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

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variance. However, the State (Virginia) appears to have included the variance language in the
permit for the purpose of administrative efficiency. Two other stages of the same landfill have
already been approved for this variance, and the operator plans to apply for the variance as soon
as adequate supporting data are collected, which is likely to occur before the existing permit
requires renewal. Although no revocation provisions were specified, in a parallel variance for
earlier-stage landfills at the same site, the permit provided that if any of the conditions in the
variance were violated, the variance would be immediately withdrawn. Table 28 summarizes the
variance requests pertaining to groundwater-protection standards.
3.3.2.6 Other Variance Requests
Other variance requests pertain to the following types of requirements: cell height, fire
protection, landfill gas/methane, leachate collection, location, pre-siting, signs, solid waste
management plans, and standards for sewage works. Information on these requests is provided in
Table 29 and is summarized below. Appendices K and L provide further details.
For each of the following types—cell height, fire protection, pre-siting, signs, solid waste
management plans, and standards for sewage works—one variance was requested. All six of
these requests were granted, because the regulations for which the variance was requested were
not germane to CCW disposal.
Five requests pertained to landfill gas/methane monitoring requirements. Three were
requests to waive the requirement for management (monitoring, collection and treatment) of
decomposition gases generated within a landfill. All three were granted, because the waste
disposed of does not produce waste gases. Two requests were to waive the requirements to
monitor for methane or decomposition gas. Both were granted for the same reason (the waste
does not produce gases). In one case, the State (Minnesota) stated that if operational records or
other reports indicate possible decomposition gas production in or around the facility, the
Commissioner reserves the right to require monitoring.
Two requests pertained to leachate collection. One requested a waiver to the leachatecollection
and treatment system otherwise required by the regulations. It was granted because the
ash being disposed of is nontoxic. The other requested a variance to allow leachate to flow more
than 130 ft across the base of the liner before encountering a perforated leachate-collection pipe.
This variance was granted, but the State (Wisconsin) regulator reserved the right to require the
submittal of additional information and to modify the approval at any time, if, in the regulator’s
opinion, modifications were necessary.
Two of the requests pertained to location requirements. One was to waive the prohibition
on locating a new solid waste landfill above an underground mine. This request was granted
because the State (West Virginia) Department of Environmental Protection found that the site
had an acceptable margin of safety. The second request was to allow the unit to be located within
100 ft of a regularly flowing surface water body or river, which the regulations otherwise
prohibit. This request was granted, but the permit requires the company to mitigate 2.8 acres of
affected wetlands by adding emergent wetlands in a 2:1 ratio and imposes additional conditions.