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Coal Ash Ponds and Ash Disposal Issues Webinar - Part I - Hot Topic Hour January 13, 2011
Two very enlightening days of discussions on the CCR issue. The extended period for public comments on the proposed rule on Coal Combustion Residuals (CCR) (commonly referred to as coal ash) concluded on November 18, 2010. According to the speakers we can expect a final rule promulgated in 2011 or 2012. The big question is “Will the final rule classify CCR as special wastes subject to regulation under Subtitle C of RCRA (Resource Conservation and Recovery Act) when destined for disposal in landfills or surface impoundments (essentially hazardous waste) or as non-hazardous wastes regulated under Subtitle D of RCRA?” If EPA decides to classify CCR as “hazardous,” under Subtitle C, EPA would create federally enforceable requirements for ash management, including waste generation, transportation and disposal. If CCR is declared non hazardous, under Subtitle D, EPA would only mandate a set of minimum national standards and leave it up to state governments and citizen litigation to enforce them.
Revision Date: 1/13/2011
Tags: 221112 - Fossil Fuel 化石燃料, Schiff Hardin, FLSmidth, American Coal Ash Association, Pneumatic Conveyor, Regulation
Joshua R. More, Partner Schiff Hardin LLP, described how in working with state regulators a utility was able to close an unlined surface impoundment. Like most states, surface impoundments in Illinois are regulated under groundwater quality rules. These rules provide for protection of groundwater quality and do not specifically address design or closure standards for surface impoundments. The Illinois Environmental Protection Agency initially proposed to regulate the closure of surface impoundments under the landfill rules. However, the landfill rules were promulgated after many of the CCR impoundments in Illinois were built, specifically exclude surface impoundments and include numerous design criteria that are impractical for surface impoundments. Therefore, the utility and its legal team, supported by technical analyses from its environmental consulting team, worked with the state to develop a set of site-specific rules governing closure of a CCR impoundment. The site specific rule has become the model for closing CCR impoundments in the State of Illinois.
Revision Date: 1/13/2011
Tags: 221112 - Fossil Fuel 化石燃料, Schiff Hardin, Regulation
US EPA's New Effluent Guideline Limitations
Revision Date: 5/2/2013
Tags: 221112 - Fossil Fuel 化石燃料, Schiff Hardin, Regulation, Effluent Treatment
Effluent Limitations Guidelines Rulemaking
Revision Date: 5/2/2013
Tags: 221112 - Fossil Fuel 化石燃料, Schiff Hardin, Regulation, Effluent Treatment