Coal Combustion Residual (CCR) Groundwater Compliance Services

TRC supported the implementation of the CCR Rule as it pertains to the client’s groundwater monitoring programs. 




Project Location


The client operates three facilities with CCR units in the Southeast U.S. The power plants use landfills to manage CCR. The CCR units are regulated under the Federal CCR Rule, and are required to perform groundwater monitoring in accordance with the Rule. The client’s objectives were to:

  • Collect groundwater samples from 62 monitoring wells representative of baseline groundwater quality.
  • Manage and evaluate baseline groundwater sampling data in accordance with 40 CFR 257.93.
  • Initiate detection monitoring programs in accordance with 40 CFR 257.94.
  • Investigate data as part of preliminary alternate source determinations (ASDs) that may result in statistically significant increases (SSI), and determine if the SSI may be from a source other than the CCR unit.
  • Develop and submit the initial annual groundwater monitoring and corrective action reports in accordance with 40 CFR 257.90(e).


TRC developed site conceptual models (including 3D geologic models) for each of the three CCR units in support of the groundwater monitoring networks installed for sample collection under the CCR Rule. TRC is providing peer review of all CCR documents including the Groundwater Sampling and Analysis Plans and the Statistical Analysis Plans developed for the program under the CCR Rule.

TRC has consulted on multiple aspects of the baseline monitoring program from sample collection methods for accuracy of results to review of statistical methods and results. 

TRC is providing guidance for determination of ASDs at two of the three facilities where preliminary results indicate the potential for statistically significant increases (SSIs) to arise during detection monitoring.  Activities include geochemical fingerprint analyses and an evaluation of the potential use of isotopic tracers.

All three CCR units are regulated under state programs where TRC is providing additional support. One facility was operating under the state assessment monitoring program and with additional data generated during the CCR implementation phase, a demonstration was made to the state agency that supported its return to detection monitoring.

TRC will continue support of the CCR units for both the CCR Rule and state programs moving forward into 2018.

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Coal Ash Management

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