The New Coal Combustion Residuals Rule – An Implementation and Enforcement Nightmare

Introduction

Almost five years after the proposal, EPA has issued its final rule regarding the disposal and beneficial use of coal combustion residuals (CCRs). The rule establishes federal standards for landfills and surface impoundments in which CCRs are disposed.

Importantly, though, the rule leaves the enforcement of those standards to citizens. This method of enforcement exposes owners and operators of CCR units to uncertain outcomes and litigation costs in a variety of different courts. Continue reading “The New Coal Combustion Residuals Rule – An Implementation and Enforcement Nightmare”