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

7
management practices may have improved to the point where concerns over environmental
exposures have been mitigated, minimized, or possibly eliminated. Therefore, DOE, in
consultation with the EPA, conducted further investigation into current disposal practices for
these remaining wastes with the objective of updating the 1995 information base on management
practices. If, in fact, controls and State oversight have improved since 1995, this development
would have a bearing on how the EPA would describe any further controls that might be
necessary to protect human health and the environment, which could minimize costs to industry
and its customers.
1.5 STUDY OBJECTIVE
The information on which the EPA based its 2000 RD—a 1997 Electric Power Research
Institute (EPRI) study reflecting information up to 1995 (EPA 1999a)⎯does not account for
changes in industry disposal and State regulatory practices pertaining to CCWs that might have
occurred since 1995. DOE was concerned that the imposition of additional regulations could
increase energy costs for consumers without a significant concomitant improvement in human
health or environmental quality. DOE and the EPA agreed to conduct a joint study to examine
data on CCW disposal practices; State regulatory practices; and the numbers, types, and
rationales for variances to regulatory requirements granted by States between 1994 and 2004.
This report describes the approach used to collect and analyze the data and the findings produced
by that analysis.
The objective of this study is to collect, analyze, and provide accurate, current, and
verifiable data on CCW management practices, State regulatory requirements, and the
implementation of those requirements. Its findings will be used to assist the EPA in determining
what requirements are appropriate in developing a Federal regulation of CCWs under a RCRA
Subtitle D rule.
1.6 STUDY SCOPE
The EPA identified the following three areas of interest:
1. Recent and current CCW industry surface disposal management practices,
2. State regulatory requirements for CCW management, and
3. Implementation of State requirements (e.g., the extent to which States grant or
deny operator requests to waive or vary regulatory requirements and the
rationales for doing so).
For each of these factors, the EPA is most interested in the extent to which liners and
groundwater monitoring are incorporated into new and expanded disposal units. This study,
therefore, focuses on liners and groundwater monitoring.