Archived
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Location
Lexington, Kentucky
Start Date
7-5-2026 10:30 AM
End Date
7-5-2026 11:00 AM
Description
The USEPA’s Legacy CCR Rule introduces new requirements for establishing groundwater monitoring systems at Legacy Surface Impoundments (LSIs) and Coal Combustion Residual Management Units (CCRMUs). These requirements present unique challenges for electric utilities, particularly at inactive or historically operated facilities where subsurface data are limited and CCR units may have nontraditional configurations such as linear roadways, elongated embankments, or distributed disposal areas. Utilities must also determine how best to apply single-unit or multi-unit monitoring approaches, integrate newly regulated units into existing monitoring networks, and align monitoring system design with planned closure strategies. This presentation outlines a systematic, defensible framework to support utilities as they evaluate groundwater monitoring options and implement systems that meet the technical and regulatory expectations of the Legacy CCR Rule. The approach incorporates defined evaluation criteria, including hydrogeologic characterization, unit geometry, monitoring objectives, regulatory compliance considerations, and long-term operational implications. Alternative monitoring system configurations are compared using a structured decision process that identifies practical, compliant, and cost-effective solutions tailored to individual CCR units or unit groupings. Drawing on lessons learned from designing and managing groundwater monitoring programs for active CCR units, the presentation highlights strategies to reduce uncertainty, streamline implementation, and enhance regulatory defensibility. The systematic approach provides utilities with a clear pathway for establishing optimized groundwater monitoring systems that support closure planning, strengthen compliance positions, and meet evolving federal regulatory requirements.
Document Type
Presentation
Archival?
Archival
Included in
Energy Systems Commons, Environmental Indicators and Impact Assessment Commons, Environmental Monitoring Commons, Mining Engineering Commons, Oil, Gas, and Energy Commons, Structural Materials Commons, Sustainability Commons
Establishing Groundwater Monitoring Systems Under the Legacy Rule: A Systematic Approach for Utilities
Lexington, Kentucky
The USEPA’s Legacy CCR Rule introduces new requirements for establishing groundwater monitoring systems at Legacy Surface Impoundments (LSIs) and Coal Combustion Residual Management Units (CCRMUs). These requirements present unique challenges for electric utilities, particularly at inactive or historically operated facilities where subsurface data are limited and CCR units may have nontraditional configurations such as linear roadways, elongated embankments, or distributed disposal areas. Utilities must also determine how best to apply single-unit or multi-unit monitoring approaches, integrate newly regulated units into existing monitoring networks, and align monitoring system design with planned closure strategies. This presentation outlines a systematic, defensible framework to support utilities as they evaluate groundwater monitoring options and implement systems that meet the technical and regulatory expectations of the Legacy CCR Rule. The approach incorporates defined evaluation criteria, including hydrogeologic characterization, unit geometry, monitoring objectives, regulatory compliance considerations, and long-term operational implications. Alternative monitoring system configurations are compared using a structured decision process that identifies practical, compliant, and cost-effective solutions tailored to individual CCR units or unit groupings. Drawing on lessons learned from designing and managing groundwater monitoring programs for active CCR units, the presentation highlights strategies to reduce uncertainty, streamline implementation, and enhance regulatory defensibility. The systematic approach provides utilities with a clear pathway for establishing optimized groundwater monitoring systems that support closure planning, strengthen compliance positions, and meet evolving federal regulatory requirements.
