1. PowerSouth Energy Cooperative:
CCR Rule
August 4, 2015

2. CCR Rule Signed by EPA Administrator December 19, 2014
Published in FR April 17, 2015
Effective date of the rule is 6 months after publication in the FR (October 19, 2015)

3. Facilities Affected By this Rule
New, Existing & Inactive CCR Impoundments
New and Existing CCR Landfills
Coal Combustion By-product Piles

4. 6 months Fugitive Dust Control Plan Weekly Impoundment Inspections
Monthly Instrumentation Monitoring
Recordkeeping, Notification, and Internet Reporting Requirements

5. 8 months
Install a permanent ID marker adjacent to each CCR Unit
Begin Annual Impoundment Inspections
9 months

6. 18 months
Document if the Impoundment is lined with a minimum 2 foot compacted clay liner meeting a hydraulic conductivity of 1x10-7
Prepare initial inflow design flood control system plan
Prepare a written closure plan
Prepare a written post-closure plan

7. 18 months Document the Initial Hazard Classification
Compile the History of Construction for each Impoundment
Conduct Structural Stability Analysis
Safety Factor Assessments!!!

8. 24 months
Prepare an Emergency Action Plan

9. 30 months Groundwater Monitoring and Corrective Action
Install GW monitoring system
Develop GW sampling and Analysis program
Initiate detection monitoring
Begin evaluating for SSI over background for Appendix III constituents

10. 42 months Complete Location Restriction Demonstration for:
Location above uppermost aquifer
Wetlands
Fault Areas
Seismic Impact Zones
Unstable Areas

11. Pressing Issues for PowerSouth
Closure of Ash Storage Area
Safety Factor Assessments for Ponds
Building for the Gypsum Pile??
Timing with the ELG Rule??

12. CCR/ELG Timeline LOWMAN ELG/CCR COMPLIANCE TIMELINE 2015 2016 2017
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025 1 2 3 4
ELG RULE & PERMIT SCHEDULE
FINAL RULE
ADEM BEGINS RENEWING PERMITS, LITIGATION,
NEW NPDES PERMIT CYCLE
w/ COMPLIANCE SCHEDULE FOR ELGs
w/ ELG COMPLIANCE
CCR RULE
COMPLIANCE SCHEDULE
EFFECT. DATE
GROUNDWATER DATA COLLECTED AND ANALYZED
5 YEAR ALTERNATIVE CLOSURE TIMEFRAME
(CEASE PLACEMENT OF CCR)
5 YEAR CLOSURE TIMEFRAME
(DEWATER AND CAP)
Still evaluating alternatives. CCR ponds no longer available.
LOWMAN ELG/CCR
COMPLIANCE TIMELINE