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S-10 − In the area of groundwater-monitoring requirements, eight States (Georgia, Illinois, Indiana, Missouri, Ohio, Pennsylvania, Virginia, and Wisconsin) experienced tightened controls, and two States (Alabama and Texas) experienced relaxed controls, with a ratio of net disposable CCWs (relaxed:tightened) of 0.50:1.0. − In the area of leachate-collection requirements, eight States (Georgia, Illinois, Indiana, Missouri, Ohio, Pennsylvania, Virginia, and Wisconsin) experienced tightened controls, and one State (Florida) experienced relaxed controls, with a ratio of net disposable CCWs (relaxed:tightened) of 0.086:1.0. − In the area of closure and post-closure requirements, three States (Indiana, Pennsylvania, and Virginia) experienced tightened controls, and no States experienced relaxed controls, with a ratio of net disposable CCWs (relaxed:tightened) of 0.0:1.0. − In the area of siting requirements, three States (Illinois, Indiana, and Virginia) experienced tightened controls, and no States experienced relaxed controls, with a ratio of net disposable CCWs (relaxed: tightened) of 0.0:1.0. − In the area of financial assurance requirements, two States (Indiana and Virginia) experienced tightened controls, and no States experienced relaxed controls, with a ratio of net disposable CCWs (relaxed:tightened) of 0.0:1.0. 3. In the 16 States hosting surveyed units, we found that State regulators did not issue variances unless there were sound scientific bases to support the variance requests. A comprehensive review of 65 permits, covering 39 newly constructed or expanded units in the time frame of 1994 to 2004, found that approximately half of the units had requested one or more variances. 8 In this review, we erred on the side of overestimating the number of variance requests; anything in a permit that looked like it might be a variance was included, even if the permit itself identified no variances. A total of 52 variance requests in 9 of the 16 States containing surveyed units were identified. Eighteen of the units requesting variances were landfills; one was a surface impoundment. Of the 52 variance requests identified, 5 were rejected and 47 were granted. Of the 47 granted, 16 were granted with provisions that would 8 Copies of the 65 permits (of a total of 85 permits reported for the surveyed units) were received from 39 of the 45 surveyed units. Some of these units have multiple permits (e.g., solid waste, construction, and dam safety).
S-11 revoke or alter the variance if certain conditions were not met. Twelve were granted because the requirement for which the variance was sought (e.g., landfill gas monitoring) was not appropriate or necessary for a disposal unit that manages CCW wastes. Ten variances were granted because the State allows variances for which it can be demonstrated that a proposed alternative meets or exceeds the environmental performance of the otherwise applicable requirement. Finally, six were identified and included as granted variances, even though the permit to which these variances pertained did not characterize them as variances. Most of the requests reviewed (with the exception of those that were not appropriate because the regulations were developed for wastes other than CCWs) were not to exempt the unit from requirements, but rather to allow for an alternative approach or material that would accomplish the same objective. In States where solid waste permits are required for units managing CCWs, few of the variance requests were for liners or groundwater monitoring. − There were seven variance requests (covering six units) for variances to liner requirements, but none requested exceptions. Rather, they requested changes to the construction method or liner material that would provide equal or greater protection than that afforded by the regulations. − Four variance requests addressed groundwater monitoring, and each request was for a variance only from the requirement to monitor for organic constituents not contained in CCWs; each of the requesting units already conducts groundwater monitoring for numerous other constituents. For the variance requests reviewed, those pertaining to cell height, fire protection, landfill gas/methane, leachate collection, location, pre-siting, signs, solid waste management plans, and standards for sewage works were granted with stipulations or were granted because the requirements were not appropriate for CCWs. The data and analyses documented in this report provide new information that appears to show improved management of CCWs in both landfills and surface impoundments.
Page 5: ACKNOWLEDGMENTS The authors wish to
Page 8 and 9: CONTENTS (Cont.) 3.1.9 Testing for
Page 10 and 11: TABLES (Cont.) 7 Trends in Construc
Page 12 and 13: TABLES (Cont.) A.14 Chronological C
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Page 16 and 17: MCL maximum contaminant level MoDNR
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Page 20 and 21: S-2 the National Rural Electric Coo
Page 22 and 23: S-4 Groundwater-monitoring requirem
Page 24 and 25: S-6 receives only material that the
Page 26 and 27: TABLE S-2 Summary Results from Chro
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Page 32 and 33: 2 Air heater and precipitator wash
Page 34 and 35: 4 wastes, and 17% were bottom ash.
Page 36 and 37: TABLE 1 (Cont.) State a Total CCWs
Page 38 and 39: 8 The remainder of this report cont
Page 40 and 41: 10 (NRECA) and the American Public
Page 42 and 43: 12 Information collected during the
Page 44 and 45: 14 − Type of variance (e.g., clos
Page 46 and 47: 16 potential duplication with the s
Page 48 and 49: TABLE 2 (Cont.) ID a Unit Name 18 S
Page 50 and 51: 20 Because new power plants built d
Page 52 and 53: 22 the number of new and expanded u
Page 54 and 55: 24 TABLE 7 Trends in Construction C
Page 56 and 57: 26 TABLE 8 Percentages of Wastes Di
Page 58 and 59: 28 TABLE 9 Numbers and Types of Per
Page 60 and 61: TABLE 11 Liner and Groundwater-Moni
Page 62 and 63: FIGURE 2 Liners in Identified New o
Page 64 and 65: 34 FIGURE 4 Liner Types Reported fo
Page 66 and 67: 36 Constituents monitored. Landfill
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Page 70 and 71: 40 (Class I) wastes for which no li
Page 72 and 73: 42 States (Alabama, Florida, Georgi
Page 74 and 75: 44 TABLE 20 Solid Waste Permitting
Page 76 and 77: 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
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TABLE G.1 Permits Issued for Survey
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TABLE G.1 (Cont.) Unit ID State Typ
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H-1 APPENDIX H: LINER DATA
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TABLE H.1 Liner Data Unit Is Unit N
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TABLE H.1 (Cont.) Unit Is Unit New
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TABLE H.1 (Cont.) Unit Is Unit New
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I-1 APPENDIX I: GROUNDWATER-MONITOR
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TABLE I.1 Groundwater-Monitoring Da
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TABLE I.1 (Cont.) ID GWM Conducted
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J-1 APPENDIX J: VARIANCE REQUESTS B
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TABLE J.1 Variance Requests by Stat
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K-1 APPENDIX K: VARIANCE REQUEST DE
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TABLE K.1 Variance Request Descript
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TABLE K.1 (Cont.) Variance Variance
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TABLE K.1 (Cont.) ID State Granted
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L-1 APPENDIX L: VARIANCE GRANTING R
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TABLE L.1 Variance Granting Rationa
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TABLE L.1 (Cont.) ID State Variance
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