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

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TABLE L.1 (Cont.) ID State Variance Category Granting Rationale Revocation Provisions Variance Comments 222 IN Cover/dust controls None specified in the permit. A company representative explained that the company’s landfill operating plan, which was the basis for the variance request and has been approved by the regulatory agency, contains the following description of how the landfill surface is managed: “Stabilized sludge is placed in a moist condition with an approximate 25% moisture content. Once placed the sludge is compacted and then the curing process minimizes wind as well as water erosion. The landfill will be developed in a manner that will minimize exposure to stabilized sludge surfaces, thereby minimizing the possibility of fugitive dust generation. Subsequent layers of waste are expected to be placed every two weeks, thereby reducing the chance of fugitive dust emission further. In areas where transport vehicles tread on the surface of the fill and on other on-site haul roads where dust may be expected, plant water trucks will be used to moisten the surfaces on a regular basis. Regular haul roads in fill areas will have an eight inch layer of bottom ash or gravel placed to reduce dust and surface wear of stabilized sludge.” 223 IN Closure/post-closure requirements None specified in the permit. The company representative explained that the material being placed into the landfill is Poz-O-Tec, which is produced by a stabilization process. Flue gas desulfurization (FGD) sludges and ash produced by coal combustion power generation facilities are raw materials for this process. Poz-O-Tec is a relatively impermeable material that is not infiltrated significantly by rainwater. Hence, it is important to provide lateral drainage at the interface between the final cover on the landfill and the Poz-O-Tec. The composition of the final cover specified in the variance accomplishes this better than the composition specified in the regulations. In addition, Poz-O-Tec in this coal combustion by-product monofill leaches significantly fewer toxic constituents than materials in a municipal landfill, which is the landfill type to which the regulations were intended to apply. 1. Documentation of violation of requirement to maintain sediment control structures and drainage ditches. 2. Documentation that fugitive dust is creating a nuisance. If vegetation is not established to the satisfaction of the State, soils specified in the regulation will be required. The landfill to which permit No. 77-3 applies is allowed to receive coal combustion by-products that are classified for disposal in Type II or Type III restricted waste areas. 329 IAC 10-36-11 allows the use of alternative cover material if it can be demonstrated that an alternate cover or site design will provide an adequate level of environmental protection. This variance has been in place since 1992. L-6
TABLE L.1 (Cont.) ID State Variance Category Granting Rationale Revocation Provisions Variance Comments 226 IN Cover/dust controls None specified in the permit. The permit merely indicates that 329 IAC 10-28-11(a) grants the commissioner the authority to approve an alternative cover if it can be demonstrated that the alternative will provide an adequate level of environmental protection. A company representative explained that intermediate cover has two purposes: (1) dust control in unused or seldom-used fill areas and (2) rainfall infiltration control to minimize leachate formation. The Soil-Sement ® polymer can be shown to fill both of these needs. If properly applied (i.e., multiple coats at effective dilutions), Soil-Sement is more effective at shedding storm water than is the soil cover specified in the regulations. The company representative reported that the manufacturer’s specifications for Soil-Sement were provided to regulatory agency personnel, who also observed an area of the landfill treated with this product. Some agency personnel were familiar with use of Soil-Sement at other coal combustion facilities in the State. According to the company representative, all agency personnel have been satisfied that Soil-Sement is an effective alternative to soil cover for this type of facility. 228 IN Cover/dust controls None specified in the permit. A company representative explained that the purposes of requiring intermediate cover at municipal landfills, which is the facility type for which the regulations were originally developed, are to deter vectors and to control fugitive dust. Because coal combustion products are composed of inorganic constituents, vector control is not needed. Also, dusting from coal combustion products can be controlled using compaction techniques and water. Therefore, to require intermediate or daily cover would only add operational expense and take up valuable landfill space with no added environmental benefit. The facility has developed and implemented a fugitive dust control plan, and the company representative indicated that dusting has not been a problem. “In the event that the alternative cover material does not perform as intended, or does not appear to be equivalent to one foot of intermediate cover soil, one foot of intermediate cover of clay type soil may be required by 329 IAC 10-28-12(a)(3).” Documented violation of requirement to maintain sediment control structures and drainage ditches. Information on the variance request to use Soil- Sement was contained in a March 18, 1994, letter. The landfill to which permit No. FP 26-2 applies is allowed to receive coal combustion by-products that are classified for disposal in Type II restricted waste areas. L-7
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ACKNOWLEDGMENTS The authors wish to
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CONTENTS (Cont.) 3.1.9 Testing for
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TABLES (Cont.) 7 Trends in Construc
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TABLES (Cont.) A.14 Chronological C
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xii
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MCL maximum contaminant level MoDNR
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xvi
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S-2 the National Rural Electric Coo
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S-4 Groundwater-monitoring requirem
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S-6 receives only material that the
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TABLE S-2 Summary Results from Chro
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S-10 − In the area of groundwater
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S-12
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2 Air heater and precipitator wash
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4 wastes, and 17% were bottom ash.
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TABLE 1 (Cont.) State a Total CCWs
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8 The remainder of this report cont
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10 (NRECA) and the American Public
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12 Information collected during the
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14 − Type of variance (e.g., clos
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16 potential duplication with the s
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TABLE 2 (Cont.) ID a Unit Name 18 S
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20 Because new power plants built d
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22 the number of new and expanded u
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24 TABLE 7 Trends in Construction C
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26 TABLE 8 Percentages of Wastes Di
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28 TABLE 9 Numbers and Types of Per
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TABLE 11 Liner and Groundwater-Moni
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FIGURE 2 Liners in Identified New o
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34 FIGURE 4 Liner Types Reported fo
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36 Constituents monitored. Landfill
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38 impoundments). The analysis does
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40 (Class I) wastes for which no li
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42 States (Alabama, Florida, Georgi
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44 TABLE 20 Solid Waste Permitting
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46 United States in 2004. The one S
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3.2.2 Findings 48 Table 22 summariz
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TABLE 22 (Cont.) Category of Regula
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52 the surveyed units was conducted
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TABLE 23 Variance Requests and Disp
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56 request, the State regulatory ag
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TABLE 26 Variance Requests by Surve
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TABLE 27 (Cont.) Variance Request S
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62 variance. However, the State (Vi
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TABLE 28 (Cont.) Variance Request S
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TABLE 29 Variance Requests by Surve
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69 5 REFERENCES ACAA 2004 American
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A-1 APPENDIX A: STATE-SPECIFIC REGU
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A.1 APPROACH A-3 APPENDIX A: STATE-
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A-5 For each State reviewed, an eff
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TABLE A.2 Summary of Regulatory Des
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A-9 addition, the regulations in Al
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TABLE A.3 Chronological Comparison
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A-13 A disposal facility in Indiana
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TABLE A.4 Permits Required for CCW
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TABLE A.4 (Cont.) a The pilot study
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A-19 landfills. Otherwise, surface
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TABLE A.5 (Cont.) a “On-site” m
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A-23 groundwater and surface water
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A-25 discharge), the facility may s
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A-27 Wisconsin—Wisconsin designat
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TABLE A.6 (Cont.) State a Illinois
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TABLE A.6 (Cont.) State a Landfills
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TABLE A.6 (Cont.) State a Landfills
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TABLE A.7 Chronological Comparison
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TABLE A.7 (Cont.) State EPA 1988 EP
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A-39 Illinois—In Illinois, landfi
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A-41 The design standards for utili
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A-43 According to Technical Guideli
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TABLE A.13 Summary of Groundwater-M
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TABLE A.13 (Cont.) State a Groundwa
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A-49 such as a commercial industria
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A-51 The Indiana regulations do not
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A-53 developed guidance documents,
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A-55 groundwater. Table A.15 summar
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TABLE A.15 (Cont.) State Leachate-C
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A-59 TABLE A.16 Chronological Compa
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A-61 quality standards, or otherwis
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A-63 A.7 CLOSURE/POST-CLOSURE REQUI
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TABLE A.17 (Cont.) State Closure/Po
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A-67 Type III restricted waste site
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TABLE A.19 Summary of Corrective Ac
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A-71 the plume (329 IAC 10-29-9). T
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TABLE A.20 Summary of Siting Contro
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A-77 The Virginia regulations speci
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TABLE A.24 Summary of Additional In
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A.12 FINDINGS A-83 Table A.26 summa
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TABLE A.26 (Cont.) States with Chan
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TABLE A.26 (Cont.) Description of C
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A-89 TABLE A.27 Summary of States w
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B-1 APPENDIX B: QUESTIONNAIRE FOR N
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B-3 APPENDIX B: QUESTIONNAIRE FOR N
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Compacted ash Compacted in-situ soi
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7.0 Monitoring B-7 7.1 Is groundwat
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C-1 APPENDIX C: SURVEY RESPONSE RAT
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C-3 APPENDIX C: SURVEY RESPONSE RAT
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C-5 USWAG asked for a response from
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C-7 nonsurveyed units). The capacit
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D-1 APPENDIX D: RECONCILIATION OF U
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TABLE D.1 Reconciliation of Units I
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E-1 APPENDIX E: UNIT COMPLETION DAT
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TABLE E.1 Trends in Unit Completion
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F-1 APPENDIX F: MATERIALS DISPOSED
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TABLE F.1 Materials Disposed of at
Page 219 and 220: TABLE F.1 (Cont.) Coal Bottom Ash (
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Page 223 and 224: G-1 APPENDIX G: PERMITS ISSUED FOR
Page 225 and 226: TABLE G.1 Permits Issued for Survey
Page 227 and 228: TABLE G.1 (Cont.) Unit ID State Typ
Page 229 and 230: H-1 APPENDIX H: LINER DATA
Page 231 and 232: TABLE H.1 Liner Data Unit Is Unit N
Page 233 and 234: TABLE H.1 (Cont.) Unit Is Unit New
Page 235 and 236: TABLE H.1 (Cont.) Unit Is Unit New
Page 237 and 238: I-1 APPENDIX I: GROUNDWATER-MONITOR
Page 239 and 240: TABLE I.1 Groundwater-Monitoring Da
Page 241 and 242: TABLE I.1 (Cont.) ID GWM Conducted
Page 247 and 248: J-1 APPENDIX J: VARIANCE REQUESTS B
Page 249 and 250: TABLE J.1 Variance Requests by Stat
Page 251 and 252: K-1 APPENDIX K: VARIANCE REQUEST DE
Page 253 and 254: TABLE K.1 Variance Request Descript
Page 255 and 256: TABLE K.1 (Cont.) Variance Variance
Page 263 and 264: TABLE K.1 (Cont.) ID State Granted
Page 265 and 266: L-1 APPENDIX L: VARIANCE GRANTING R
Page 267 and 268: TABLE L.1 Variance Granting Rationa
Page 269: TABLE L.1 (Cont.) ID State Variance
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