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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