Coal Combustion Residual (CCR) Compliance
MKAA has extensive experience in performing the compliance inspections of Coal Fired Power Plants landfills and impoundments as well as the ancillary associated tasks. Provided below is a summary of CCR compliance requirements. MKAA can readily address each of these CCR compliance obligations.
● Inspections –Under 40 CFR 257.83, all CCR- 1) Seven (7) Day Inspections - CCR surface impoundments and landfills must be inspected within a Seven (7) Contiguous Days by a qualified person for any actual or potential structural weakness or other conditions that may interrupt operation or safety. Results of the inspection by the qualified person will be posted in the facility operating record. 2) Monthly inspections - Each inspection will address the required CCR criteria of impoundments and landfills as well as monitoring all instrumentation supporting the operation of CCR unit to be conducted by a qualified person no less than once per month (Seven day and Monthly inspections implemented no later than April 8, 2017),
● Operating Criteria- Annual Inspection of Impoundments – Each inspection must be conducted by a qualified professional engineer. These inspections are focused mainly on structural stability of the unit. (Implementation no later than July 19, 2017).
● Groundwater Monitoring and Corrective Action – Deadline to Install the Groundwater Monitoring System and Begin Monitoring – Owners and operators of inactive CCR surface impoundments and landfills must meet 40 CFR 257.100 with implementation of groundwater monitoring system no later than April 17, 2019.
● Groundwater Monitoring and Corrective Action – Deadline to Prepare an Initial Groundwater Monitoring and Correction Action Report - Owners and operators of inactive CCR surface impoundments and landfills must meet 40 CFR 257.100. Required to prepare an annual groundwater monitoring and corrective action report. (Implementation no later than August 1, 2019).
● Detection Monitoring Program (DMP) – Deadline for Analyses of Eight Independent Samples. Owners and operators of inactive CCR surface impoundments and landfills subject to provisions of 40 CFR 257.100. The DMP sample collection requirements as in Groundwater Monitoring and Correction Action. (Implementation no later than April 17, 2019).
● Closure/ Post Closure Care – Deadline to Prepare a Written Closure Plan – The written closure plan describes the steps necessary to close a CCR unit at any point during the active life of the unit. The plan will provide narrative description of the closure process- left in place, clean closure. (Implemented by April 17, 2018).
● Closure/ Post-Closure Care – Deadline to Prepare a Written Post-Closure Care Plan – Owner/ Operator prepare a post-closure plan. Description of monitoring and maintenance activities as required by 40 CFR 257.100. (Implementation no later than April 17, 2018).
● Recordkeeping, Notification and Public Accessible Internet Site Requirements – The CCR rule requires the owner/ operator of a CCR unit to be subject to recordkeeping for publicly accessible internet reporting. Each file must be maintained in the operating record for five (5) years.
● NOTE- Text developed from: Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals From Electric Utilities; Extension of Compliance Deadlines for Certain Inactive Surface Impoundments; Response to Partial Vacatur. A Rule by the Environmental Protection Agency on 08/05/2016