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Closure and Post-closure Care for CCR Units


 

The CCR Rule establishes long-term safety of CCR disposal units that are closing by providing specific standards for closing procedures, post-closure monitoring and maintenance, and time frames for initiation and completion.

 

Inactive CCR Surface Impoundments (40 CFR 257.100)

Inactive CCR surface impoundments are required by the CCR rule to commence closure activities no later than April 17, 2018.  Specific requirements are outlined for both closure in place and closure through CCR removal. Owners of inactive CCR surface impoundments that intend to close the unit were required to prepare a notification of intent to initiate closure by December 17, 2015. This notification should have included a description of intended closure procedures, a timeline for completing closure activities and required certification(s) by a qualified professional engineer. Additionally, annual progress reports on the progress of closure activities are required to be completed. The first annual report must be prepared within 13 months of preparing the notification of intent to initiate closure and the second annual report must be prepared 12 months afterwards. Upon completion of closure activities, a notification of completion of closure with certification from a qualified professional engineer must be submitted within 60 days of completing closure of the CCR surface impoundment.

 

Closure or Retrofit of CCR Units (40 CFR 257.101)   

The CCR Rule requires mandatory closure or retrofitting of a CCR disposal facility under the following circumstances:

  • At any point past the effective date of the CCR Rule (October 19, 2015), if it is determined that concentrations of at least one Appendix IV constituent are found to be above the groundwater protection standard, the unit must cease receiving all waste (CCR and non-CCR) and closure activities (or retrofitting) must be initiated within six months of making the determination.
  • If a CCR unit is unable to comply with the location standard and is unable to prove the unit can still operate safely in accordance with the location restrictions by the deadline (October 17, 2018), the unit must cease receiving all waste (CCR and non-CCR) and closure activities must be initiated within six months of the deadline.
  • If the owner of an existing CCR surface impoundment fails to complete the initial or subsequent safety factor assessment by the deadline (initial: October 17, 2016; subsequent: every five years thereafter) or fails to document that the calculated factors of safety meet minimum safety factors, the unit must cease receiving all waste (CCR and non-CCR) and begin closure activities within six months of the deadline.

 

Criteria for Conducting the Closure or Retrofit of CCR Units (40 CFR 257.102)

The CCR Rule establishes specific criteria for voluntary and mandatory closure or retrofitting, including timelines for completion, documentation, and allowances for time extensions. For existing CCR landfills and existing CCR surface impoundments, an initial written closure plan must be completed by October 17, 2016. When closure of a CCR unit occurs because of an owner’s voluntary decision to cease using the unit, the CCR Rule establishes the following requirements:

  • When it is known that a CCR unit is receiving its final waste shipment or when the known final volume of CCRs is removed for beneficial use, closure must begin within 30 days of receipt or removal.
  • For idle CCR units, the owner or operator must initiate closure of the CCR unit within two years after receiving its last shipment of waste (CCRs or non-CCR) or within two years after removing the last volume of CCRs for beneficial use, whichever is later. The CCR Rule provides procedures for rebuttal of this closure requirement.

For all CCR landfills, closure activities must be completed within six months of initiating closure activities; for all CCR surface impoundments, closure activities must be completed within five years of initiating closure activities. If the owner of a CCR disposal unit can prove that the time frame for closure completion is not feasible due to factors beyond the facilities control, the CCR rule has established procedures for extending the closure time frame.

When retrofitting an existing surface impoundment, a written retrofit plan must be completed at least 60 days prior to commencing retrofit activities. Retrofit activities must be completed within the same time frames specified for closure activities.

 

Alternative Closure Requirements (40 CFR 257.103)

Under the CCR Rule, a CCR unit may continue to receive CCR if the owner or operator can certify the absence of alternative disposal options for the facility. Inconvenience and increased costs are not considered sufficient qualifications to warrant continued use.

 

Post Closure Care Requirements (40 CFR 257.104)

Post-closure care for CCR disposal units must be conducted for at least 30 years, which includes repairs to the final cover and erosion, run-on and run-off prevention, groundwater monitoring and corrective action.


 

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