On May 18, 2023, EPA published the proposed Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy CCR Surface Impoundments (proposed rule) in the Federal Register to amend subpart D of part 257 of Title 40 [Docket ID No. EPA-HQ-OLEM-2020-0107; FRL–7814-02-OLEM]. TRC initially summarized key aspects of EPA’s proposed rule in Summary of Proposed Coal Combustion Residuals Legacy CCR Surface Impoundments Rule, June 15, 2023. Drawing from our expertise and extensive experience supporting utilities as they navigate the intricacies of the CCR rule, TRC has submitted public comments related to EPA’s proposed compliance timeline and schedule.
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Background and Public Comment Status
EPA’s proposed rule would regulate Legacy CCR Surface Impoundments and Coal Combustion Residual Management Units (CCRMU) under the existing Subpart D of part 257 of Title 40, known as the CCR Rule, which became effective on October 19, 2015. The proposed rule adds the following two categories of currently unregulated CCR units:
- Legacy CCR Surface Impoundments. Inactive surface impoundments at inactive or closed electric utilities that no longer receives CCR, but contained both CCR and liquids on or after October 19, 2015; and
- CCRMUs. Other areas at electric utilities where CCR is managed or has inadvertently been spilled directly on land, such as previously closed or inactive landfills, and previously closed surface impoundments – unless the CCR use meets the proposed rules’ criteria for beneficial use off site.
EPA received public comments on the proposed rule from May 18 through July 17, 2023, hosted an in-person hearing on June 28, 2023, and an online public hearing on July 12, 2023. EPA also held an online meeting with the Utility Solid Waste Activities Group (USWAG) affiliates on June 20, 2023, to answer questions and gain feedback on the proposed rule.
One of EPA’s objectives for the proposed rule is to address the D.C. Circuit Court of Appeals decision of August 21, 2018, which found EPA remiss in not specifically addressing legacy CCR impoundments. A second EPA objective is to incorporate other past CCR management practices at CCR accumulation areas where CCR was placed or spilled directly onto the ground, referred to as CCRMUs.
Both the legacy CCR impoundments and the other CCR accumulation areas (CCRMUs) are currently exempt from regulation under the existing 2015 CCR rule.
The proposed rule has broad sweeping compliance obligations for sites with both inactive impoundments and landfills, and/or CCRMUs by extending inspection, groundwater monitoring, cleanup, closure, record keeping, and public internet reporting obligations for legacy impoundments at inactive sites and inactive landfills at regulated sites. Through regulation of CCRMUs, the proposed rule would also drastically change beneficial use of CCR materials at facilities. Two key exclusions under the proposed rule are:
- An active or inactive utility that only has inactive or closed landfills on site would not be covered by the proposed rule unless there are inactive or active surface impoundments present, then the inactive landfill is covered under the proposed rule and would be regulated as a CCRMU; and
- The current proposal would not apply to a utility that only has a landfill that closed prior to October 19, 2015, at an inactive site.
Key Considerations and Identified Challenges
Key Considerations and Identified ChallengesOn July 17, 2023, TRC submitted public comments to EPA’s Docket (Docket ID No. EPA-HQ-OLEM-2020-0107) for the proposed rule with the goal of providing feedback that will improve the successful implementation of the proposed rule while honoring EPA’s efforts to address CCR-related groundwater impacts that pose an unacceptable risk to human health and the environment.
TRC note that the requirements of the proposed rule will have significant impact to electric utility facilities regulated by the proposed rule, and the costs of these impacts will ultimately be borne by the electric rate payers, further burdening economically disadvantaged populations. Many comments are related to identified challenges imposed by the proposed rule including the expedited compliance and implementation timeframes, which will be difficult, if not impossible, to achieve within EPA’s aggressive timelines based on available resources. TRC also reviewed comments posted by EPA on the docket from other stakeholders and found that that many highlighted similar common themes and challenges. Our comments identified key consideration and challenges including:
- CCRMUs too broadly defined;
- Asset retirement considerations;
- Limited consultant and contractor resources available;
- Aggressive and unattainable groundwater monitoring compliance schedule;
- Closure timeframes need to recognize the difficulty to achieve groundwater protection standards (GWPS);
- Alignment with existing EPA Guidance; and
- Allowance for risk-based management strategies following available EPA and state policy and guidance.
A more detailed description of these key considerations is provided in our comments to the EPA docket.
Based on these concerns, we offered an alternative compliance schedule to EPA that would proceed at an accelerated pace while aligning with the objectives of other existing EPA regulatory programs such as CERCLA and RCRA. Our proposed alternative compliance schedule considers the availability of consultant and contractor resources to implement the proposed rule and make informed decisions using site-specific data.
How TRC Can Help
TRC will continue to monitor the development of this proposed Rule change and other upcoming CCR related rulemaking, and track what it means for the industry and our clients.
TRC delivers engineering, construction and environmental strategies for all phases of coal ash management and compliance. Our scientists and engineers are experts in all aspects of the CCR rule including evaluating/applying Federal and State regulations, identifying technical remedies and business implications for compliance options and designing engineering solutions to address site-specific issues. For more information on the regulatory outlook for coal ash, or to discuss our coal ash management solutions please contact our experts below.
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Additional Restrictions for Major Modifications Other restrictions will come into play for new Major Sources, those that have a potential to emit 50 tons per year or more of VOC or NOx and “major modifications” that result in a VOC emission increase that exceeds 25 tons per year and also exceeds 25 tons per year when aggregated with all creditable increases and decreases in emissions of VOC from the source over any period of five consecutive years, which includes the calendar year in which the increase will occur. For sources that are major due to NOx emissions, a NOx emission increase that exceeds 25 tons per year and exceeds 25 tons per year when aggregated with creditable increases and decreases over the five-year period is also deemed to be a major modification. If a major modification occurs, the source is required to utilize the Lowest Achievable Emission Rate (or LAER) for the pollutant(s) that exceed 25 tons per year aggregated over the five-year period. However, Best Available Control Technology (BACT) can be substituted for LAER under certain conditions. Additionally, emissions must be offset as a means to advancing the area toward attaining the ozone standard. These same requirements will apply to newly constructed Major Sources. Upcoming Deadlines With these actions, the impacted areas will now have until August 3, 2027, to reach attainment. If they do not, USEPA is again obligated to reclassify ongoing nonattainment status to Severe nonattainment, reducing the Major Source threshold in half to just 25 tons per year. In the meantime, the states will be required to revise State Implementation Plans to demonstrate that attainment will be achieved by this deadline. A unique consideration in Wisconsin affects sources subject to a Registration Operation Permit. These permits establish annual emission limits as a percentage of the Major Source threshold (25, 50, or 80 percent depending on the Permit). For these sources, the annual emission limit for VOC and NOx will automatically be cut in half on January 16, 2025. Sources in the ozone nonattainment areas that hold these permits should evaluate whether the Registration Permit provides a long-term option given that the annual emission limits have been cut in half now and may again be cut in half in three years’ time. Next Steps: TRC Can Help TRC is available to support your air compliance and permitting needs by offering expert in-house resources to perform: Ambient Monitor Siting Evaluation Ambient Monitor Deployment, Operation and Maintenance For more information, contact Melanie Klamar, Robert VandenMeiracker and Mike Zebell.
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FERC Issues Annual Report on Critical Infrastructure Protection (CIP) Reliability Audits
November 17, 2020
In its 2020 Report on CIP Reliability Audits, the Federal Energy Regulatory Commission found that most of the cybersecurity protection processes and procedures adopted by utilities met the mandatory CIP requirements for protecting the Bulk Electric System. However, there are areas for improvement.
TRC Digital partners with Dominion Energy to evolve its distributed energy resource strategy
September 22, 2020
Dominion Energy, one of the nation’s largest producers and transporters of energy, has partnered with TRC Digital to evaluate, implement and integrate technology to further the utility’s distributed energy goals. TRC Digital will facilitate Dominion Energy’s strategy development and technology execution, allowing Dominion Energy and its customers to accelerate the shift to distributed energy resources (DER) and net carbon reduction.
NERC Issues 2020 State of Reliability Report
September 22, 2020
The Report identifies areas of ongoing concern including generation reserve margins and the reliability risk from shifting the resource mix toward renewables.
TRC Digital and Reactive help utilities measure inertia for a more resilient grid
September 21, 2020
Together, TRC and Reactive combine TRC’s industry-leading power engineering expertise with Reactive’s machine learning software to provide utility teams with high-resolution frequency monitoring and automatic event analysis.
NERC Issues Lessons Learned on Misoperations Due to Mixing Relay Technologies
August 13, 2020
On July 10, 2020 NERC released new Lessons Learned guidance to address situations where multiple composite protection systems have misoperated as a result of mixing protective relay technologies at the remote terminals of directional comparison blocking (DCB) schemes. This technical information will help utilities improve the reliability of the Bulk Power System.
NERC Reliability Standard PRC-024-3 Approved: Frequency and Voltage Protection Settings for Generating Resources
July 28, 2020
On July 9, 2020 NERC standard PRC-024-3 was approved, paving the way for improved protection systems in support of keeping generating resources connected during defined frequency and voltage excursions.
Summary of NERC CIP Standards Updates
June 29, 2020
FERC has released a notice of inquiry seeking comments on potential enhancements to NERC’s Critical Infrastructure Protection (CIP) Reliability Standards.
TRC Digital Partners with Treverity to Put Utility Engineers at the Center of Their Data
June 26, 2020
As part of TRC’s LineHub solution, Treverity helps transmission engineers get a holistic view of the grid through powerful digital data visualization and a customer-centric user interface.
Strategic Electrification
February 4, 2020
As we look to spur strategic electrification across the US, it will be up energy providers and solution implementers to continue sharing ideas, insights and lessons learned
NERC Reliability Report Prioritizes Power System Security Risks for Action
January 2, 2020
NERC’s 2019 ERO Reliability Risk Priorities Report identified and prioritized the major risks facing the utility industry with a particular focus on security issues.
TRC Expands Presence in Power Market with Acquisition of Ohio-based IJUS
October 1, 2018
LOWELL, Mass. – TRC, a leading provider of end-to-end engineering, consulting and construction management solutions fueled by innovative technology, announced today it has acquired IJUS, a top power/utility engineering firm based in Gahanna, Ohio. Terms of the deal were not disclosed.
NERC Proposes Compliance Monitoring and Enforcement Plan for 2019
September 26, 2018
This month, NERC released the first draft of its 2019 Compliance Monitoring and Enforcement Plan (CMEP) which identifies power delivery system risks and outlines compliance audit requirements for next year. The risk elements outlined in the plan include significant differences from previous years, as shown in the table below. Each NERC region must consider these risks as they develop their monitoring and audit scopes for utilities. Utilities should be prepared to be audited and implement any necessary compliance initiatives in these areas.
NERC Standard Extends Maintenance Program Obligations to Generators
February 3, 2014
The approval of NERC Standard PRC-005-2 extends protection system maintenance obligations to Generators and crates one comprehensive standard establishing minimum maintenance activities and maximum time intervals for protection systems and load shedding equipment affecting the bulk electric system.
