TEXTILES.ORG
September 29, 2010
Mr. Steven Souders
Office of Resource Conservation and Recovery
United States Environmental Protection Agency
5304P
Washington, DC 20460
40 CFR Parts 257, 261, 264 et al.
Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule Docket ID No. EPA-HQ-RCRA-2009-0640
Additional information on Environmental Protection and Structural Integrity with Geosynthetic Systems
Introduction
In response to the recent publication of the Notice of Proposed Rule Making Hazardous and Solid Waste Management System; Identification and Listing of Special Wastes; Disposal of Coal Combustion Residuals From Electric Utilities; Proposed Rule, related to the care, separation and storage of coal combustion residuals (CCRs) GMA offers the following additional comments and information (including attached appendices):
GMA again compliments the EPA for the statements and inclination to require geosynthetic lined facilities designed to protect the groundwater from potential contamination. GMA again recommends that the regulations put forth require the use of a composite liner system (geomembrane and geosynthetic clay liner) as this system has been demonstrated (by EPA) to be the most effective barrier methodology, regardless of the classification of the materials (hazardous, non-hazardous or designated for beneficial re-use). This submittal supplements the previous GMA submission dated August 12, 2010 and contains additional references to EPA reports and studies as well as test data generated, using EPA protocols that support the effectiveness of composite liner systems and their components.
Statement of EPA request(s)
In 75 FR 35202, EPA solicits comment on whether the Subtitle D (i.e., municipal solid waste) option should allow facilities to use an alternative design for new disposal units, so long as the owner or operator demonstrates that CCR constituent concentrations are not exceeded at the relevant point of compliance. Additionally, in 75 FR 35203, EPA states interest in receiving data and information that demonstrates whether an alternative liner would be equally protective. Similarly, in 75 FR 35175 and 75 FR 35222, EPA solicits comment with supporting information and data on whether the Subtitle C option should also provide for alternative liner designs based on a specific performance standard. The prescriptive liner system under Subtitle D (40 CFR Part 258) is a composite liner with two components: an upper component consisting of a minimum 30-mil flexible membrane liner (FML, also commonly called a geomembrane), and a lower component consisting of at least a two-foot layer of compacted soil with a hydraulic conductivity of no more than 1 x 10-7 cm/sec. Although the existing Part 40 CFR Part 258.40(a)(1) requirements allow for alternative liner demonstrations, EPA expresses reluctance in allowing alternative liners for new CCR facilities in 75 FR 35203.
Respondent comments
GMA would like to ensure that EPA is aware of all pertinent information related to the effective use of geosynthetic materials for waste containment The Geosynthetic Institute (Drs. Robert and George Koerner, Folsom, PA) website contains an index of the U.S. EPA documents that are related to the use of geosynthetics. The complete list is attached as Appendix “C” a link to the webpage is here: www.geosynthetic-institute.org/epa.html. Clearly, geosynthetic materials have been well examined and proven to be effective.
In 75 FR 35202, EPA solicits comment on whether the Subtitle D (i.e., municipal solid waste) option should allow facilities to use an alternative design for new disposal units, so long as the owner or operator demonstrates that CCR constituent concentrations are not exceeded at the relevant point of compliance. Additionally, in 75 FR 35203, EPA states interest in receiving data and information that demonstrates whether an alternative liner would be equally protective. Similarly, in 75 FR 35175 and 75 FR 35222, EPA solicits comment with supporting information and data on whether the Subtitle C option should also provide for alternative liner designs based on a specific performance standard. GMA would like to state our concurrence with the opinions and information previously supplied to the EPA docket by CETCO Lining Technologies. In the interest of brevity, GMA does not re-supply the technical reference materials listed in that document. However, based on the technical information presented therein, GMA recommends that the USEPA CCR Disposal Proposed Rule for either the proposed Subtitle C and Subtitle D Regulation option be revised to define a ‘composite liner’ as consisting of two components: An upper component consisting of a minimum 30-mil flexible membrane liner (FML), and a lower component consisting of either at least a two-foot layer of compacted soil with a hydraulic conductivity of no more than 1 x 10-7 cm/s, or a geosynthetic clay liner (GCL) containing at least 0.75 lb/ft2 of sodium bentonite. If ‘composite liner’ is not redefined to include a lower component GCL, then the allowance of an alternative liner design/system should be included.
EPA 9090 testing is a historically important testing protocol that was developed to demonstrate the chemical resistance of geosynthetic materials. EPA document EPA/600/S2-90/041 (Appendix “D”) outlines the application of this testing protocol. Appendices “E, F, G, H and I” demonstrate the excellent performance of specific geosynthetic materials.
Conclusion
The benefits and successes of utilizing geosynthetic barriers in containment systems has been well documented by the technical materials supplied by GMA previously and further referenced here. Geosynthetics have been tested and successfully evaluated in great detail over a long period of use in a very wide range of applications by EPA.
GMA recommends that the US EPA CCR Disposal Proposed Rule for either of the Subtitle C and/or Subtitle D Regulation options define and require a ‘composite liner’ consisting of two components: An upper component consisting of a minimum 30-mil flexible membrane liner (FML), and a lower component consisting of a geosynthetic clay liner containing at least 0.75 lb/ft2 of sodium bentonite. If ‘composite liner’ is not redefined to include a lower component GCL, then the allowance of an alternative liner design/system should be included.
GMA thanks EPA for the consideration provided. GMA, the respective member companies and their staffs are more than willing to respond to any additional EPA inquiry on this or other related topics.
Sincerely,
Andrew M. Aho
Managing Director
Geosynthetic Materials Association
Industrial Fabrics Association International
1801 County Road B West
Roseville, MN 55113-4061
John Henderson
Chairman: Executive Council
Geosynthetic Materials Association
TenCate Geosynthetics N. A.
365 South Holland Drive
Pendergrass, GA 30567
Instruction to access the full GMA comments and attachments
- Go to www.regulations.gov
- Type “geosynthetic materials association” in the Enter Keyword or ID field
- Click on the first search result ID: EPA-HQ-RCA-2009-0640-4033 ; Comment submitted by Andrew M. Aho, Managing Director and John Henderson, Chairman, Executive Council, Geosynthetic Materials Association (GMA)
- Click on primary letter to EPA and supporting documents (attachments)