
980
1,000
988
* Ref. 27.
t Methodology assumes same relative sizes of mid-1977 Handy-
Whitman electric utility construction indices for mid-1979.
North Central * 1,000.
A similar method was used to form operating and maintenance
cost indices 1n Table 18. In this case. Department of Labor 1977
wage rates for each of the representative SMSA's were averaged
and then compared to the Chicago base rate to form regional oper-
ating cost indices. As in the preceding table, these Indices are
relative to the cost estimates developed by TVA for the Chicago
area. In this way, they allow model plant descriptions to Incor-
porate regional cost differences for plant construction and oper-
ation.
Table 19 summarizes the model plant attributes. Even with
the Indicated simplifying assumptions, the methodology requires
each of five model plants to be considered in both an urban
(high-priced land) and a rural (low-priced land) setting.
55
-------
TABLE 18. OPERATING AND MAINTENANCE REGIONAL COST INDICES
Reg i on
West
Mi dwest
East
S . M . S . A .
Wage Rate
Index
A1buquerque
4.57
Denver-Boulder
5.79
Las Vegas
7.53
Phoenix
5.59
Salt Lake City
4.94
Tucson
5.63
Averaqe
5.675
908
Ch i cago
6.25
Cleveland
6.86
Dallas-Ft. Worth
5.06
Detroi t
8.05
Houston
6.63
Mi nnea poli s
6.44
St. Louis
6.59
Average
6.554
1 ,049
Baltimore
6.30
Boston
5.57
Nassau-Suffolk
5.El
New York
5.47
Phi 1adelphi a
5.64
Pittsburgh
7.23
Washington, D.C.
5.48
Average
5.843
935
* Source is Bureau of Labor Statistics, U.S. Department of Labor.
Methodology assumes 1977 averaqe wage rate differentials are
good adjustments for 1980 Chicago O&M costs.
Chicago = 1,000.
-------
TABLE'19. SUMMARY OF MODEL PLANT ATTRIBUTES
Base Case: 500 MW
30 Yr. Life (New)
1 Mi. to Disposal Site
Region
West
Midwest
East
Land Costs/Acre
High Low
707
2,878
3,608
188
799
1,259
Construction
Cost Index
980
1,000
988
O&M
Cost Index
908
1,049
935
Model Plant Name
Western
Midwest 1
Midwest 2
Eastern 1
Eastern 2
Coal Type
% S % Ash
2
3»i
5
2
3's
12
12
16
12
16
-------
UNIT COST DEVELOPMENT
Methods/Assumptions
Because model plant attributes differ from the base case
presented by TVA, it is necessary to address the accounting meth-
odology and assumptions used to generate unit cost estimates. As
in the TVA report, annual revenue requirements for sludge dispo-
sal are divided into direct and indirect cost components. As
Table 20 shows, the direct costs consist of those for delivered
raw materials (e.g., ground lime) and for plant "conversion."
This latter category includes: (1) operating labor and supervi-
sion, (2) maintenance (at 4 percent for plant and 3 percent for
pond of direct investment), (3) analyses and operation (operation
cost refers to landfill operation, when applicable), and (4)
electricity costs.
The Indirect costs consist of capital charges and overhead
costs. Capital charges are defined as straight-line depreciation
of net capital investment (excluding land and working capital),
Interim replacement of equipment (0.7 percent for pond or 2.5
percent for landfill of net capital Investment), insurance and
property taxes (at 2 percent of net capital and land), cost of
capital (Interest and dividends at 11.6 percent of depreciated
total Investment), and cost of income taxes (at 5.6 percent of
depreciated total capital). The percsntages associated with the
last two components derive from the methodology (also used by
TVA) that capital Investment is funded by 60 percent debt (at 10
percent Interest) and 40 percent equity (at 14 percent return to
stockholders); I.e., 0.6 x 10 percent + 0.4 x 14 percent = 6 per-
cent + 5.6 percent s 11.6 percent. So, if corporate Income tax
equals the return to stockholders, then income tax also repre-
sents 5.6 percent of depreciated total capital. It should be
noted that, although cost of capital Includes interest on land
purchase, the purchase price of land is not being amortized or
depreciated. This Is identical to the TVA methodology, in which
no explicit estimate of residual land value 1s assumed due to
site-specific variables which are beyond the scope of this con-
ceptualized analysis.
The overhead portions of Indirect costs follow the TVA meth-
odology of allocating an additional 50 percent of conversion
costs (less electricity) for plant overhead, and another 10 per-
cent of direct operatlrg labor and supervision for administrative
overhead. As Table 20 shows, total annual revenue requirement 1s
thus the sum of all these direct and indirect costs.
The plant operating profile, as developed by TVA and adopted
for this Hfe-cycle analysis, requires a declining number of
hours of plant operation over the disposal system's 30-year life
span. The assumed annual hours of operation are as follows:
7,000 hours for each of the first 10 years, 5,000 hours for each
of the next 5 years, 3,500 hours for each of the following 5
years, and 1,500 hours for each of the remaining 10 years of
58
-------
example annual revenue requirements*
Direct Costs 2,650
Delivered raw materials 859
Conversion cost 1,791
Operating labor and supervision 1,332
Maintenance 172
Analysis and operation 181
Electricity 107
Indirect Costs 3,576
Capital charges 2,601
Depreciation, interim replacement,
insurance, and property taxes 758
Cost of capital and income taxes 1,843
Overhead 975
Plant 842
Administration 133
Total annual revenue requirements 6,227
* Source is TVA (4) base case for IUCS process, except (1) property
taxes are for first-year capital value and (2) cost of capital
and income taxes are for the first year of operation, rather than
as a "levelized" average.
"59
-------
plant life. This means that the model plant operating profile
consists cf a total of 127,500 hours of operation for a total
production of 6.375 x 10 kilowatt hours produced over a 30-year
period.
As the hours of operation decrease with plant age, the non-
capital annual costs decrease also. Per the TVA methodology, it
is assumed that raw materials, analysis and operation, electri c-
ity, and plant overhead decrease in direct proportion to annual
hours of operation; direct charges for labor and supervision, as
well as indirect charges for administrative overhead, are scaled
proportional to annual operating hours raised to the 0.5 power;
direct charges for maintenance are scaled proportional to annual
operating hours raised to the 0.6 power. In this way, "labor and
maintenance costs reoonize economies of scale and minimal labor
requirements by decreasing less rapidly than hours of plant oper-
ation.
Example of Model Plant Cost Generation
Assumptions presented in the preceding secti ons . *¦! 1 ow model
plant costs to be generated from TVA conceptual design estimates.
As in the TVA report, capital costs include all construction and
site improvements, vehicles and equipment, engineering design and
supervision, contractor fees and start-up allowance, and all land
and working capital. It only remains to make adjustment for fuel
characteristics and other regional cost differentials.
Table 21 exemplifies this process of adjusting TVA cost es-
timates to reflect model plant assumptions. In this instance,
the TVA unlined ponding base case has had its .pond and land re-
quirements adjusted to reflect lower model plant sludge genera-
tion. In combination with a lower construction index and lower
land costs, this results 1n a decreased initial capital require-
ment and lower first-year indirect (i.e., capital charges) costs.
Similarly, fuel characteristics and a lower OSM cost index pro-
duce lower first-year direct costs and lower indirect (I.e.,
overhead) costs. The result in Table 21 is total first-year
costs for a western urban model plant which disposes of its
sludge by unlined ponding.
The first-year costs do not reflect the assumed decllninq
plant operating profile nor the present value of future revenue
commitments for this model plant. Table 22 summarizes lifetime
revenue commitments for the example model plant. As described
previously, annual hours of plant operation are assumed to de-
crease in stepwise increments from 7,000 in Year 1 to 1,500 1n
Year 30. In this example, there are no delivered raw materials;
but, if there were, they would also decrease in direct relation
to hours of operation. The mechanisms by which the other costs
decrease have already been discussed. It is interesting to note
that since no inflation has been included, all categories except
that for capital charges are already in terms of mid-1980 present
value. Putting the capital charges in terms of present value
60
-------
TABLE 21. ADAPTATION OF TVA CONCEPTUAL DESIGN COSTS:
AN EXAMPLE FOR WESTERN URBAN UNLINED PONDING
Fuel characteristics: %S
%Ash
Construction cost index*
Plant capital investment#
Land cost/acre
Number of acrest
Land costt#
Working capital#
Total initial capital investment#
O&M cost index*
Raw materials cost#
Labor and supervision cost#
Maintenancet#
Analysis and operationt#
Electricityt#
Total direct costs for the first
year of operationt#
Total indirect costs for the first
year of operations#
(see Table 20 for elaboration)
TVA
Conceptual
Design
3^
16
1,000
$12,587
$ 3,500
486
$ 1,700
$ 104
$14,391
1,000
0
219
35.90
8.50
55.30
$ 518.70
$ 2,246.40
SCS
Model Plant
2
12
980
$10,498
$ 707
371
$ 26?
$ 1C»
$10,864
908
0
198.80
214.20
7.72
38.20
459
$ 2,737
Total first year costst#
$ 2,765.10
$ 3,196
* Relative to the TVA conceptual design (=1,000).
t Includes pond size adjustment to fuel characteristics.
# All costs in K$ for new 500-MW (30-yr life) disposal plant.
61
-------
TABLE 22. EXAMPLE OF
MODEL PLANT LIFETIME REVENUE COMMITMENTS
(IN K$)
Cost of
Year of
Annual
Delivered
Conver-
Over-
Lower Unit
Hours Of
Raw
sion
Capital
head
Operation
Operation
Materials
Costs
Charges
Charges
1
7,000
0
459
2,507
230
2
7,000
0
459
2,447
230
3
7,000
0
459
2,387
230
4
7,000
0
459
2,327
230
5
7,000
0
459
2,266
230
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
7,000
0
459
2,206
230
7,000
0
459
2,146
230
7,000
0
459
2,036
230
7,000
0
459
2,026
230
7,000
0
459
1,966
230
5,000
0
376
1,905
191
5,000
0
376
1,845
191
5,000
0
376
1,785
191
5,000
0
376
1,725
191
5,000
0
376
1,665
191
3,500
0
305
1,604
157
3,500
0
305
1,544
157
3,500
0
305
1,484
157
3.5CO
0
305
1,424
157
3, SCO
0
305
1,364
157
1,500
0
187
1,304
99
1,500
0
187
1,243
99
1,500
0
187
1,183
99
1,500
0
187
1,123
99
1,500
0
187
1,063
99
1,500
0
187
1,003
99
1,500
0
187
942
99
1,500
0
187
882
99
1,500
0
187
822
99
1,500
0
187
762
99
Cumulative
costs
Average cost 1n mills per ufti
•After deflating capital charges by the (Internal)
rate of return, I.e., 11.65.
Annual Annual Present
Revenue Value* Revenue
Requirements fiequlrenents
3,196
3.196
3,136
2,382
3,076
2,606
3.016
2.363
2,956
2,150
2,895
1,964
2,835
1,800
2,775
1,657
2,715
1,531
2,655
1,421
2,472
1,203
2,412
1,119
2,352
1,045
2,292
981
2,232
925
2,066
771
2,006
729
1,946
691
1,886
659
1,826
631
1,589
431
1,529
409
1,469
391
1,403
375
1,348
362
1,288
350
1,223
34C
1,168
331
1,107
323
1,047
317
63.926
33.954
1.00
.53
62
-------
requires deflating or discountinq by some factor. In this case,
it Is the return to debt and equity financing (6 percent + 5.5
percent = 11.6 percent), otherwise known as the internal rate of
return, which has been selected as the most appropriate discount
factor. The final column of Table 22 reflects what happens when
all future revenue requirements are put in terns nf mid-1980 dol-
lars. The cumulative lifetime cost to this model plant for this
disposal method is nearly $34 million, which equates to an aver-
age present value revenue requirement of 0.53 mills per kilowatt
hour (in terms of 1980 dollars). These costs are the incremental
costs of sludge disposal, and are in addition to other model
plant costs to produce electricity.
DISCUSSION OF UNIT COST RESULTS
Methods presented in the preceding sections were applied to
each of the ten model plants, using each of the six disposal al-
ternatives. The resulting 60 cost scenarios had capital invest-
ment requirements, per Tables 23 and 24; first-year operating re-
venue requirements, per Tables 25 and 26; and lifetime revenue
requirements, per Tables 27 and 28.
However, it is the present value lifetime revenue commit-
ment, shown at the bottom of the last column in Table 22, that is
of particular Interest. It is this parameter for the various
model plants which most accurately measures future revenue com-
mitments and forms the most appropriate basis of unit cost esti-
mates. Tables 29 and 30 show these values for cumulative costs
1n thousands of dollars, and average unit revenue requirements in
terms of mills per kilowatt hour.
The values presented in Table 30 (when stated to 10 signifi-
cant digits) will be used, in following sections, to determine
the economic impacts of various FGD regulatory scenarios. For
this reason, it is important to note the great diversity of aver-
age unit costs shown in this table. Not only do unit costs per
kilowatt hour vary considerably for each sludge disposal type un-
der the various regional model plant scenarios, but the relative
cost rankings between disposal types are not consistent from one
region of the county to the next. This is as it should be when
such factors as fuel composition, construction and 0«M costs, and
land prices are allowed to vary on a region-to-req1on and urban-
to-rural basis. It is precisely this cost sensitivity to re-
gional and local sludge disposal variations which will manifest
Itself in the resultant cost impact analysis.
INDUSTRY APPLICATION OF UNIT COSTS
In applying these model plant unit costs to the utility in-
dustry for each of the regulatory scenarios, it is necessary to
assume that unit revenue requirements (per kilowatt hour) for the
various disposal methods are invariant with respect to the size
of the total plant disposal operation. This simplifying assump-
tion appears to be at least partially substantiated by the TVA
63
-------
TABLE 23. ESTIMATED CAPITAL INVESTMENT (K$) FOR ALL MODEL UTILITIES
Ho del Plant Location*
Western
Midwestern
Eastern
Fuel Type (Sulfur, Ash)
Z, 12
3?,, 12
5, 16
2, 12
3H. 16
Construction Cost Index
980
1,000
1,000
988
9C8
O&M Cost Index
908
1,049
1,049
9
35
935
Land Cost ()/Acre)
707
188
2,878
799
2,878
>99
3,608
1,259
3,608
1,259
Disposal Process
Unllned Pond
10.864
10.672
13.369
12,440
15,425
14,259
12,125
11,253
14,357
13,216
Clay-lined Pond
13,602
13,410
14,371
13,442
21,901
20,734
13,699
12,827
17,431
7,959
16,190
7,518
Ory and Landfill
6,562
6,497
7,522
7,162
8,447
7,998
7,856
7,520
Dravo
17,179
17,033
20,448
20,236
27,459
26,665
19,211
18,549
24,010
10,685
23,037
IUCJI-
8,228
8,128
9,246
8,915
12,126
11,604
9,346
8,893
10,232
Dry, Hix, and Landfill+
6,287
6,231
7,835
7,563
9,942
9,506
6,604
6,348
8,621
8,262
'Oastc plant characteristics:
- 500 KM
- Limestone scrubbing 0 1.5 stolchlometry
- Fly ash collected with $02, unless otherwise noted.
*Fly ash collected separately and added to dewatered sludge.
-------
TABLE 24. ESTIMATED CAPITAL INVESTMENT ($/kW CAPACITY) FOR ALL MODEL UTILITIES
Model Plant Location*
Western
Midwestern
Eastern
Fuel Tjpe (Sulfur, Ash)
Z, 12
3
-------
TA8LE 25. ESTIMATED FIRST-YEAR OPERATING REV.'NUE REQUIREMENTS (K$) FOR ALL MODEL UTILITIES
Model Plant Location*
Western
Midwestern
Eastern
Fuel Type (Sulfur, Ash)
2.
12
12
5,
16
2,
12
3"i
16
Construction Cost Index
980
1.0GG
1,000
988
988
O&H Cost index
903
1,049
1,049
935
935
Land Cost ($/Acre)
707
18a
2,878
799
2,878
799
3,608
1,259
3.600
1,259
Disposal Process
Unlined Pond
3,196
3,159
3,582
3,404
4,330
4,107
3,367
3,199
3,979
1,760
CI ay-lined Pond
3,893
3,856
4,178
3,999
6,Cc9
5,805
3,725
3,565
4,774
4,530
Dry and Landfill
3.374
3,362
4, J16
4,247
•I, 732
,,646
3,942
3,878
4,322
4,237
Dravo
8,747
8,719
7,699
7,659
10,476
'0,324
6,733
6,006
8,571
8,384
iUCSf"
4,33f?
4,318
5,795
5,731
7,442
7,3.'
5,051
4,964
6,072
5,985
Ory, Mix, and Landfillr
2.789
2,778
4,370
4,317
5,323
b,239
3,432
3.383
4,33-1
« 265
•Basic plant characteristics:
- 500 IW
- limcsiOij scrubbing 0 1.5 stolchloKictry
- Fly ash collected with 502, unless otherwise noted,
~fly ash collected separately and added to dewaterod sludge
-------
TABLE 26. ESTIMATED FIRST-YEAR OPERATING REVENUE REQUIREMENTS
(mills/kWh) FOR ALL MODEL UTILITIES
H0J-3I Plant Location*
Western
Midwestei r,
Eastern
Fuel Type (Sulfur, Ash)
2. 12
3'j,
12
5,
16
2.
12
3'j
. 16
Construction Cost Index
98C
1,000
1,000
988
988
O&M Cost Index
908
1,049
1,049
S
35
935
land Cost ($/Acre)
7u7
188
2,878
799
2,870
799
3,608
1,259
3,608
1 1.259
Disposal Process
Unlincd Pond
.91
.90
1.02
.97
1.24
1.17
.96
.91
1.14
1.07
CI ay-lined Po.id
1.11
1.10
1.19
1.14
1.72
1.66
1.06
1.02
1.36
1.30
Dry and Land'i11
.96
.96
1.23
1.21
1.35
1.33
1.13
1.11
1.23
1.21
Dravo
2.50
2.19
2.20
2.19
3.00
2.95
1.92
1.89
2.45
2.39
lUCSf
1.24
1.23
1.65
1.64
2.13
2.10
1.44
1.42
1.73
1.71
Dry, Mix, and Landfillt
.80
.79
1.25
1.23
1.52
1.50
.90
.97
1.24
1.22
•Basic plent.characteristics:
- 500 MM
- Limestone scrubbing 9 1.5 Stoichiometry
- Fly ash collected with S02, unless otherwise rioted.
'Fly ash collected separately and added to dewatercd sludge.
-------
TABLE 27. ESTIMATED TOTAL LIFETIME REVENUE REQUIREMENTS (K$) FOR ALL MODEL PLANTS
Model Plant Location*
Western
Midwestern
Eastern
Fuel Type (Sulfur, Ash)
2, 12
3
-------
TABLE 28. ESTIMATED TOTAL LIFETIME REVENUE REQUIREMENTS
(mills/kWh) FOR ALL MODEL PLANTS
Model Plant Location*
Western
Midwestern
Eastern
Fuel Type (Sulfur, Ash)
2, 12
3
-------
TABLE 29. ESTIMATED PRESENT VALUE LIFETIME REVENUE REQUIREMENTS
(KS) FOR ALL MODEL PLANTS
Hodel Plant Location*
Western
Midwestern
Eastern
Fuel Type (Sulfur, Ash)
2, 12
335
935
Land Cost ($/Acre)
707
188
2,878
799
2,878
799
3,608
1,259
3,608
1,259
Disposal Process
Unllned Pond
33,954
33,612
34,796
33,144
44,718
42,645
34,442
32,891
40.764
38,735
Clay-lined Pond
40,082
39,741
44,574
42,922
60,242
58,167
37.034
35,654
47,904
45,696
Dry and Landfill
51,064
50,948
68,708
68,068
74,853
74,055
59,243
58,645
67,583
66,799
Dravo
121,089
120,829
95,330
94,953
129,899
128,487
80,108
78,930
102,892
101,162
iucst
64,000
63,822
92,145
91,557
116,431
115.503
76,818
76,013
93,057
92,251
Dry, Mix, and Landflllt
38,852
38,751
68,630
68,146
81,940
81,163
52,438
51,982
65,143
64,504
•Basic plant characteristics:
- 500 MW
- Limestone scrubbing 9 1.5 stoichiometry
- Fly a,h collected with S02, unless otherwise noted.
*Fly ash collected separately and added to dewatered sludge.
-------
TABLE 30. ESTIMATED PRESENT VALUE LIFETIME REVENUE REQUIREMENTS
(mills/kWh) FOR ALL MODEL PLANTS
Model Plant Location*
Western
Midwestern
Eastern
Fuel Type (Sulfur, Ash)
2, 12
3*1,
12
5.
16
2
12
3H
, 16
Construction Cost Index
930
1,000
1,000
988
988
O&H Cost Index
903
1,049
1,049
t
135
935
Land Cost (l/Acre)
707
188
2,878
799
2,8/8
799
3,608
1,259
3,608
l',259
Disposal Process
Unlined Pond
.53
.53
.55
.52
.70
.67
.54
.52
.64
.61
Clay-lined Pond
.63
.62
.70
.67
.94
.91
.58
.56
.75
.72
Dry and Landfill
.80
.80
1.08
1.07
1.17
1.16
.93
.92
1.06
1.05
Oravo
1.90
1.90
1.49
1.49
2.04
2.02
1.26
1.24
1.61
1.59
IUCSf
1.00
1.00
1.44
1.44
1.83
1.81
1.20
1.19
1.46
1.45
Dry, Mix, and Landfill*
.61
.61
1.08
1.07
1.29
1.27
.82
.82
1.02
1.01
'Basic plant characteristics:
- SOD HU
- Limestone scrubbing P 1.5 stolchianetry
- Fly ash collected with S02, unless otherwise noted.
*Fly ash collected separately and added to dewatered sludge.
-------
conceptual design FGD disposal study, in which unit revenue re-
quirements did not substantially change for generating capacities
1n excess of 500 MW.
With this in mind, it is necessary to make one further sim-
plifying assumption in order to apply the model plant unit costs
to the industry profiles: when determining remaining hours of
future plant operation, it is assumed that industry plants con-
form to the TVA decreasing operating profile. In other words, a
plant which will have been in operation for 4 years by mid-1980
is assumed to have done so at 7,000 hours per year, and to have a
remaining productive life of 99,500 hours (127,500 hours useful
life - 4 x 7,000 hours = 99,500 hours of useful life) over the
remaining 26 years.
72
-------
SECTION 8
UTILITY INDUSTRY RESPONSE TO REGULATORY SCENARIOS
METHODOLOGY AND ASSUMPTIONS FOR THE COST IMPACT ANALYSIS
As was described in Section 6, the five regulatory scenarios
and their associated FGD sludge disposal requirements are as fol-
lows:
• Scenario No. 1 - No change from current trend in disposal
practices.
• Scenario No. 2 - No urban ponding.
• Scenario No. 3 - Ho urban or rural ponding.
• Scenario No. 4 - No ponding; chemical fixation required
for urban plants.
• Scenario No. 5 - No ponding; chemical fixation required
for both uroan and rural plants.
Applying each regulatory scenario to a model plant, It is assumed
that the utility in question wili select the lowest cost alterna-
tive that meets the regulatory criteria. To assess the industry-
wide impact of these same regulatory scenarios, the projected
1980 and 1985 FGD capacity was described on a plant-by-plant ba-
sis in terms of the 10 model plants.
The resulting model Industry profiles for 1980 and 1985 are
presented in Tables 31 end 32, respectively.
In these two tables, the projected FGD capacity has been
categorized by model plant characteristics and sludge disposal
method. For those cases in which the sludge disposal method has
yet to be selected, 1t was assumed that a new plant would base
Its decision on the relative costs (see Tables 29 and 30) of all
available disposal alternatives. On the other hand, an existing
01 ant would consider the "Dry, Mix, and Landfill" alternative
only 1f fly ash were already collected separately in an electro-
static precipitator.
ESTIMATED INDUSTRY RESPONSE TO MORE STRINGENT REGULATIONS
The Industry profile of FGD capacity, shown in Tables 31 and
32, was subjected to regulatory scenarios No. 2 through 5. The
73
-------
TABLE 31. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 1, 1980
Location
Western
Hidwestern No. 1
Hidwestern No. 2
Eastern Wo. 1
[astern N'j. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
375
2,535
240
1,325
884
1,705
Clay-Lined
Pond
1,390
Dry and
Landfill
1,100
1,025
167
Dravo
2,475
1,250
1UCS*
MO
800
920
490
Dry, Mix, and
Landfill*
815
250
2,779
1,790
184
360
TOTALS
375
4,450
490
7,049
1,957
1,868
920
2,065
2,965
1,250
*riy ash collected separately and addod to dewatercd sludge.
HOTf: All amounts In MW's of generating capacity.
-------
TABLE 32. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 1, 1985
Location
Western
Midwestern Ho. 1
Midwestern No. 2
Eastern No. 1
Eastern Ho. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rura 1
Oisposal
Process
Unlined
Pond
375
10,655
240
8,366
1,484
660
1,705
CIay-Lined
Pond
3,110
Dry and
Landfill
1,100
1,025
167
Oravo
2,475
1,250
IUCS*
530
800
920
490
Dry, HI*, and
Landfill*
815
250
2,779
2,450
184
360
TOTALS
375
12,570
490
15,810
2,617
2,468
1,580
2,065
2,965
1,250
•Fly ash collected separate)/ and added to dewatcred sludge.
NOTE: All amounts In MW's of generating capacity.
-------
impact of each successive degree of regulation is to further
limit the number of available disposal alternatives. Applying
each scenario of the model industry profile, those plants which
would be out of compliance were assumed to change to their least-
cost alternative which still met the new requirements.
Tables 33 through 36 display the anticipated 1980 industry
profiles resulting from implementation of scenarios No. 2 through
5, and Tables 37 through 40 show the 1985 profiles for scenarios
No. 2 through 5.
As an example of how the industry response was estimated,
consider the industry category of western urban unlined ponding.
Since the 375 MW of existing capacity is assumed to collect SO?
and fly ash wet, it cannot consider the "Dry, Mix, and landfill"
alternative. Hence, in going from scenario No. 1 for 1980 (Table
31) to the no-urban-ponding scenario No. 2 (Table 33), the re-
sponse of this industry sector would be from unlined ponding to
the cheapest remaining method of compliance and landfill. In
terms of Table 30, this involves an increase in average present-
value revenue requirements from 0.53 mills to 0.80 mills per ki-
lowatt hour. Therefore, the impact of regulatory scenario No. 2
(shown in Table 33) is to convert this 375 MW of capacity to F60
sludge dewatering and landfill disposal.
The following discussion presents the results of similar
cost impact analyses for all 10 model plants and 5 regulatory
scenari os.
COST IMPACT OF THE UTILITY INDUSTRY RESPONSE
The methodology and assumptions presented in preceding sec-
tions were used to estimate future revenue commitments and capi-
tal investments in each of the key years for each coal-fired in-
dustry sector under each of the regulatory scenarios. The re-
sults of this analysis are presented in tabular form on the fol-
lowing pages. Total future revenue commitments under the various
regulatory scenarios are shown in Tables 41 through 45 for mid-
1980, and in Tables 46 through 50 for mid-1985. Total capital
investments for each model industry sector under each regulatory
scenario are shown in Tables 51 through 55 for mid-1980, and in
Tables 56 through 60 for mid-1985.
Of additional interest are Tables 61 through 64, which iden-
tify the existing FGD sludge disposal capital investments which
would be displaced by regulatory scenarios No. 2 through 5. Be-
cause these estimates Include all land, equipment, and construc-
tion expenditures, they offer only an upper limit for estimating
scenario-induced sunk costs to the utility Industry. It is to be
expected that the actual extent of these sunk costs will greatly
depend on site-specific considerations and the nature of the dis-
posal operation subsequently Adopted.
76
-------
TABLE 33. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 2, 1930
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
2,535
1,325
884
1,705
Clay-Lined
Pond
1,390
Ory and
Landfill
375
1,100
240
1,025
167
Oravo
»
2,475
1,250
1UCS*
530
800
920
490
Dry, Mix, and
Landfill*
815
250
2,779
1,790
184
360
TOTALS
375
4,450
490
7,049
1,957
1,868
920
2,065
2,965
1,250
•Fly ash collected separately and added to dewatercd sludge.
NOTE: AM amounts in HU's of generating capacity.
-------
TABLE 34. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 3, 1980
Location
Western
Midwestern Ho. 1
Midwestern Ho. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Uulined
Pond
Clay-lined
Portd
Ory and
landfill
375
2.585
240
3.740
167
8ti4
1,405
Dravo
2,475
1,250
1UCS*
530
800
920
490
Dry, Mix, and
Landfill*
1.865
250 .
2,779
1.790
184
660
lOTALs
375
4,450
490
7,049
1,957
1,868
920
2,0£5
2,965
1,250
•Fly ash collected separately and added to dewatcred sludye.
NOH: All amounts In HW's of generating capacity.
-------
TABLE 35. DISTRIBUTION OF UTILITY F60 SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 4, 1980
Location
Western
Midwestern Ho. 1
Midwestern Ho. 2
Eastern No. 1
eastern No. 2
Setting
Urban
Rural
Urban | Rural
Urban
Rural
Urban
Rural
Urb»n
Rural
Disposal
Process
Unlined
Pond
Clay-Lined
Pond
Ory and
Landfill
Z.S8S
3,740
884
1,405
Dravo
2,475
1,250
1UCS*
375
490
530
1.957
600
920
490
Dry, Nix, and
Landfill*
1.865
2,779
184
660
TOlAlS
375
4.450
490
7,049
1,957
1,863
920
2,065
2.9C5
1,250
*fly ash collected separately atvd added to dewatered sludge.
HOT£: AM anounts in Mtf's of generating capacity.
-------
TABLE 36. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 5, 1980
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern Ho. 1
Eastern Ho. 2
Setting
1
Urban 1 Rural
Urban
Rura'.
Urbun
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unl 1i~.hJ
Pc nd
I
Clay-Lined
Pond
""i-y avid
canJtill
Dravo
2/75
i ,253
1UCS*
375
4.450
490
7.049
1,957
1,868
920
2,065
490
—
Dry, Htx, and
Landfill*
TOTALS
4,450
490
7.049
1,957
1,86*
920
2.065
2.965
1,250
1
i
*fly ash collected separately #n
-------
TABLE 37. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 2, 1985
Location
Western
Midwestern Ho. 1
Midwestern No. 2
Eastern Ho. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unltned
Pond
10,655
8,366
1,484
1,705
Clay-lined
Por«J
3,110
Dry and
landfill
375
1,100
240
1,025
167
Dravo
2,475
1,250
1UCS*
530
800
920
490
Dry, Hi*, and
Landfill*
815
250
2,779
2,450
184
660
360
1,250
TOTALS
175
12,570
490
15,810
2,617
2,468
1,560
2,065
2,965
•Fly ash collected separately and Added to dewatered sludge.
NOTE: All aaounts In r«"s of generating capacity.
-------
TABLE 38. DISTRIBUTION OF UTILITY F6D SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 3, 1985
co ^
~ O
o
Location
Western
Midwestern Mo. 1
Midwestern Ho. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
UnlIncd
Pond
Clay-Lined
Pond
Dry and
Landfill
375
2,585
240
12,C01
167
684
1,405
Cravo
2,475
1,250
IUCS*
530
800
920
490
Dry, Mix, and
Landfill*
9,985
250
2,779
2,450
784
660
660
TOTALS
375
12,570
490
15,810
2,617
2,468
1,580
2,065
2,965
1,250
•Fly ash collected separately and added to dewatered sludge.
NOTE: All aaounts in KU's of generating capacity.
-------
TABLE 39. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 4, T985
c».
u>
O
Location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
Clay-lined
Pond
Dry and
Landfill
2,585
12,501
884
1,405
Oravo
2.475
1,250
IUCS*
375
490
530
2,617
800
1,580
490
Dry, Mix, and
Landfill*
9,985
2,779
764
660
TOTALS
375
12,570
490
15,810
2,617
2,468
1,580
2,065
2,905
1,250
~Fly ash collected separately and added to dewatered sludge.
MOTE: All Mounts in KM's of generating capacity.
-------
TABLE 40. DISTRIBUTION OF UTILITY FGD SLUDGE DISPOSAL CAPACITY, SCENARIO NO. 5, 1985
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern Ho. 1
Eastern Ho. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
•
Rural
Disposal
Process
Unlined
Pond
Clay-Lined
Pond
Dry and
Landfill
Dravo
2,475
1,250
IUCS*
375
12,570
490
15,810
2,617
2,468
1,580
2,065
490
Dry, Mix, and
Landfill*
TOTALS
375
12,570
490
15,810
2,617
2,468
1,580
2,065
2,965
1,250
•Fly ash collected separately and added to dewatered sludge.
NOTE: All amounts in HM's of generating capacity.
-------
TABLE 4T: REGULATORY SCENARIO NO. 1, YEAR 1980, TOTAL FUTURE REVENUE Commitments
CO \
U1 ^
«/-¦
Location
Western
Midwestern Ho. 1
Midwestern Ho. 2
Eastern No. 1
Eastern Ho. 2
Setting
Urban
Rural
Urban
Rural
Uroan
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
18.009
151,424
9,366
65,164
47,020
96,936
Clay-lined
Pond
96,324
Dry and
landfill
112,036
125,152
14,020
Dravo
444,070
245,963
IUCS*
81,066
159,439
95,628
88,641
Dry, Mix. and
Landfill*
56,228
32,431
329,736
251,921
26,588
33,317
TOTALS
18,009
319,738
41,797
697,442
265,941
233,047
95,620
130,253
532,711
245,963
•Fly ash collected separately and added to dewatered sludge.
MOTE: All amounts in 1,000's of 1980 $.
-------
TABLE 42. REGULATORY SCENARIO NO. 2, YEAR 1980, TOTAL FUTURE REVENUE COMMITMENTS
CD
cn
location
Western
Hidwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
151.424
65,164
47,020
96,936
Clay-Uned
Pond
96,324
Dry and
landfill
27.084
112,086
18,495
125,152
14,020
Cravo
444,070
245,963
IUCS*
81,066
159,439
95,628
88,641
Dry. Mix, and
landfill*
56,228
32,431
329,736
251,921
26,588
33,317
IOTAIS
27,084
319,738
50,926
697.442
265,941
2:3,047
95,628
130,253
532,711
245,963
'Fly ash collected separately end added to dewatered sludge.
NOTE: All amounts In 1,000's of 1980 S.
-------
TABLE 43. REGULATORY SCENARIO HO. 3, YEAR 1980, TOTAL FUTURE REVENUE COMMITMENTS
cov.
Location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unllned
Pond
Clay-Lined
Pond
Ory and
Landfill
27,084
234.619
18,495
411,734
14,020
81,652
137,650
Oravo
444.070
245,963
1UCS*
81,066
159,439
95,628
88,641
Dry. Nix. and
landfill*
137.606
32.431
329,736
251,921
26,583
64,337
TOTALS
27.084
372,225
50.926
822,536
265,941
267,679
95,628
201,957
532,711
245,963
•Fly ash collected separately and added to dewatered sludge.
NOTE: All amounts in 1,000's of 1980 (.
-------
TABLE 44. REGULATORY SCENARIO NO. 4, YEAR 1980, TOTAL FUTURE REVENUE COMMITMENTS
oo -
o
Location
Western
Midwestern No. 1
Midwestern Ho. 2
[astern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
I'll Ined
Pond
Clay-Lined
Pond
Dry and
landfill
234,619
411,734
81,652
137,650
Oravo
444,070
245,963
IUCS*
33,945
68,347
81,066
379,771
159.439
95,628
88,641
Dry, Mix, and
Landfill*
137,606
329,736
26,588
61,307
TOTALS
33,945
372,225
68,347
822,536
379,771
267,679
95,628
201,957
532,711
245,963
•Fly ash collected separately and added to deMatered sludge.
NQIE: All amounts In 1,000's of 1980 $.
-------
TABLE 45. REGULATORY SCENARIO NO. 5, YEAR 1980, TOTAL FUTURE REVENUE COMMITMENTS
location
Wes tern
Hidwestern No. 1
Hidwestern No. 2
Eastern No. 1
Eastern No. 2
letting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unl incd
Pond
Clay-lined
Pond
Dry and
landfill
Dravo
444,070
245,963
IUCS*
33,945
520,537
68.347
1.077,896
379,771
324,630
95,628
272,744
88,641 .
Drv, Mix, and
Landfill*
TOTALS
33,945
520,537
68,347
1,077,896
379,771
324,630
95,628
272,744
532,711
245,963
•Fly ash collected separately and added to dewatered sludge.
NOTE: All anounts in 1,000's of 1900 $.
-------
TABLE 46. REGULATORY SCENARIO NO. 1, YEAR 1985, TOTAL FUTURE REVENUE COMMITMENTS
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
l-Vban
Rural
Urban
Rural
Disposal
Process
Unltned
Pond
11,285
650,746
5,567
510,100
79,691
45,463
66,147
Clay-Lined
Pond
211,220
Ory and
Landfill
81,317
86,847
8,334
Dravo
304,258
176,53a
IUCS*
54,424
108,709
58,803
63,607
Dry, Mix, and
Landfill*
38,889
23,011
225,764
281,178
18,389
23,043
TOTALS
11,285
770,952
28,578
1,088,355
289,512
206,789
104,266
89,190
367,865
176,538
•Kly ash collected separately and added to dewatered sludge.
NOTE; All amounts In 1,000's of 1980 $.
-------
TABLE 47. REGULATORY SCENARIO MO. 2, YEAR 1985, TOTAL FUTURE REVENUE COMMITMENTS
Location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unllned
Pond
650,746
510,100
79,691
66,147
Clay-Lined
Pond
211,220
Dry and
Landfill
16,971
81,317
10,993
86,847
8,334
Dravo
304,258
176,538
IUC5*
54,424
108,709
58,803
63,607;
Ory, Mix, and
Landfill*
38,889
23,011
225,764
281,178
18,389
69,218
23,043
TOTALS
16,971
770,952
34,004
1,088,355
289,512
206,789
128,021
89,190
367,865
176,538
*Fly ash collected separately and added to dewatered sluuge.
NOTE: All amounts In 1,000's of 1980 $.
-------
TABLE 48. REGULATORY SCENARIO NO. 3, YEAR 1985, TOTAL FUTURE REVENUE COMMITMENTS
Location
Western
Midwestern Ho. 1
Midwestern No. 2
Eastern No. 1
Eastern Ho. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Onlined
Pond
Clay-Lined
Pond
Dry and
Landfill
16,971
162,680
10,993
1,469,407
8,334
49,521
92,413
Dravo
304,258
176,538
IUCS*
54,424
108,709
58,803
63,607
Dry, Mix, and
Landfill*
727,244
23,011
225,764
281,178'
115,785
69,218
45,671
TO ALS
16,971
889,924
34,004
749,595
289,512
274,015
128,021
138,084
367,865
176,538
*Fly ash collected separately and added to dewatered sludge.
NOTE: /«ll amounts In 1,000's of 1980 $.
-------
TABLE 49. REGULATORY SCENARIO NO. 4, YEAR 1985, TOTAL FUTURE REVENUE COMMITMENTS
Location
Uestei
Midwestern Ho. 1
Midwestern Ho. 2
[astern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
P.jral
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
UnlIned
Pond
CI ay-lined
Pond
Pry anj
liDjf Ml
162,650
1,469,407
49,521
92.413
176.533
Dravo
304,2'jfl
IUCS*
21.271
45.639
54.424
412,497
108,709
160,203
63,607
Dry, Hi*. #ftd
landf i 11*
727.-M4
225.764
115,785
45,671
13a.004
176.533
TQTAIS
21.271
639.924
45,639
1.749.5V5
412,497
274,015
160,203
367.865
•Fly ash collected separately arid added to dewatered sludge.
NOTC: All Muuntt in l.CCO's of 1980 $.
-------
TABLE 50. REGULATORY SCENARIO NO - 5, YEAR 1985, TOTAL FUTURE REVENUE COMMITMENTS
location
Western
Midwestern fo. 1
Midwestern Ho. ?
Eastern Ho. 1
Eastern No. 2
Setting
Urban
Kuril
Urban
kurtl
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unl irved
Pond
Clay-lined
Pcnd
Dry and
landfill
304,258
Or 4 »o
176.533
176,5J8
IUCS*
21,271
1,401, Ml
45,639
2,334,220
412,4',7
350,720
160,203
1.96,566
63.607
Dry, Hi*. and
landfill*
186.566
toms
21,271
1,401,541
45,639
2,334.220
412,497
350,720
160,203
367,865
•fly ash collected se^rately and added to de*jtercd sludge.
HOIC: All Mount* In 1,000's of 1930 }.
-------
TABLE 51. REGULATORY SCENARIO NO. 1, YEAR 1980, TOTAL CAPITAL INVESTMENTS
location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
(astern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
OHposal
Process
Unl incd
Pood
8.148
S4.107
6.417
32.077
25,210
38,373
Clay-Lined
Pond
37,369
Dry and
landfill
14.293
14,682
2,821
Or 4*o
118,850
57,593
1UCS*
9,450
18,566
17,197
10.471
Dry, Mi«, and
landfill*
10.157
3.918
42,035
35.592
3,498
4,571
TOTALS
8.143
78.557
10,335
135.613
38,413
47,274
17,197
42,944
129,321
57.593
•fly ash collected separately and addeb to devaterrl sludge.
WOII: All Mounts in 1,000's of I960 i.
-------
TABLE 52. REGULATORY SCENARIO NO. 2, YEAR 1900, TOTAL CAPITAL INVESTMENTS
Location
Western
Midwestern Ho. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unl tried
Pond
54,107
32,077
25,210
38,373
Clay-Lined
Pond
37,369
Dry and
Landfill
4,922
14.293
3,611
14,682
2,821
Cravo
118,850
57,593
1UCS«
9,450
18,566
17,197
10,471
Dry. Hlx. and
Landfill*
10,157
3,918
42,035
35,592
3,498
4,571
TOTALS
4.922
78,557
7,529
135,613
38,413
47,274
17,197
42,944
129,321
57,593
•fly ash collected separately and added to dewatered sludge.
NOTE: AM Mounts In 1,000's of 1980 $.
-------
TABLE 53. REGULATORY SCENARIO NO. 3, YEAR 1930, TOTAL CAPITAL INVESTMENTS
| Location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
OHpotal
Process
Unlined
Pond
Clay-Lined
Fond
Dry and
landfill
4,922
33.589
3.611
53,060
2.821
14,140
21,131
Dravo
116.850
5/,593
IUCS*
9.450
18,566
17,197
10,471
Dry, HI*, and
landfill*
23,242
3.918
42.035
35.592
3,498
8,379
57.593
TOTALS
4.922
56.831
7,529
104.545
38,413
36,204
17,197
29,510
129,321
•Fly ash collected separately and added to dewatered sludye.
NOU: *11 Mounts In J ,000's or 19CQ |.
-------
TABLE 54. REGULATORY SCENARIO NO. 4, YEAR 1980, TOTAL CAPITAL INVESTMENTS
1
Location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern Mo. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Olsposal
Process
UnlIned
Pond
Clay-lined
Pond
Dry and
Landfill
33,589
53,060
14,140
21,131
Dravo
118,850
57.593
IUCS*
6.171
9.061
9.450
47,461
18,566
17,197
10,471
Dry, Mix, and
landfill*
23.242
42,035
3,498
8.379
57,593
TOTALS
6,171
56,831
9,061
104,545
47,461
36,204
17,197
29,510
129,321
'Fly ash collected separately and added to dettatered sludge.
WOIf: All Mounts in 1,000's of 1980 $.
-------
TABLE 55. REGULATORY SCENARIO NO. 5, YEAR 1980, TOTAL CAPITAL INVESTMENTS
Location
Western
HldMcstern No. 1
Midwestern Ho. 2
Eastern Ho. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Kural
Disposal
Process
UnlIned
Pond
Clay-lined
Pond
Dry and
Landfill
Dravo
118,eso
57,593
IUCS*
6,171
72,339
9,061
125,047
47,461
43,353
17,197
36,728
10,471
Dry, Mix, and
Landfill*
36,728
TOTALS
6,171
72,339
9,061
125,047
47,461
43,353
17,197
129,321
57.593
*Dy ash collected separately and added to Jewatcred sludge.
NOTE: All aaounts In 1,000's of 1980 %.
-------
TABLE 56. REGULATORY SCENARIO NO. 1, YEAR 1985, TOTAL CAPITAL INVESTMENTS
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
8,MS
227.420
6,417
207,257
42,321
16,005
38.373
•Clay-Lined
Pond
83,609
Dry and
Landfill
14,293
14,682
2,821
Dravo
118,650
57,593
IUCS*
9,450
18,566
17,197
10,471
Dry, Nix, and
landfill*
10,157
3,918
42,035
48,715
3,498
4,571
IOIAIS
fi.148
251,870
10,335
357,033
51,536
64,385
33,202
42.944
129,321
57,593
•Fly ash collected separately and added to dewatcrcd sludge.
NOTE: All aaountl In 1,000's of 1980 $.
-------
TABLE 57. REGULATORY SCENARIO HO. 2, YEAR 1985, TOTAL CAPITAL INVESTMENTS
Location
Western
Midwestern No. 1
Midwestern No. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
UnlIned
Pond
227.420
207,257
42,321
38,373
Clay-Lined
Pond
83,609
Dry and
Landfill
4.922
14.293
3.611
14.682
2,821
Oravo
118,850
57,593
IOCS*
9,450
18,566
17,197
10,471
Dry, Mix, and
Landfill*
10.157
3.918
42,035
48,715
3,498
8,717
4.571
TOTALS
4.922
251,870
7.529
357,033
51,536
64,385
25,914
42,944
129,321
57,593
•Fly ash collected separately and added to dewatcred sludge.
NOTE: All Mounts In I.OOO's of I960 $.
-------
TABLE 58. REGULATORY SCENARIO NO. 3, YEAR 1985, TOTAL CAPITAL INVESTMENTS
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern Ho. 1
tastern Ho. 2
Setttr>9
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
Clay-Lined
Pond
Dry and
Landfill
4,922
33,689
3,611
178,553
2,621
14,140
21,131
Dravo
118,850
57,593
IOCS*
9,450
18,5(6
17,197
10,471
Pry, Mix. and
Landfill*
124,413
3,918
42,035
48,715
14,905
8,717
8,379
TOTALS
4,922
158.022
7,529
230.038
51,536
47,611
25,914
29,510
129,321
57,593
•Fly ash collected separately and added to dewatered sludge.
NOTE: A1) amounts In 1,000's of 1980 $.
-------
TABLE 59. REGULATORY SCENARIO NO. 4, YEAR 1985, TOTAL CAPITAL INVESTMENTS
.ocatton
Western
Midwestern No. 1
Ml '.western Ho. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban -
Sural
Urban
Rural
Disposal
Process
Unlined
Pond
Clay-lined
Pond
Dry and
Landfill
33.58*
178,553
14.140
21,131
Dravo
118.850
57,593
IUCS*
6.171
9.061
9,450
63.467
18,566
29,534
10,471
Dry, HU, and
landfill*
124,433
42,035
14,905
8,379
TOTALS
6.171
158,022
9.061
230,038
| 63,467
47,611
20,534
29,510
129,121
57,593
*FIi ash collected separately and added to dewatered sludge.
NOTE: All «mounts III 1,000's of I960 J.
-------
TABLE 60. REGULATORY SCENARIO NO. 5, YEAR 1985, TOTAL CAPITAL INVESTMENTS
Location
Western
Midwestern Mo. 1
Midwestern No. 2
Eastern No. 1
[astern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unltned
Pond
Clay-Lined
Pond
Ory and
Landfill '
Dravo
118,850
57,593
1UCS»
6.171
204.338
9.061
281,256
63,467
57,278
29,534
36,728
10,471
Ory. Nix, and
Landfill*
TOTALS
6.171
204.338
9.061
281.256
63,467
57,278
29,534
36,728
129,321
57.593
•Fly ash collected separately and added to dewatered sludge.
NOTE: All amounts In 1,000's of 1900 (.
-------
TABLE 61. REGULATORY SCENARIO NO. 2, YEAR 1980, TOTAL DISPLACED CAPITAL INVESTMENTS
Location
Western
Midwestern No. 1
Midwestern Ho. 2
Eastern No. 1
Eastern No. 2
Set .ing
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rurai
Urban
Rural
Disposal
Process
Unlined
Pond
8.148
6,417
Clay-Lined
Pond
Dry and
Landfill
Oravo
IUCS*
Dry, Mix, and
Landfill*
TOTALS
8,148
6,417
*Fly ash collected separately and added to dewati.'>ed sludge.
NOTE: All amounts in 1,000's of 1900 $.
-------
TABLE 62. REGULATORY SCENARIO NO. 3, YEAR 1980, TOTAL DISPLACED CAPITAL INVESTMENTS
Location
Western
Midwestern Ho. 1
Midwestern Mo. 2
Eastern No. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
8,148
54,107
6,417
32,077
25,210
38,373
CI ay-Lined
Pond
37,369
Dry and
Landfill
Dravo
IUCS*
Dry, Mix, and
Landfill*
TOTALS
8,148
54,107
6,417
69,446
25,210
38,373
*Fly ash collected separately arid added to dewatered sludge.
NOTE: All amounts In 1,000's of 1900 $.
-------
TABLE 63. REGULATORY SCENARIO NO. 4, YEAR 1980, TOTAL DISPLACED CAPITAL INVESTMENTS
Location
Western
Midwestern Ho. 1
Midwestern No. 2
Eastern Ho. 1
Eastern Ho. 2
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Disposal
Process
Unlined
Pond
B, 143
54.107
6,417
32,077
25,210
38,373
CIay-Lined
Pond
37,369
Dry and
LandFilt
2,821
Dravo
1UC5*
Dry, Mix, and
Landfill*
3,918
35,592
3P.373
,
TOTALS
8,148
54,107
10,335
69,446
38,413
25,210
~Fly ash collected separate)/ and added to dewatercd sludge.
NOTE: All Mounts In 1,000's of 1980
-------
TABLE 64. REGULATORY SCENARIO NO. 5, YEAR 1930, TOTAL DISPLACED CAPITAL INVESTMENTS
Location
Western
Midwestern Ho. 1
Midwestern Ho. 2
Eastern Ho. 1
Eastern No. 2
Setting
Urban
Rural
Urban
Rural
Urban
Ruril
Urban
Rural
Urban
Rura 1
Disposal
Process
UnlIned
Pond
8.143
54,107
6,417
32,077
25,210
38,373
Clay-Lined
Pond
37,369
Dry and
Landfill
14,293
14,682
2,821
Dravo
IUCS*
Dry, Hi*, and
landfill*
10,157
3,918
42,035
35,592
3,498
4.571
TOTALS
8.148
78,557
10,335
126,163
38,413
28,708
42,944
•fly ash collected separately and added to dewatered sludge.
NOTE: All aaounts in l.OOO's of 1980 $.
-------
Because of the amount of Information generated, Section 9
will summarize the salient points of these analysis results. The
interested reader is encouraged to examine the data presented in
the tables, particularly those estimates which apply to the in-
dustry section with which he is most familiar. The following ex-
ample demonstrates the derivation and significance of this tabu-
lar Information.
Consider again the 1980 Industry sector for western urban
unlined ponding under the no-change scenario No. 1. By 1980, the
375-MW capacity of this sector (see Table 31) will be composed of
a 6-year-old 250-MI7 plant (85,500 remaining hours), and a 4-year-
old 125-MW plant (99,500 remaining operating hours). The total
remaining electricity production potential for these two plants
1s 3.38 x 10 kilowatt hours. At an average present value FGD
sludge disposal cost of 0.533 mills per kilowatt hour (see Table
30), a future revenue commitment of $18,009,000 1s required.
The procedure for determining this same sector's capital
commitment 1s similar to the above methodology, 1n that the model
plant capital costs for disposal per kilowatt of generating ca-
pacity ($21.73 for western urban unllned ponding, Table 24) are
multiplied by the associated generating capacity. An estimated
Initiul FGD sludge disposal capital Investment of $8,148,000 was
made by this sector under regulatory scenario No. 1.
Under regulatory scenario No. 2 for 1980, the FGD sludge
disposal capacity of this sector Is assumed to shift from unllned
ponding to landfill disposal of dewatered sludge and fly ash.
From the preceding discussion, the future revenue commitment in-
creases to $27,084,000 as a result of the more stringent regula-
tion.
The same methodology Is employed for estimating 1985 cost
Impacts. Because plants Included In the 1980 Industry profile
would be 5 years older by 1985, the associated remaining hours of
productive operation must be adjusted accordingly. For the 250-
MW and 125-MW western plants used 1n this example, their respec-
tive ages would be 11 and 9 years, and their remaining hours
would be decreased by 33,000 and 3i,000 hours, respectively, from
the 1980 estimates. The result of these changes Is that future
revenue commitments of this sector after 1985 for regulatory sce-
nario No. 1 (1n terms of 1980 dollars) would become $11,285,000,
a substantial decrease from the estimated 1980 commitment of
$18,009,000. It should be noted, however, that several other
model Industry sectors are planning to add FGD capacity after
mid-1980, and will Instead experience an increase In revenue com-
mitment after mid-1985.
109
-------
SECTION 9
ANALYSIS OF ESTIMATED UTILITY INDUSTRY IMPACTS
It 1s possible to assess, the economic impacts of regulatory
scenarios No. 2 through 5 in terms of the no-change scenario No.
1, from the estimated total dollar amounts for coal-fired utility
future revenues and capital Investments required for FGD disposal
(as developed In Tables 41 through 60 of Section 8). Tables 65
and 66 summarize these economic impacts to each industry sector
for the years 1980 and 1985.
Returning to the example of the western urban sector in
1980, Table 65 shows an increase in future revenue requirements
of $9 million when regulatory scenario No. 2 replaces No. 1.
This is 1n addition to the $18 million already expected under re-
gulatory scenario No. 1. Scenario No. 4 will require this sector
to make an additional revenue commitment of $16 million. Al-
though this sector would experience increased total future reve-
nue commitments under scenarios No. 2 through 5, the lower por-
tion of Table 65 shows that these scenarios would require less
capital-intensive forms of disposal, possibly because the dis-
posal systems required under scenarios No. 2 through 5 tend to
need less land and greater raw material inputs.
The far right column of Table 65 shows an estimated 1980 fu-
ture revenue commitment of $2.58 billion by the coal-fired elec-
tric utility industry under the no-change requTatory scenario No.
1. This amount Increases by $972 million under the most restric-
tive regulatory scenario considered. Although industry-wide fu-
ture revenue requirements for FGD sludge disposal Increase under
scenarios No. 2 through 5, the total 1n i t * a1 capital requirements
are expected to decrease slightly from $565 million under sce-
nario No. 1 to $544 million under scenario No. 5. Thus, the more
restrictive scenarios are expected to offer some small relief to
the financing requirements of most coal-fired utility Industry
sectors.
Table 66 presents a similar but more dramatic picture than
Table 65. A larger portion of generating capacity 1s expected to
be coal-fired in 1985 than in 1980. For this reason, future re-
venue commitments under scenario No. 1 are shown to rise to
$3,133 b1111or (new plants were assumed to be free under scenario
No. 1 to consider all types of FGD sludge disposal). Under regu-
latory scenario No. 5, future revenue requirements for sludge
disposal Increase $2,324 MlHon to an impressive Industry total
of $5,467 billion. As not'd for Table 65, total Industry capital
110
-------
TABLE 65. SUMMARY OF REGULATORY SCENARIO IMPACTS FOR 1980
location/Coal Type
Western
Midwestern No. 1
Hldwesteri: No. 2
Eastern No. 1
Eastern No. 2
Industry
Sum/
01 f ference
Setttnq
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Regulatory
Scenario
No.
,
Total future Rev-
enue Comltaents
18
320
42
700
266
233
96
130
'.33
246
2,580
2
Increase In Total
Future Revenue
Canal taents
9
0
9
0
0
0
0
0
0
0
IB
3
9
52
9
125
0
35
0
72
0
0
30?
4
16
52
26
125
114
35
0
72
0
0
440
97 2
5
16
201
26
3S0
114
91
0
)42
0
0
»
2
3
4
5
Total Capital
Investments
8
78
10
136
38
47
17
43
129
57
0
565
Increase In total
Capital Invest-
ment**
-3
0
-3
0
0
0
0
0
0
-6
-3
-22
-22
•6
-3
-31
-31
0
-11
-11
-4
0
0
0
-13
0
0
0
0
-83
-2
¦2
-1
-1
9
-13
-6
0
-71
-10
9
0
-21
•Docs not Include anjr sunk costs for displaced disposers.
NOIt: All MKxinti are In ll)6 „f |%o (.
-------
TABLE 66. SUMMARY OF REGULATORY SCENARIO IMPACTS FOR 1985
location/Coal Type
Western
Midwestern Ho. 1
Midwestern No. 2
eastern No. 1
Eastern No. 2
Industry
Sum/
Di fference
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Regulatory |
Scenario 1
Ho. |
1
Total Future Rev-
enue Const taents
11
771
28
1,088
289
207
104
89
368
176
3,133
2
3
Increase In Total
future Revenue
Comitnents
6
0
5
0
0
0
24
0
0
0
35
6
119
5
661
0
67
24
49
0
0
931
4
5
10
119
631
17
661
123
67
56
49
0
0
0
10
17
1.246
123
144
56
97
0
1
2
3
4
5
Total Capital
tnvestments
8
252
10
3S7
51
64
33
43
129
57
0
0
0
0
1,006
-13
-264
-264
Increase In Total
Capital Invest-
ments*
-3
0
-3
0
0
0
-7
0
0
-3
-94
-94
-48
-3
-127
0
-17
-17
-7
-7
-13
0
---
-2
-I
-1
-1
-127
-76
12
-4
-4
-13
-6
0
12
0
-132
•lioes not include any sunk costs frr displaced disposers.
HOTf: All amounts are In 10* of 1980 t.
-------
requirements by 1985 are reduced somewhat by the more restrictive
regulatory scenarios, but the Increases in present value lifetime
costs to the consumer far outweigh these capital savings.
Table 67 summarizes Tables 41 through 50 in terms of ulti-
mate electricity cost to the consumer (in mid-1980 mills per ki-
lowatt hour). The last two columns In Table 67 summarize econo-
mic impacts to the consumer in average mills per future kilowatt
hour, and by the percent Increase over regulatory scenario No. 1.
The Industry averages are not simple averages, but are weighted
in terms of future hours of electrical production. Thus, the
percent increases actually reflect additional plant capacities
and remaining life spans (which determine remaining kilowatt
hours of production}, as well as future revenue requirements.
The relatively larqer increments in percent increases for regula-
tory scenarios Mo. 3 and No. 5 are primarily due to the greater
total generating capacities that will be located In rural rather
than urban settings (see Tables 31 and 32).
The economic Impacts of scenarios No. 2 through 5 appear to
be proportionately greater for the western reqion. But in terms
of absolute differences, the midwestern region appears to bear
the greatest incremental costs under these scenarios (see Tables
65 and 66).
It also appears from Table 67 that each regulatory scenario
has a relatively greater impact (i.e., percent increase) in 1985
than in 1980. This difference is partially due to the fact that,
because of more rural plants, the Industry average cost Is much
lower for scenario No. 1 In 1985 than 1t 1s in 1980. This dif-
ference 1s also partially due to the greater freedom of disposal
choice open to new plants coming on line after mid-1980.
The averages do not Include, however, the sunk costs of
those capital investments already made under scenario No. 1,
which are no longer usable under regulatory scenarios No. 2
through 5. Because these additional Incremental costs were not
included in this analysis, some caution is appropriate when com-
paring average cost Impacts for 1980 to those for 1985.
113
-------
TABLE 67. SUMMARY OF REGULATORY SCENARIO IMPACTS TO CONSUMERS (mills/kWh}<
V-
location/
Coal Type
Western
Midwestern No. 1
Midwestern No.' 2
Eastern No. 1
Eastern No. 2
Industry
Percent
Increase
Over
Scenario
No. 1
Setting
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Urban
Rural
Average
Regulatory
Scenario No.
For the Tear 1980:
1
.53
.61
.88
.93
1.28
1.30
1.20
.57
1.59
1.59
1.017
2
.80
.61
1.08
.93
1.28
1.30
1.20
.57
1.59
1.59
1.024
0.7
3
.80
.72
1.08
1.10
1.28
1.49
1.20
.88
1.59
1.59
1.136
11.7
4
1.00
.72
1.44
1.10
1.83
1.49
1.20
.88
1.59
1.59
1.190
17.1
5
1.00
1.00
1.44
1.44
1.83
1.81
1.20
1.19
1.59
1.59
1.400
37.7
Regulatory
Scenario No.
For the Year 1985:
1
.53
.55
.91
.67
1.28
1.07
.78
.57
1.59
1.59
.759
—
2
.80
.55
1.SC
.67
1.28
1.07
.96
.57
1.59
1.59
.767
1.1
3
.80
.64
1.08
1.08
1.28
1.42
.96
,B8
1.59
1.59
.984
29.7
4
1.00
.64
1.44
1.08
1.83
1.42
1.20
.88
1.59
1.59
1.026
35.2
5
1.00
1.00
1.44
1.44
1.83
1.81
1.20
1.19
1.59
1.59
1.321
74.2
A
Mil amounts are in present value as of mid-1980.
-------
REFERENCES
1. Barrier, J. W., H. L. Faucett, and L. J. Henson. Conceptual
Design and Economic Evaluation of Alternative Methods for
Disposal of Lime-Limestone Scrubbing Wastes. Draft. U.S.
Environmental Protection Agency, Research Triangle Park,
North Carolina, 1977. 221 pp.
2. Barrier, J. W., H. L. Faucett, and L, J. Henson. Economic
Assessment of Fiue Gas Desulfurization Sludge Disposal Al-
ternatives. J. Environ. Eng. Div. Am. Soc. C1v. Eng.,
104(EE5): 951-966, October 1978.
3. Barrier, J. W., H. L. Faucett, and L. J. Henson. Economics
of Disposal of Lime-Limestone Scrubbing Wastes: Sludge-Fly-
ash Blending and Gypsum Systems. Draft. U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina,
1978. 187 pp.
4. Barrier, J. W., H. L. Faucett, and L. J. Henson. Economics
of Disposal of Lime-Limestone Scrubbing Wastes: Untreated
and Chemically Treated Wastes. EPA-600/7-78-023a, U.S. En-
vironmental Protection Agency, Research Triangle Park, North
Carolina, 1978. 416 pp.
5 Edwards, R. G». A. B. Broderson, and W. P. Hauser. Social,
* Economic, and Environmental Impacts of Coal Gasification and
liquefaction Plants. IMMR 14-GR2-76, Institute for Mining
and Minerals Research, University of Kentucky, Lexington,
Kentucky, *976. 269 pp. (Available from National Technical
Information :>.-v1ce OTIS) as PB-253 747).
6 Employment and Earnings (U.S. Bureau of Labor Statistics)
24(11):1-138. November 1977.
7 Federal Energy Administration, Office of Utility Project Op-
erations. Inventory of Power Plants in the United States.
FEA/G-77/202, June 1977. 350 pp. (Available from National
Technical Information Service (NTIS) as PB-269 867).
8 FUna R. B., W. M. Graven, F. 0. Hess, P. P. Leo, R. C.
Rossi* and J. Rossoff. Disposal of Flue Gas Cleaning
Wastes: EPA Shawnee Field Evaluation; Initial Report. EPA-
600/2-76-070, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, 1976. 219 pp. (Available
from National Technical Information Service (NTIS) as PB-251
876).
115
-------
Fling, R. B., W. M. Graven, P. P. Leo, and J. Rossoff. Dis
posal of Flue Gas Cleaning Wastes: EPA Shawnee Field Evalu
ation; Second Annual Report. EPA-600/7-78-024, U.S. Envi-
ronmental Protection Agency, Research Triangle Park. North
Carolina, 1978. 184 pp.
Le, T., E. Rubin, and P. Meier. Coal Utilization in the
Northeast. Volume VIII. Solid Waste Management Issues and
Impacts. Draft. U.i. Department of Energy, Washinqton.
D.C., 1978. 93 pp.
Lunt, R. R., C. 8. Cooper, S. L. Johnson, J. E. Oberholtzer
G. R. Schimke, and W. I. Watson. An Evaluation of the Dis-
posal of Flue Gas Desulfurization Wastes in Mines and the
Ocean: Initial Assessment. EPA-600/7-77-051, U.S. Environ
mental Protection Agency, Research Triangle Park, North Car
olina, 1977. 318 pp. (Available from National Technical
Information Service (NTIS) as PB-269 270).
McGlamery, G. G., R. L. Torstrick, W. J. Broadfoot, J. P.
Simpson, L. J. Henson, S. V. Tom)inson, and J. F. Young.
Detailed Cost Estimates for Advanced Effluent Desulfuriza-
tion Process. EPA-600/2-75-006, U.S. Environmental Protec-
tion Agency, Washington, D.C., 1975. 417 pp. (Available
from National Technical Information Service (NTIS) as PB-242
541).
Michael Baker Jr., Inc. State-of-the-Art of Sludge Fixa-
tion. Draft. Research Project 786-1, Task 3, Beaver, Penn-
sylvania, 1977. 251 pp.
Murphy, B. L., G. F. Hoffnagle, J. R. Ma honey, and J. L.
Watson. Energy Consumption of Environmental Controls: Fos-
sil Fuel, Steam ETectrfc Generating Industry. In: Energy
and the Environment. Proceedings of the Fifth National Con-
ference, American Institute of Chemical Engineers, Cincin-
nati, Ohio, 1977. pp. 174-179.
Oglesby, S. , Jr., and G. Nichols. Particulate Control High-
lights: Research on Electrostatic Precipitator Technology.
EPA-600/8-77-020a, U.S. Environmental Protection Agency,
Washington, D.C., 1977. 16 pp. (Available from National
Technical Information Service (NTIS) as PB-276 643).
Pedco Environmental, Inc. Summary Report - Flue Gas Desul-
furlzatlon Systems. U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina, September 1977. 415
pp.
SCS Engineers. Chemical Speclatlon of Flue Gas Desulfurlza-
tlon Constituents. Draft. U.S. Environmental Protection
Agency, Cincinnati, Ohio, 1977.
116
-------
18. Taylor, G. C., and 0. W. Albrecht. A Framework for Economic
Analysis of Hazardous Wastes Management Alternatives. In:
Land Management of Hazardous Wastes, Proceedings of the
Fourth Annual Research Symposium, San Antonio, Texas, March
6, 7, and 8, 1978. D. W. Shultz, ed. EPA-600/9-78-016,
U.S. Environmental Protection Agency, Cincinnati, Ohio,
August 1978. pp. 55-73.
19. Temple, Barker & Sloane, Inc. An Analysis of Recent Elec-
tric Utility Rate Increases. U.S. Environmental Protection
Agency, Washington, D.C., 1975. 99 pp. (Available from Na-
tional Technical Information Service (NTIS) as PB-257 718).
20. Temple, Barker 4 Sloane, Inc. Economic and Financial Im-
pacts of Federal Air and Water Pollution Controls on the
Electric Utility Industry. EPA-230/3-76-013. U.S. Environ-
mental Protection Agency, Washington, D.C., 1976. 403 pp.
(Available from National Technical Information Service
(NTIS) as PB-254 308).
21. Temple, Barker S Sloane, Inc. Economic and Financial Im-
pacts of Federal A1r and Water Pollution Controls on the
Electric Utility Industry. Executive Summary. EPA-230/3-
76-013, U.S. Environmental Protection Agency, Washington,
D.C., 1976. 32 pp. (Available from National Technical In-
formation Service (NTIS) as PB-254 307).
22. U.S. Bureau of the Census. 1974 Census of Agriculture.
Washington, D.C.
23. U.S. Department of Agriculture. Economic Research Service.
Balance sheet of the farming sector. Agricultural Informa-
tion Bulletin 411, Washington, D.C., 1977. 53 pp.
24. U.S. Environmental Protection Agency, Effluent Guidelines
Division. Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the
Steam Electric Power Generating Point Source Cateaory. EPA-
400/1-74 029a, October 1974. 840 pp.
25. Weaver, D. E., C. J. Schmidt, and J. P. Woodyard. Data Base
for Standards/Regulations Development for Land Disposal of
Flue Gas Cleaning Sludges. EPA-6U0/7-77-118, U.S. Environ-
mental Protection Agency, Cincinnati, Ohio, 1977. 285 pp.
26. We&ter, D. W. University of Tennessee. State-of-the-Art
Review of FGD Sludge Stabilization Using Admixtures. Pre-
sented at the 71st Air Pollution Control Association Annual
Meeting and Exhibition, Houston, Texas, June 25-30, 1978.
27 Whitman, Requard and Associates. Handy-Whitman indexes:
electric utility construction. Eng. News-Rec., 199(12 ):97,
September 22, 1977.
117
-------
Federal Power Commission. Form 67 Data (unpublished).
1976.
118
-------
-------
>\
w:.'. a\
1 m
I r '
I L-
«¦ • -«••¦• j.., .>^...,w.—. I,, .,, www
!• »
:
«S
if
. • ••>
/"N
i .
U •
f:
TV
7.
/ ft
r
L
¦f"™" .
k
,y.~
n
X
I—
1
«Stli 1
i.lir-Hiimn ii
-*•" —'¦ '¦"•¦ --"Min
-------
. ^
1^©^., .
jtvCi
l/l
S a
CssS Ov
^ O
C5 cc
U-i Q.
Ou «
a.
u>
------- |