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About The Rule - CCR

 

 

GW Monitoring under the CCR Rules

Final rules were published by USEPA in Federal Register (40 CFR Part 257) on April 17, 2015 and took effect October 19, 2015. It is stated that states can manage CCR disposal sites under their own Solids Waste Management Plans – state regulations can be equivalent to or more stringent than EPA rules but not less than. Ground water monitoring programs must be in place by October 2017, but background water quality must be established prior to this. The data will be subject to statistical analysis – this means that having accurate data is vital to “passing” statistics to avoid triggering Assessment monitoring.

Detection of contamination from an unlined pond, either statistical exceedance or a hit above the MCL, will trigger pond closure and corrective action (pump and treat or other remediation)

Also ground water monitoring data are required to be made public beginning January 31, 2018. 

 

Timing

  • Must complete EIGHT ROUNDS of GW sampling (both background and downgradient) by October 2017 
  • Three monitoring tiers – Detection, Assessment & Corrective Action
  • Samples for metals CANNOT be filtered! This means proper well design, construction and sampling is CRITICAL to avoid biased data 

 

CCR Rule Requirements for GWS

Rule preamble lists several assumptions about monitoring well performance that pose unique challenges for CCR sites:

  • Sampling with no filtration means that increased importance is placed on proper well construction and purging/sampling procedures to eliminate or minimize sources of sampling artifacts.”
  • “A properly designed well should allow for sufficient groundwater flow for sampling, minimize the passage of materials into the well…” and “…provide a representative hydraulic connection to the geologic formation of interest.”
  • “…a properly constructed well is capable of yielding groundwater samples with low turbidity (< 5 Nephelometric Turbidity Units)…”
  • “Groundwater sampling should be conducted utilizing EPA protocol low-stress (low-flow) purging and sampling methodology, including measurement and stabilization of key indicator parameters prior to sampling.”