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

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38<br />

impoundments). The analysis does not include the six supplemental units identified by<br />

USWAG’s January 2006 follow-up th<strong>at</strong> was conducted to identify any units th<strong>at</strong> had not<br />

responded to the 2004 survey. 18 To determine if the exclusion of these six units from the<br />

analysis may have produced findings th<strong>at</strong> were not represent<strong>at</strong>ive of the 56 units th<strong>at</strong> comprised<br />

the analysis, we compared the results for the key parameters of interest (liners and groundw<strong>at</strong>er<br />

monitoring) for the following groups of units:<br />

USWAG-surveyed units (from December 2004 survey),<br />

EPA-identified units, and<br />

USWAG supplemental units (identified by USWAG in the 2006 follow-up).<br />

The results are summarized in Table 17 and are described below:<br />

Liners. The percentage of USWAG units identified as having liners in the<br />

2004 survey was 100% (45 of 45); the percentage of EPA-identified units was<br />

91% (10 of 11); and the percentage of supplemental units was 67% (4 of 6).<br />

All of the surface impoundments (surveyed, nonsurveyed, and supplemental)<br />

have liners. The three landfills with no liners (of the total 42 landfills) include<br />

the following:<br />

− One EPA-identified landfill th<strong>at</strong> manages only bottom ash in North<br />

Dakota. North Dakota regul<strong>at</strong>ions classify bottom ash as inert, and inert<br />

wastes in the St<strong>at</strong>e do not require liners. 19<br />

− Two supplemental units (owned by the same utility company) in South<br />

Carolina. One of these landfills is loc<strong>at</strong>ed over a thick geologic unit (marl)<br />

th<strong>at</strong> has a permeability of < 1 × 10 -6 cm/s (the required permeability of<br />

liners) and receives CCWs th<strong>at</strong> are classified by the St<strong>at</strong>e as low-toxicity<br />

18 These units were not included because of time and resource constraints.<br />

19 According to ND Chapter 33-20-01.1, “inert waste” means nonputrescible solid waste th<strong>at</strong> will not generally<br />

contamin<strong>at</strong>e w<strong>at</strong>er or form a contamin<strong>at</strong>ed leach<strong>at</strong>e. Inert waste does not serve as food for vectors. It includes,<br />

but is not limited to, construction and demolition m<strong>at</strong>erial such as metal, wood, bricks, masonry, and cement<br />

concrete; asphalt concrete; tree branches; bottom ash from coal-fired boilers; and waste coal fines from air<br />

pollution control equipment.

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