adem.alabama.gov adem land division update chip crockett chief, industrial hazardous waste branch...
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adem.alabama.gov
ADEM Land Division Update
ADEM Land Division Update
Chip CrockettChief, Industrial Hazardous Waste Branch
Air & Waste Management Association
Southern SectionPine Mountain, Georgia
August 21, 2015
adem.alabama.gov
Land Division OrganizationLand Division Organization
• Phil Davis, Chief – Land Division Ron Shell, Chief – Environmental Services Branch
• 334-271-7771 – [email protected] Sonja Massey, Chief – Groundwater Branch
• 334-271-7832 – [email protected] Chip Crockett, Chief – Industrial Haz Waste Branch
• 334-271-5627 – [email protected] Steve Cobb, Chief – Governmental Haz Waste Branch
• 334-271-7739 – [email protected] Eric Sanderson, Chief – Solid Waste Branch
• 334-271-7755 – [email protected]
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National Emerging IssuesNational Emerging Issues
• Coal Combustion Residuals
• UST Regulations
• Definition of Solid Waste
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Federal Coal Combustion Residual Rules
Federal Coal Combustion Residual Rules
• 6/21/2010 - Draft RCRA Coal Combustion Residual (CCR) Rule Published in Federal
• 12/19/14 - Final RCRA CCR Rule signed by EPA
• 4/17/15 - Published in Federal Register
• Establishes minimum criteria for the safe disposal of CCR’s generated from electric utilities or independent power producers.
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Federal Coal Combustion Residual Rules (cont)
Federal Coal Combustion Residual Rules (cont)
Key Take Aways: MSW Landfills not subject States not required to adopt rules; program is self-implementing Technical requirements substantially mirror RCRA Subtitle D Siting Restrictions for new and existing CCR disposal units Groundwater monitoring for new and existing units Composite or alternative liner design required for new CCR
disposal units Structural integrity requirements Fugitive Dust Control and Closure/Post Closure Plans Facility website is required to be maintained to allow review of
documentation required by the rule EPA has no administrative enforcement authority
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Federal Coal Combustion Residual Rules (cont)
Federal Coal Combustion Residual Rules (cont)
Path Forward: Currently assessing the impacts/needs to the existing State solid
waste program to implement the federal rule Continue to meet with interested Stakeholders Expect to mirror the rule into state regulations and develop permit
program for CCR units which are active and/or in Post Closure Federal legislation currently under consideration in the House of
Representatives
EPA CCR Website: • http://www2.epa.gov/coalash/coal-ash-rule • Final Rule• Frequently Asked Questions
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Definition of Solid WasteDefinition of Solid Waste
• Procedures of Solid Waste Variances (required)
• Speculative Accumulation (required)• Legitimacy Criteria (required)• Exclusions (optional)
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Legitimacy CriteriaLegitimacy Criteria
• Prohibits Sham Recycling• Adds “Hazardous Secondary Materials” (HSMs)• Legitimacy Criteria
HSM must provide a useful contribution to the recycling process
Recycling process must produce a viable product HSM has to be managed like a commodity Recycled product must be comparable to a legit
product
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ExclusionsExclusions
• Remanufacturing of 18 High-Value Solvents
• Generator-controlled Reclamation Does not necessarily have to be reclaimed at
the generating facility• Reclamation by a Verified Recycler
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DSW Take-AwaysDSW Take-Aways
• Alabama plans to adopt the entire DSW rule, for now. Timing – Public notice of proposed rules in
October 2015• DSW rule changes little about recycling in
Alabama that does not involve reclamation.
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Federal UST RegulationsFederal UST Regulations
• Signed June 19, 2015• Effective 90 days after publication in the
Federal Register (pending)• Codify statutory changes made in the
2005 Energy Policy Act Most states, including Alabama, have already
implemented• Impose new tank inspection requirements
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Requirements Already Implemented in AlabamaRequirements Already
Implemented in Alabama
• Operator Training• Secondary Containment• Spill Basin Testing Every Three Years• Release Detection for Emergency Generators• Internally Lined USTs Must Permanently Close if
they Fail Internal Inspections ADEM allowed addition of cathodic protection before
January 16, 2013
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New Routine Inspection Requirements
New Routine Inspection Requirements
• Monthly Inspections Spill Prevention Equipment Release Detection Equipment
• Annual Inspections Containment Sumps Hand-held Release Detection Equipment
• Triennial Inspections & Testing Overfill Prevention Equipment Containment Sumps used for Interstitial Monitoring Release Detection Equipment, including Line Leak
Detectors
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adem.alabama.gov
Additional RequirementsAdditional Requirements
• Eliminated Vent Flow Restrictors as Overfill Prevention Option for New USTs
• Compatibility Notification if > 10% ethanol or 20% biodiesel Demonstrate Compatibility Record Keeping
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Next StepsNext Steps
• Final Rule published July 15, 2015• States have 3 years to adopt regulations and
request program re-authorization from EPA• ADEM is currently reviewing regulations and
will likely move forward with rulemaking later this year
• ADEM plans to conduct outreach efforts to owners and other interested parties later this year.
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Contact InformationContact Information
• CCREric Sanderson, Chief
Solid Waste Branch
(334) 271-7755
• Hazardous Waste / DSWChip Crockett, Chief
Industrial Hazardous Waste Branch
(334) 270-5627
• USTLee Davis, Chief
UST Compliance Section
(334) 271-7759