The Geosynthetics Manufacturers Association (GMA), in a formal response to the EPA’s publication of a proposed rule aimed developing regulations to govern the storage of Coal Combustion Residuals (CCRs) has well supported the use of engineered geosynthetic lining systems as the most qualified measure of containment technology available today.
GMA is in the process of crafting a second response to the EPA which will address in more detail, specific questions posed by the EPA in their recently published Proposed Rule. As the EPA works to establish the best method of managing CCRs the published Proposed Rule is posted on-line with a solicitation for comment by September 10, 2010.
The proposed rule titled 40 CFR Parts 257, 261, 264 et al. – Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule – Docket ID No. EPA-HQ-RCRA-2009-0640. is investigating two proposals for regulating CCRs:
"… Under the first proposal, EPA would reverse its August 1993 and May 2000 Bevill Regulatory Determinations regarding coal combustion residuals (CCRs)and list these residuals as special wastes subject to regulation under subtitle C of RCRA, when they are destined for disposal in landfills or surface impoundments. Under the second proposal, EPA would leave the Bevill determination in place and regulate disposal of such materials under subtitle D of RCRA by issuing national minimum criteria. Under both alternatives EPA is proposing to establish dam safety requirements to address the structural integrity of surface impoundments to prevent catastrophic releases."
GMA encourages industry comments on the proposal, which can be made by clicking on the “Submit Comment” link in the top left of the on-line proposal referenced above.
Send your conference or event information to Chris Kelsey, chris@geosynthetica.net.
