Analysis - The Institute for Southern Studies

9. Post-closure monitoring requirements
Of the 34 state regulations reviewed, 11 states require immediate compliance with post-closure groundwater monitoring requirement for
surface impoundments: AZ, LA, MO, ND, NM, NV, NY, OK, SC, TN, UT. Seven states require post-closure groundwater monitoring
only at newly constructed surface impoundments: CO, KY, MI, NC, PA, WI, WV.
Of the 34 states reviewed, 22 states require immediate compliance with post-closure groundwater monitoring requirements for landfills:
AL, CO, GA, IA, KS, KY, MD, MI, MN, MO, MT, ND, NY, OH, PA, SC, TN, TX, UT, VA, WA, WY. Eight states require post-closure
groundwater monitoring at newly constructed landfills: FL, IL, LA, MS, NV, OK, WI, WV.
10. Baseline storage tank/container design and operating standards
The baseline storage tank /container design and operating standards were not evaluated in this RIA because of a lack of data about the baseline
count and conditions of CCR storage or treatment tanks, containers, and containment buildings at electric utility plants
Industry Baseline CCR Disposal Characterization Findings
Appendix F of this RIA presents on a plant-by-plant basis the baseline engineering controls assumed for each of the 383 of the 495 electric
utility plants which onsite dispose CCR (84 plants solely dispose CCR offsite; this RIA assumes that all offsite CCR disposal units are landfills,
and further assumes that all of those offsite landfills currently comply with the engineering controls described in this RIA for the regulatory
options). Exhibits 3I (for landfills) and Exhibit 3J (for impoundments) below summarize the assignment of baseline conditions in this RIA
for these 411 plants which dispose CCR onsite.
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