By Andrew Aho
In May, the EPA announced that it plans to regulate coal-ash containment sites by requiring that all sites are fitted with liners (geomembranes and geosynthetic clay liners).
As you know, GMA has been advocating for such regulations through our government relations program. We successfully lobbied Members of Congress to send a letter to the EPA with the recommendation to mandate lining of coal-ash sites and we have been assisting in the development of legislation that would require geosynthetic lining of these sites.
When adopted, these regulations will have a tremendous impact on the geosynthetic materials market in the U.S. The proposed rules will apply to all new and all existing sites. Geomembranes and GCLs will be used as liners. Geotextiles and geogrids will be used in access roads and levee reinforcement for these sites.
We estimate that this work will result in $350 million in revenue for the geosynthetic industry during the next five to seven years. That is a conservative estimate and is predicated on which regulations the EPA adopts.
This summer the EPA sought comments on two options for regulating coal combustion residuals. The first is to regulate coal combustion residuals (CCR) under Subtitle C of the Resource Conservation and Recovery Act (RCRA). This option would regulate coal ash as hazardous waste. Even though this regulation would require double-liner systems, GMA has consistently held the position that coal ash should not be considered hazardous waste.
The second option would regulate CCRs under Subtitle D of RCRA. Under this option coal ash would be regulated as solid waste (just as municipal garbage is currently regulated).
For years the geosynthetic liner industry has recognized the inadequacies of coal-ash containment sites. The regulations have basically been left to states. It is evident by a survey of the sites conducted by EPA that that method was sorely lacking. The survey revealed that some sites were not designed by certified engineers and others did not have engineers monitoring the construction QA/QC.
Of course, the triggering event that brought this issue to the fore was the December 2008 failure of the TVA coal-ash surface impoundment retaining wall in Kingston, Tenn. The option that the EPA adopts will address the issue of structural and safety integrity of the coal-ash surface impoundments to prevent failures such as the Kingston disaster.
GMA assembled a task group of experts from the liner industry to review the EPA’s proposed options and rules, with the goal of preparing commentary verbiage submitted by GMA as an industry participant. That group was chaired by Boyd Ramsey of GSE Lining Technologies.
This summer Boyd said, “GMA has worked hard and effectively and has positioned the geosynthetic industry well on this issue. All participants understand the need for lining systems and GMA will continue to promote proper regulations and usage of the correct materials to protect the environment with the best materials and civil engineering practices available.”