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 201 OH Liner requirements According to the permit, “deep dynamic compaction” (DDC) is an option as a demonstration project. A company representative explained that the regulatory agency approved use of DDC as an alternative means for densifying the subgrade foundation soils below the liner system prior to construction of the liner system. In this case, the landfill was sited in an unreclaimed mine area. Hence, the subgrade foundation soils consisted of mine spoil material. According to the company, approval of this alternative densification method for subgrade foundation soils was not a variance from any regulatory requirement, including those regarding liner construction. It was simply regulator consent to use an alternative (i.e., unconventional) method for consolidating the subgrade foundation soils. DDC was accomplished by dropping a 20-ton weight from a crane (up to 75 ft in height) approximately 50,000 times over a 25-acre area. This process densified the semiconsolidated mine spoil soils that composed the landfill subgrade, reducing the potential for either total or differential settlement. The DDC method was more cost-effective and time efficient than other subgrade consolidation methods, such as preloading or excavating and recompacting the subgrade soils in controlled lifts. The company reports that the demonstration was completed, and the regulatory agency ultimately certified its acceptance of the prepared subgrade. DDC was found to produce significant densification of the subgrade foundation soils, which assures the integrity of the overlying recompacted soil liner and geomembrane liner. However, the company stated that the regulatory agency expressed concerns related to the lack of documentation on achievement of pre-established performance criteria for certain relatively small areas within the overall project area. None specified The permit allows sieving and recompacting mine spoil according to the permit application or the use of dynamic compaction as a demonstration project alternative. Technically, this might not qualify as a variance. L-12
TABLE L.1 (Cont.) ID State Variance Category Granting Rationale Revocation Provisions Variance Comments 241 VA Groundwater monitoring 241 VA Groundwater monitoring 203 VA Groundwater monitoring None specified in the permit. A company representative explained that the Stage III Landfill did not begin receiving ash until 2002 and that not enough Phase I monitoring data have yet been collected to progress to Phase II monitoring. Even so, the permit Module X, Attachment X-2, Section IV.2(a) states that the variance has been granted for monitoring during Phase II. The company believes the State regulatory agency included the variance language in the permit at the time of the last permit modification for reasons of administrative efficiency, considering that the Phase I monitoring data for the Stage III Landfill so far suggest that support for granting this variance will be available before the permit is due for renewal. After sufficient Phase I monitoring data are available, the company plans to implement the variance during Phase II monitoring based on the current permit language. None specified in the permit. A company representative explained that coal ash has long been generally recognized by industry personnel and State regulators as not presenting an organic pollutant risk. Hence, when the State adopted solid waste landfill regulations in 1988, many coal combustion by-product landfills in the State, including three at power plants owned by the company, requested variances from the section(s) in the regulations requiring testing for organic constituents during Phase II monitoring. Also, groundwatermonitoring data collected after 1988 but before the variance was granted demonstrated that no semivolatile organic compounds, pesticides, polychlorinated biphenyls, or volatile organic compounds other than carbon disulfide, which can occur naturally, were detectable at the landfill site. A company representative provided the following quote from the letter approving the variance: “variance is justified because the facility is a coal ash landfill and not likely to contain and release organic constituents, and because organic constituents have been tested for, but not detected.” None specified. However, for Stages I and II, a parallel variance provides that, if any of the conditions outlined in the variance are violated in any form or manner, the variance will be withdrawn. If any of the conditions outlined in the variance are violated in any form or manner, the variance will be withdrawn. Unknown (the letter granting the variance was not available for review) Module X, Attachment X-2, Section IV.2(a) of the permit indicates that the facility has been granted this variance for the Stage III landfill. However, Module XI, Section XI.D.3, of the permit suggests that the variance may only apply to Stages I and II. None None L-13
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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
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TABLE F.1 (Cont.) Coal Bottom Ash (
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TABLE F.1 (Cont.) Coal Other Unit C
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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 and 270: TABLE L.1 (Cont.) ID State Variance
Page 275: TABLE L.1 (Cont.) ID State Variance
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