Paper: U.S. EPA’s Final CCR Rule Impact on Past, Current, and Future Disposal

What actions are required?


Coal Combustion Residuals (CCR) handling and disposal activities are rapidly changing in the electric power generating industry.  Although recycling, reusing, and repurposing all coal combustion by products is preferred, if some portion requires dewatering, treatment, and disposal, EPA’s Final CCR Rule (Rule), published on April 17, 2015, may financially impact your past, present, and future operations. That is the date the compliance clock started ticking. If the State in which your generating stations are located do not already have CCR regulations that meet EPA’s final rule and your disposal areas are currently in compliance, you’ll need to make decisions and prepare documentation for your former, existing, and ongoing ash impoundments and landfills.

Douglas J. Dahlberg, James T. Perry – Sargent & Lundy

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