Document Type

Article

Abstract

On 19 October 2015, the Disposal of Coal Combustion Residuals (CCRs) for Electric Utilities final rule (CCR Rule), issued by the U.S. Environmental Protection Agency (US EPA) under Subtitle D of the Recovery and Conservation Act (RCRA), became effective. The Groundwater Monitoring and Corrective Action subsections of the CCR Rule (40 CFR §§ 257.90–257.98) set out strict requirements for groundwater monitoring at the detection and assessment levels, followed by (if necessary) groundwater characterization in support of corrective measures assessment. Since the federal CCR Rule was implemented, the US EPA has proposed and finalized some amendments, and some states have proposed programs to implement parts or all of the federal CCR Rule, including requirements for groundwater monitoring, assessment, and corrective measures. This article was prepared to highlight the value that can be added to the process from judicious application of the conceptual site model (CSM) approach in progressing through the steps required by the CCR Rule. This article introduces the CSM as a practical, industry-focused project planning tool that can inform project managers, scientists, and engineers on how to collect the right type, quantity, and quality of data, and to leverage statistical, geostatistical, and numerical methods to generate legally defensible information from these data. If implemented properly, the CSM can help assess key data gaps and uncertainty for installing a groundwater monitoring system; meet 90-day implementation periods set forth by the CCR Rule; conceptualize the nature and extent of impacted groundwater; assess cumulative risks, potential alternative sources, and remedies; evaluate the effectiveness of a chosen remedy; manage and handle ponded materials; and successfully communicate site-specific information to stakeholders and regulators.

First Page

1

Last Page

9

DOI

10.4177/CCGP-D-18-00012.1

Publication Date

1-1-2019

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