Page 7 - May/June 2015 Vol. 33 No. 1
P. 7
Although the rule may change somewhat
once published, it’s a good idea to start

preparing now for the final ruling.

regulations for all existing CCR surface management options prior to the effective website. This is one of the most important
impoundments. date of the regulations. aspects of the new rule and is designed
to promote transparency between CCR
4. Owners and operators of existing 5. Closure and post-closure plans for unit operations and management, and the
landfills and surface impoundments must existing surface impoundments and land- public.
install a groundwater monitoring system, fills must be prepared within 18 months
sampling and analysis program, and after the final rule is published. Closure This public information requirement
detection monitoring program within 30 requirements are described for inactive presents the most immediate deadline
months after the final rule is published in surface impoundments, closures for cause, for hundreds of impacted utilities. They
the Federal Register. New units must have and end-of-life unit closures, while post- now need to populate their websites with
a monitoring system before they can take closure care maintenance requirements specified records and information in a
in CCR waste. Groundwater samples must are described for closed units. format suitable for public review no later
be analyzed and the required constituents than six months after publication of the
compared to background levels. What you should be thinking about final rule.
now: Consider units which may
What you should be thinking about require closure and post-closure plan. What you should be thinking about
now: Should concentrations of one or Closures will result in either clean now: Failure to provide the required
more constituents be detected at levels closure or closure-in-place. Additional information on a publicly accessible
above the groundwater protection facility considerations may include website by the effective date of the final
standards, any “unlined” surface conversion to dry ash management rule may subject the affected facility to
impoundment must close, while systems, construction of new surface citizen-led lawsuits. Make sure you have a
lined units must begin an assessment impoundments, the search for new CCR compliant website, ready to launch, with
monitoring program. Now is the time to disposal capacity, or closure of the facility. requirement documentation once the rule
consider obtaining a groundwater sample is made final. Such a website should be
to get a head-start on any necessary 6. All utility companies subject to the designed to be flexible as requirements
corrections, and to consider any unit CCR rule must post certain CCR unit may increase or change over time.
information on a publicly accessible
View online at tnpublicworks.com 7
   2   3   4   5   6   7   8   9   10   11   12