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Location

Lexington, Kentucky

Start Date

6-5-2026 11:30 AM

End Date

6-5-2026 12:00 PM

Description

Illinois Administrative Code Part 845 requires owners and operators of coal combustion residual (CCR)-containing impoundments with groundwater protection standard (GWPS) exceedances to perform a Corrective Action Alternatives Analysis (CAAA) to evaluate viable remedies prior to selecting and implementing corrective action. The goal of a CAAA is to holistically evaluate a range of factors for the various corrective actions being considered at an impoundment. This presentation summarizes two CAAAs conducted for surface impoundments (SIs) at two power plants. Each CAAA applied a consistent decision framework that evaluates corrective action options using multiple performance criteria, such as: • Magnitude of Reduction of Existing Risks; • Effectiveness of the Remedy in Controlling the Source; • Short-Term Risks to the Community or the Environment During Implementation of Remedy; • Time To Achieve Groundwater Protection Standards; • Long-Term Reliability of the Engineering and Institutional Controls; • Potential Need for Replacement of the Remedy; • The Ease or Difficulty of Implementing a Remedy; • The Degree to Which Community Concerns Are Addressed by the Remedy; and • Disturbance to sensitive ecosystems. A CAAA is a decision-making tool that is designed to aid in the selection of a corrective action alternative. For the two example SIs, multiple corrective action alternatives were evaluated. . At Site 1, the evaluated alternatives included Source Control with Groundwater Polishing (Source Control-GWP), Source Control with Groundwater Extraction (Source Control-GWE), and Source Control with Phytoremediation (Source Control-Phytoremediation). At Site 2, the evaluated alternatives included Source Control-GWP and Source Control with a Groundwater Extraction Trench (Source Control-GWET). The analysis was a scientifically-defensible approach that resulted in the selection of the most appropriate corrective action alternative at each site.

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Presentation

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May 6th, 11:30 AM May 6th, 12:00 PM

Corrective Action Alternative Evaluation for Surface Impoundment Remedy – Two Case Study Examples

Lexington, Kentucky

Illinois Administrative Code Part 845 requires owners and operators of coal combustion residual (CCR)-containing impoundments with groundwater protection standard (GWPS) exceedances to perform a Corrective Action Alternatives Analysis (CAAA) to evaluate viable remedies prior to selecting and implementing corrective action. The goal of a CAAA is to holistically evaluate a range of factors for the various corrective actions being considered at an impoundment. This presentation summarizes two CAAAs conducted for surface impoundments (SIs) at two power plants. Each CAAA applied a consistent decision framework that evaluates corrective action options using multiple performance criteria, such as: • Magnitude of Reduction of Existing Risks; • Effectiveness of the Remedy in Controlling the Source; • Short-Term Risks to the Community or the Environment During Implementation of Remedy; • Time To Achieve Groundwater Protection Standards; • Long-Term Reliability of the Engineering and Institutional Controls; • Potential Need for Replacement of the Remedy; • The Ease or Difficulty of Implementing a Remedy; • The Degree to Which Community Concerns Are Addressed by the Remedy; and • Disturbance to sensitive ecosystems. A CAAA is a decision-making tool that is designed to aid in the selection of a corrective action alternative. For the two example SIs, multiple corrective action alternatives were evaluated. . At Site 1, the evaluated alternatives included Source Control with Groundwater Polishing (Source Control-GWP), Source Control with Groundwater Extraction (Source Control-GWE), and Source Control with Phytoremediation (Source Control-Phytoremediation). At Site 2, the evaluated alternatives included Source Control-GWP and Source Control with a Groundwater Extraction Trench (Source Control-GWET). The analysis was a scientifically-defensible approach that resulted in the selection of the most appropriate corrective action alternative at each site.