CCR Rule Compliance Assessment at Three Coal-Fired Power Plants
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Our electricity-generating client retained Geosyntec to conduct compliance assessments at three coal-fired power plants for eight coal combustion residual (CCR) units to identify whether the units met the federal CCR rule for location restrictions and groundwater monitoring systems.

Each plant had a bottom ash pond complex and a fly ash pond and two of them had CCR landfills. The objectives of the project were twofold. The first was to understand whether the CCR units comply with the location restrictions and whether CCR unit modifications made prior to the regulatory due date were sufficient or if they needed to make plans to close the CCR units. The second was to identify whether the groundwater monitoring systems were compliant with the performance standard and whether they needed to implement modifications in time to obtain sufficient samples to establish background groundwater quality conditions and conduct the appropriate statistical evaluations prior to the regulatory due date.

Geosyntec's Scope of Services

Geosyntec worked with the client and several other consultants to design and provide consistent compliance assessments and develop a standard compliance report format for 10 power plants. We completed the assessments of three plants under a rigorous schedule and included a review and evaluation of the geologic and hydrogeologic conditions; the number, spacing, and depths of the monitoring wells within each groundwater monitoring system; and existing state-approved groundwater monitoring programs (if applicable) at each CCR unit. The location restrictions included assessing the separation distance from the uppermost aquifer, wetlands, distance to fault areas, seismic impact zones, and unstable areas. Draft compliance assessment reports were issued and discussed with the client who used the information to begin the planning stages for continued operation of the CCR units, including making modifications or preparations to close the units.

The compliance assessments identified that the groundwater monitoring systems at all three plants had groundwater monitoring wells that were not in full compliance with the CCR rule. All three plants required the installation of additional groundwater monitoring wells within the uppermost aquifer to accurately represent the upgradient and downgradient groundwater quality for the specified CCR units. Geosyntec completed the installation of new monitoring wells at each plant on an expedited schedule allowing time to obtain the appropriate number of groundwater samples to establish background water quality conditions and to conduct a statistical evaluation of the groundwater quality data prior to the regulatory due date.

In addition, location restriction evaluation reports were certified in time to meet the regulatory due date.

Notable Accomplishments

Geosyntec completed the compliance assessments and modified the groundwater monitoring systems within the rigorous schedule and applicable regulatory due dates' deadlines. The work allowed all but one unit to continue operating, which had been expected by the client.

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Project Summary

  • Location: Southern Ohio and Kentucky
  • Client: Confidential Electric Generating Company
  • Project Practice Areas: Waste Management, Environmental Management
  • Type of Facility: Coal plants
  • Services Provided: Assessment of groundwater monitoring system for compliance, Installation of groundwater monitoring wells, Assessment of location restriction standards, Certification reports by qualified professional engineer
  • Type of Work: Coal ash pond compliance assessment
  • Governing Regulation: Federal regulations