| Insights

Wait, How Many Trucks? Ash Pond Closure by Removal

Utilities around the country have developed preliminary closure plans for surface impoundments storing coal ash, gypsum, and other coal combustion residuals (CCR). Some ash ponds are already in the process of closing. To close, the utility must either remove the CCR and redispose of it elsewhere, or prepare the site and close and cap it in place.

In litigation and through the media, citizen groups have argued in favor of closure by removal, but either option is available under EPA’s regulations. Closure in place is allowed only if the utility can demonstrate satisfaction of environmental performance standards, and closure by removal allows for reduced long term regulatory obligations. In that sense, the regulations provide a bit of an incentive to close by removal.

 On the other hand, the regulations also recognize a benefit in closing as soon as reasonably possible. The longer the closure process takes, the more time ash is left unsecured and at risk of exposure to the elements.

 So how long should the closure process take? One data point is how long it would take to excavate the CCR and transport it for redisposal elsewhere. For larger CCR units, the task is daunting.

 To read more, visit JD Supra.