Presentation: "Federal & State Coal Ash Regulations: Dual Compliance Challenges"
On December 28, 2018, Public Act (PA) 640 was signed into law to provide the State of Michigan oversight of coal combustion residual (CCR) impoundments and landfills and to better align existing state regulations with the United States Environmental Protection Agency (USEPA) CCR Resource Conservation and Recovery Act (RCRA) Rule (40 CFR 257 Subpart D) (CCR Rule). The law is aimed at ensuring compliance with the federal CCR standards through a state permitting program that would be deemed to be “equivalent to” or “as protective as” the federal program. If or until EPA approves Michigan’s State CCR Permit Program, owners of CCR facilities must comply with both the Federal CCR rule and the State CCR rules.
This presentation will review compliance with these new State CCR regulations, where they are similar to and differ from the federal CCR Rule, challenges complying with both programs concurrently, development of a Hydrogeologic Monitoring Plan, differing closure criteria requirements and what these mean for operating permit holders.
Presented by the ASCE Southeastern Michigan Branch Environmental Committee
One (1.0) PDH Provided
Molly Reeves, CPG, CPESC
Senior Hydrogeologist at HDR