Strategic Decision Making for CCRMU Closure - A Framework for Evaluating Closure In-Place vs. Removal Options

Utility companies face complex decisions under the USEPA’s Legacy CCR Rule, which requires identifying and closing Coal Combustion Residual Management Units (CCRMUs). The rule allows two closure pathways, closure by removal or closure in place, each with distinct regulatory and technical challenges. While closure in place is often more cost-effective, it must meet stringent liquid management performance standards, including eliminating liquids before closure and controlling post-closure infiltration and leachate release. These requirements can prohibit closure in place feasibility. However, effective engineering controls offer potential solutions making closure in place viable. This presentation introduces a structured decision-making framework that helps utilities evaluate closure options and integrate engineering controls to manage liquids. The framework combines regulatory review, technology assessment, and practical tools such as developing options and conceptual-level designs with life-cycle cost analysis, schedule comparison, and semi-quantitative scoring. Attendees will learn a stepwise approach for developing closure options, understanding and applying engineering controls, defining evaluation criteria, comparing alternatives, and developing defensible closure strategies. By applying this method, utilities can move from identifying viable options to making robust, well-supported decisions that balance compliance, cost, and long-term performance.