Coal Combustion Residuals Groundwater Compliance & Monitoring

The client operates seven CCR-regulated impoundments at two coal fired facilities in the Mid-Atlantic. Two of the units are also regulated under a state Solid Waste Permit and are therefore required to perform groundwater monitoring in accordance with federal and state requirements. The client’s objectives were to:

• Evaluate and develop a groundwater strategy for monitoring the units, including single or multi-unit monitoring programs.
• Install a groundwater monitoring system and collect groundwater samples representative of back-ground groundwater quality data to monitor the 7 CCR units.
• Manage and evaluate background groundwater sampling data in accordance with 40 CFR 257.93.
• Initiate a detection monitoring program in accordance with 40 CFR 257.94.
• Investigate data 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 accord-ance with 40 CFR 257.90(e).
• Address necessary monitoring and reporting under the state Solid Waste Permit.

TRC SOLUTIONS

TRC installed a groundwater monitoring well network and implemented a quality assurance project plan (QAPP) that included a sampling and analysis plan (SAP) for each of the facilities. 

During 2017, TRC has managed the federal and state groundwater monitoring programs, coordinating with subcontractors, and collecting background groundwater quality from monitoring wells around each of the seven CCR units. Additionally, TRC has been managing the data in EQUIS®, performing data QA/QC, and evaluating groundwater data trends. TRC also evaluated anomalous data during the background sampling program, identified potential alternate sources, and modified the groundwater sampling program to accurately characterize releases from the units.

For the federal CCR Rule, background data collection was completed by October 17, 2017, with the groundwater monitoring well networks and planned statistical evaluations being certified by a professional engineer. Using the background data, TRC is performing the statistical evaluation in accordance with the performance standards of the CCR rule for each CCR unit. Groundwater data (detection monitoring data) collected subsequent to October 1, 2017 is being evaluated to determine if an SSI is observed and will be reported within the initial annual groundwater monitoring reports that are due on January 31, 2018.

TRC is additionally providing necessary sampling and reporting in accordance with the facility’s Solid Waste Permit.