Coal Combustion Waste Management at - DOE - Fossil Energy ...

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disposal units. In addition, a January 2006 follow-up identified six supplemental disposal units
from four utilities that had not responded to the December 2004 survey. Adding the capacities of
these utilities to the total brings the response rate up to 71%, using the capacity proxy. This is a
conservative estimate for the following reasons: (1) the actual coal-fired power plant capacity
requiring CCW disposal capacity is much less than the generating capacity that was used to
calculate the sample coverage rate; (2) the total U.S. coal-fired power plant capacity (335.2 GW
in 2004) includes those power plants that are on standby and produce neither power nor CCWs;
(3) a significant portion (between 35% and 40%, according to different sources) of CCWs are
beneficially used, thus requiring no disposal in waste units; and (4) because less than 3% of the
total coal-fired generating capacity has been added during the period that closely corresponds to
the survey period, new disposal capacity would be required for only a small portion of the total
generating capacity.
For the State regulatory analysis, our initial objective was to compare current CCWrelated
regulatory requirements with comparable information from earlier reports. It was evident
from the outset, however, that a nationwide study of the CCW regulations and their
chronological changes in the States that have coal-fired generating capacity would not be
feasible under the time and resource constraints of this study. Therefore, an alternative approach
was undertaken, namely reviewing the current regulatory programs applicable to CCWs in States
that contain units of one or more of the following types and comparing the results with
corresponding information from earlier reports: (1) new CCW disposal units (i.e., those
permitted, constructed, or laterally expanded between 1994 and 2004) and (2) units that are the
basis of proven, potential, or alleged damage cases. 2 Of the 26 States identified as meeting the
selection criteria, a pilot study involving five States (Pennsylvania, Illinois, Indiana, Virginia,
and Wisconsin) was conducted to determine whether it would be feasible, within the established
budget and schedule constraints, to collect enough data for all 26 States to allow comparisons of
current regulatory requirements with comparable information from earlier reports and identify
changes.
Information collected during the pilot study covered the following categories of
regulatory control:
Regulatory designation of CCWs for disposal,
Permitting requirements,
Liner requirements,
2 In comments to the EPA, public interest groups have identified cases in which they allege that damage to
human health or the environment was caused by fossil-fuel-combustion waste management units. As of
May 2006, 86 of the alleged damage cases have been investigated by the EPA to verify the existence and cause
of the damage. As defined in the 1999 RTC, proven damage cases are those with exceedences of primary
maximum contaminant levels (MCLs) or other health-based standards in groundwater or surface water off-site
or at a distance from the waste management unit sufficient to conclude that they could cause human health
concerns, while potential damage cases are those with (1) documented exceedences of primary MCLs or other
health-based standards on-site or beneath or close to the waste source, and/or (2) documented exceedences of
secondary MCLs or other non-health-based standards on-site or off-site.