Page 6 - May/June 2015 Vol. 33 No. 1
P. 6

EPA’s Tough New Coal Ash Regulations
Featuring Major Compliance Responsibilities for Utilities

On December 19, 2014, the long- 2. New design criteria require composite 3. Among the new operating criteria
awaited Environmental Protection liner systems for new landfills, surface are standards for stormwater run-on and
Agency’s (EPA) decision on how it plans impoundments, and lateral expansions. In run-off controls for landfills and their
to regulate coal ash, a by-product of coal- addition, leachate collection and removal lateral expansions, as well as standards for
fired utilities, was published. What’s the systems must be installed for new landfills developing an inflow flood control system
main takeaway? While EPA continues to and their lateral expansions. plan for surface impoundments and their
classify coal combustion residuals (CCR) lateral expansions. Air criteria standards
as non-hazardous waste, they have set Structural integrity criteria have been include a CCR fugitive dust control
forth a series of new requirements and developed for all surface impoundments plan applicable to all existing and new
deadlines which significantly impact all and their lateral expansions. They include units. Weekly and annual inspections are
coal-fired plants. periodic hazard potential classification required for all CCR units, with additional
assessments, structural stability monthly inspections required for surface
Although the rule may change assessments, safety factor assessments, and impoundments.
somewhat once published, it’s a good idea emergency action plans (as applicable).
to start preparing now for the final ruling. What you should be thinking about
Essentially, the EPA established national What you should be thinking about now: CCR fugitive dust control plans
minimum criteria for existing and new now: If safety factor assessments are not must be in place for all existing CCR units
CCR landfills, surface impoundments, completed by the appropriate deadlines or within 6 months after the regulations are
and lateral expansions of those units. The the facility fails to document that the safety published. Run-on and run-off control
criteria address six major areas: factors have been achieved, the existing system plans for existing CCR landfills
surface impoundment must close. A must be prepared within 18 months
1. Location restrictions surface impoundment closure may result in after publication and an inflow design
the search for new CCR disposal capacity, flood control system plan for existing
2. Design criteria conversion to a dry ash management CCR surface impoundments must be
system, or closure of the facility. prepared within 18 months. Weekly
3. Operating criteria inspections by a qualified person must be
Now is the time to begin the initiated within 6 months after the ruling
4. Groundwater monitoring and evaluation of any existing CCR is published for all existing CCR units,
corrective action surface impoundments for previous while annual inspections by a qualified
liner construction, as unlined surface professional engineer must be initiated
5. Closure and post-closure care impoundments are subject to closure if a within 9 months. Monthly inspections
groundwater monitoring sample shows an by a qualified person must start within 6
6. Recordkeeping, notification, and Appendix IV constituent at a statistically months after the publication date of the
internet posting requirements significant level above its groundwater
protection standard.
Here is a high-level overview of each

1. Location restriction standards now
address the siting of CCR units in relation
to the uppermost aquifer, wetlands,
fault areas, seismic impact zones, and
unstable areas. If the facility’s surface
impoundments and landfills can’t comply
with these standards, those units must be
closed. Moreover, new units and lateral
expansions of existing units must meet
these location restrictions before they can
receive CCR waste.

What you should be thinking
about now: If your existing surface
impoundments and landfills can’t
demonstrate compliance with their
respective location restriction standards,
they must be closed. If this happens, it
will require clean closure or closure-in-
place. Further facility actions may include
conversion to a dry ash management
system, construction of a new surface
impoundment, or closure of the facility.

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