c/EPA

Office of Resource Conservation and Recovery

EPA-530-F-23-001
June 2023

Fact Sheet: Legacy Coal Combustion
Residuals (CCR) Surface Impoundments and
CCR Management Units Proposed Rule

The United States Environmental Protection Agency (EPA) issued a proposed rule that would require the safe
management of coal ash dumped in areas that are currently unregulated at the federal level. This includes inactive
power plants with surface impoundments that are no longer being used and historical coal ash disposal areas at
power plants with regulated coal ash units. This proposal applies to historical contamination and inactive units that
no longer support current power plant operations.

What Does the May 2023
Proposal Do?

On May 18, 2023, EPA proposed to amend the
rules governing the disposal of CCR in landfills
and surface impoundments. EPA proposed
regulatory requirements for inactive surface
impoundments at inactive facilities (referred to
as "legacy CCR surface impoundments"). This
proposal responds to the 2018 U.S. Court of
Appeals for the District of Columbia Circuit
ruling that vacated the exemption for legacy
CCR surface impoundments from the CCR
regulations.

Why is the Legacy CCR Surface
Impoundment Proposal Important?

Coal ash is a byproduct of burning coal in power
plants that, without proper management, can
pollute waterways, groundwater, drinking
water, and the air. Coal ash contains
contaminants like mercury, cadmium,
chromium, and arsenic associated with cancer
and various other serious health effects. Many
facilities stored coal ash in surface
impoundments, which have the potential to
leak or to fail, sending coal ash and its

contaminants into water sources, including
surface water and groundwater.

On April 17, 2015, the EPA promulgated
national minimum criteria for existing and new
CCR landfills and existing and new CCR surface
impoundments. This final rule did not impose
any requirements on inactive facilities. On
August 21, 2018, the U.S. Court of Appeals for
the District of Columbia Circuit vacated the
exemption for inactive surface impoundments
at inactive facilities and remanded the issue
back to EPA to take action consistent with the
opinion in "Utility Solid Waste Activities Group,
etal. v. EPA."

Legacy CCR surface impoundments are more
likely to be unlined and unmonitored, making
them more prone to leaks and structural
problems than units at facilities that are
currently in service. These units are currently
not regulated at the federal level and could
adversely impact groundwater. To address
these concerns, EPA proposed safeguards for
legacy CCR surface impoundments that largely
mirror those for inactive impoundments at
active facilities, including requiring the proper


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closure of the impoundments and remediating
CCR-contaminated groundwater.

CCR Management Units Proposal

In addition, through implementation of the
2015 CCR rule, EPA found that power plants
with regulated impoundments had also
disposed of coal ash in areas outside of
regulated units, and that many utilities had
identified these areas as the source of detected
groundwater contamination. These areas,
referred to as "CCR management units," include
coal ash in surface impoundments and landfills
that closed prior to the effective date of the
2015 CCR Rule, inactive CCR landfills, and other
areas where coal ash is placed directly on the
land. EPA also proposed to establish
groundwater monitoring, corrective action,
closure, and post closure care requirements for
these areas.

Applicability Documentation

EPA proposed that for both legacy CCR surface
impoundments and CCR management units,
facilities would first need to write reports with
information to identify the units, delineate the
boundaries of the units, include figures of the
facilities and where the units are located, and
the sizes of the unit. The facilities would then
post these reports on their websites for the
public to access.

Compliance Deadlines

This rule would become effective six months
after publication of the final rule in the Federal
Register. No facility would be required to meet
any of the new requirements before that six-
month date.

The proposed compliance deadlines would
allow additional time beyond the effective date
for facilities to comply with certain technical
criteria based on the amount of time EPA
projects that facilities would need to complete
them (e.g., installing the groundwater

monitoring system, developing the
groundwater sampling and analysis program).

Power Sector Engagement and
Outreach

Power plants no longer use the areas that are
the subject of this proposal to support their
current operations (i.e., they no longer need to
place additional coal ash in these units).
However, EPA will continue to work with power
facilities and grid operators to address any
reliability concerns.

Public Comment

EPA will collect public comments on this
proposal through July 17, 2023. EPA will host an
in-person hearing in Chicago, Illinois on June 28,
2023. Additionally, EPA will host an online
public hearing on July 12, 2023.

Where Can I Find More
Information?

1.	Read about the proposed rule and the
public hearings on our proposal
webpage:

https://www.epa.gov/coalash/propose
d-changes-legacv-coal-combustion-
residuals-surface-impoundments-and-
ccr-management.

2.	Learn about coal ash:
www.epa.gov/coalash.

3.	For information about how to submit
comments, contact Michelle Lloyd by
email at lloyd.michelle@epa.gov or by
telephone at (202) 566-0560.

4.	For press inquiries, contact:
press@epa.gov.


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