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Environment – ccr rule compliance data and information

Background

On April 17th, 2015, the U.S. Environmental Protection Agency (EPA) released a final rule, 40 CFR Parts 257 and 261, entitled “Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals (CCRs) from Electric Utilities; Final Rule.” 80 Fed. Reg. 21302 (Apr. 17, 2015).

EPA’s Rule has been the subject of litigation and appeal. Portions of the rule were appealed, and on August 5, 2016, EPA issued revised rules and deadlines relating to inactive coal combustion residuals (CCR) surface impoundments. 81 Fed. Reg. 51,802 (Aug. 5, 2016). EPA’s latest revision to the 2015 rule was in July March 2018. 83 Fed. Reg. 36435 (July 30, 2018).

Under Subpart D, Part 257, the rule pertains to the management and disposal of CCRs. It establishes minimum national criteria to evaluate operating conditions at existing and new CCR landfills and surface impoundments to ensure that these do not pose an unreasonable risk to the health and the environment of the community in which they are sited.

The Georgia Environmental Protection Division (EPD), which administers solid waste management and disposal provisions in Georgia, has developed regulations relating to CCR landfills, surface impoundments, and expansions codified at Georgia Department of Natural Resources Rules, Section 391-3-4-.10 (“GDNR CCR Rule”). The GDNR CCR Rule adopts EPA’s Standards for the Disposal of Coal Combustion Residuals in Landfills and Surface Impoundments 40 CFR 257.60 through 257.107, however, Georgia’s rules differ in that only those revisions as follows have been adopted: (80 Fed. Reg. 21468 (April 17, 2015); 80 Fed. Reg. 37988 (July 2, 2015); and 81 Fed. Reg. 51807 (August 5, 2016). The EPD is seeking authorization under the 2016 Federal Water Infrastructure Improvements for the Nation (WIIN) Act to administer a coal combustion residuals (CCR) permit program for Georgia under Section 4005 of the Resource Conservation and Recovery Act (RCRA).

Crisp County Power Commission (CCPC) has a small surface impoundment which received coal ash or coal combustion residuals infrequently. CCPC generates electricity with renewable hydropower, natural gas, and coal was utilized on an infrequent and as-needed bases. CCPC’s fossil generating plant is Plant Crisp, located in Warwick, Georgia, was constructed in 1957 and is a dual-fuel facility consisting of a 12.5 megawatt (MW) capacity coal and natural gas-fired plant and a 5 MW capacity natural gas combustion turbine.

Applicability

Subpart D, Part 257 applies to owners and operators of new and existing CCR landfills and surface impoundments, including lateral expansions of such units that manage and dispose of solid waste that is the result of the combustion of coal in an electric utility boiler. Although some exclusions apply, this rule is applicable to Plant Crisp’s 6.1 acre ash pond that has been in operation since the 1970s. GDNR’s CCR Rule also applies to the ash pond.

The ash pond is no longer used. The ash pond was historically used sporadically as the Plant Crisp boiler is a dual fuel (coal and/or natural gas) boiler. For economic reasons, Plant Crisp was operated primarily using natural gas. Crisp County Power Commission ceased use of coal at Plant Crisp and has no coal remaining at the site. Plant Crisp repeatedly meets all air quality requirements dictated by federal and state regulations.

Compliance

Each CCR unit subject to the final rule requirements will record compliance with these requirements in the facility’s operating record, notify the state of decisions and maintain a publicly available website of compliance information. These requirements allow transparency to the community and to the regulatory authorities on a facility’s status with regard to the regulation.

Plant Crisp Ash Impoundment Compliance Information

CCPC has one surface impoundment which no longer receives CCR. The ash impoundment is not lined. CCPC is closing the ash pond. Although the existing impoundment was found to be “low risk” to the community, CCPC has developed a closure plan (see below). As the closure progresses, please visit this website for updates and status of various reporting items. The closure plan is available on this website.

The ash pond is located on a parcel of approximately 100 acres of CCPC property near Lake Blackshear and the Flint River. The ash pond itself is approximately 6.1 acres, with embankments on the western and partially southern and northern sides. The ash pond was inspected in 2014 and 2015. EPA contractor CDM Smith determined that the Plant Crisp ash pond was a low hazard unit during the EPA’s coal combustion residuals impoundment assessment, dated February 2014. CDM Smith. (2014). “Assessment of Dam Safety of Coal Combustion Surface Impoundments – Final Report: Crisp County Power Commission Plant Crisp Warwick, Georgia.” Prepared for U.S. Environmental Protection Agency Washington, D.C., Rev. 1, February 2014. The maximum embankment height is on the west end and is approximately 22 feet high. Rizzo Associates, 2015. Rizzo Associates. (2015). “Dam Safety Assessment Report Plant Crisp Coal Combustion Waste Impoundment.” Submitted to Crisp County Power Commission, 14-5232, Rev. 0, January 2015. Copies of these reports can be found here. Fluid levels in the ash pond are low due to evaporation and environmental factors. Geosyntec Consultants. (2016). “Fugitive Dust Control Plan Crisp Plant Crisp Ash Pond.” Prepared for Crisp County Power Commission, September 2016.

This website is maintained in accordance with 40 C.F.R. § 257.107. and the GDNR CCR Rule. CCPC has developed this website and will maintain it through closure completion or at least five years as provided in 40 C.F.R. §257.107(c).

Fugitive dust control plan

Click here for a copy of the Fugitive Dust Control Plan. Adobe Reader is required.

Closure plan

Click here for a copy of the Closure Plan. Adobe Reader is required.

Reports and documents

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Data collected during the detection monitoring indicated that statistically significant increases were identified for appendix III constituents over background. No constituent exceeded an EPA maximum contaminant level or MCL which establishes the regulatory criteria for drinking water. In 2018, following the completion of the 2018 groundwater monitoring report, EPA revised the groundwater protection standard for constituents which do not have an established drinking water standard. Those rules were appealed and remanded to EPA in August of 2018. In compliance with 40 CFR §257.95(a), CCPC will initiate an assessment monitoring program for the ash pond.