When the Federal CCR rule went into effect in 2015, it was a new regulatory layer on top of a widely varying landscape of state regulations affecting CCR management in impoundments and landfills. Some states already had significant regulations on the books for CCR impoundments and/or landfills, while others did not. Where state regulations existed, they varied widely from state to state. While a few states have moved toward closing the gap between state and federal CCR requirements, many utilities continue to face confusing and conflicting requirements coming from different regulatory programs as they move ahead with managing their CCR facilities.
Through case studies, SCS Engineers will share state-versus-federal regulatory challenges utilities have encountered in different regions of the country during landfill design and management, impoundment closure, and groundwater monitoring and reporting since the implementation of the Federal CCR Rule. For example, some sites have completely distinct groundwater monitoring programs under state versus federal rules, with different well locations, well depths, and monitoring parameters for the same facility. We will highlight unique approaches to bridging regulatory gaps and resolving regulatory conflicts between state and Federal CCR requirements.
SCS will also share insights gained on the long-term potential for regulatory resolution of these issues based on discussions with state regulators in multiple states.