ABSTRACT: The U.S. Environmental Protection Agency published 40 CFR 257, Subpart D, the Coal Combustion Residuals (CCR) Rule on April 17, 2015. This Rule includes provisions for groundwater monitoring of active, inactive, and new CCR landfills and impoundments. Various deadlines are set for the establishment of a groundwater monitoring system, the sampling and analysis of groundwater, and the statistical evaluation of groundwater data.

The CCR Rule created three phases of groundwater monitoring that include Detection Monitoring, Assessment Monitoring, and Corrective Action Monitoring. Groundwater protection standards will need to be developed based upon maximum contaminant levels (MCLs) or background levels. Criteria that trigger these phases of monitoring include a statistically significant increase (SSI) and a statistically significant level (SSL). If SSLs are determined in Assessment Monitoring, then the nature and extent of a release must be determined and a corrective action remedy developed. Reporting requirements that need to be a part of the operating record and/or posted to the public internet site are established.

This presentation will provide an overview of upcoming CCR Rule requirements and corresponding deadlines. In addition, selected case studies of current CCR monitoring system designs including single units and multi-units with interconnected hydraulic water-bearing units, sampling and analysis programs, and data quality management challenges will be described.

Kathy Webb, P.G.

Senior Market Leader | Principal

Kathy Webb, who co-founded SynTerra (then known as The Fletcher Group) in 1992, has completed remedial investigations and regulatory compliance projects associated with Resource Conservation and Recovery Act (RCRA) facilities, state and federal Superfund sites, solid waste landfills, brownfield redevelopment, utility coal combustion residual (CCR) management units, and regulated industrial facilities. She has supported litigation as an expert witness related to chlorinated solvents, metals, and polychlorinated biphenyls (PCBs).

Kathy is known for her practical assessment strategy with the perspective of the client’s business objectives. She routinely evaluates groundwater corrective action systems for effectiveness and progress toward achieving compliance objectives. She has co-authored a trade journal paper with case studies of low-impact remedial strategies. Kathy is a licensed Professional Geologist in North Carolina and South Carolina.

Mark Taylor, P.G.

Principal

Mark has worked more than 40 years in natural-resource based industries. His expertise includes mine geology and mine engineering, hydrogeologic and geotechnical investigations, solid and hazardous waste management, and regulatory negotiations. He has published peer-reviewed papers about coal geology, ore geochemistry, mineralogy, and solid waste management. He is a leading expert in mining and environmental permitting for litigation support.

Mark is licensed as a Professional Geologist in South Carolina, Alabama, Arkansas, Georgia, Kentucky, Mississippi, North Carolina, and Washington. He serves on the boards of the Upstate Red Cross and Upstate Forever. He served on the South Carolina Board of Registration for Geologists for six years. Mark holds a Master’s degree in Geological Sciences from The University of Michigan and a Bachelor’s degree in Geological Science from Harvard University.

Andrea Kehn, P.E.

Vice President of Engineering | Principal

Andrea Kehn, leader of our Civil & Environmental Engineering Business Unit, has 28 years of experience in chemical manufacturing and environmental consulting. She leads and supervises staff professionals on multidisciplinary projects for a variety of industrial clients. Andrea’s vast experience and expertise includes: air quality construction and operating permitting; air quality modeling; air permit record-keeping and reporting; Oil Spill Prevention Control and Countermeasures (SPCC) and Storm Water Pollution Prevention Plans (SWPPP); NPDES permitting; water quality modeling; process safety management; risk management compliance and auditing; and RCRA compliance.

Andrea is registered as a Professional Engineer in South Carolina. She holds a Bachelor of Science degree in Chemical Engineering from Michigan Technological University.

Ruth Albright, P.E.

Vice President | Principal

Ruth has led projects for major industrial facilities throughout the Southeast and beyond. She built her knowledge of environmental regulations and their application to manufacturing operations while working for the second largest chemical manufacturing company in the United States. At SynTerra, she has expanded both her knowledge and reputation working for chemical manufacturing operations of all sizes. She has also worked extensively with other manufacturing operations, including pulp and paper, industrial equipment, pharmaceuticals, food, and automotive parts and assembly. Her experience includes air and wastewater permit compliance, solid and hazardous waste management, solid waste construction permitting, hazardous materials transportation, wastewater treatment systems, air pollution control equipment operations and maintenance, and ambient air monitoring systems.

Ruth is a professional engineer registered in South Carolina, North Carolina, Georgia, Florida, Virginia, Mississippi, Oklahoma, Michigan, Arkansas, and Kentucky. She is an active member of the South Carolina Chamber of Commerce Environmental Technical Committee and serves as the chair of the water subcommittee. She has previously served as the program and committee chair for the Greater Greenville Chamber of Commerce Environmental Affairs committee. She has a Bachelor’s degree in Chemical Engineering from Clemson University.

Groundwater Monitoring in the CCR Rule – What’s Next?