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Corrective Action for Impacted Groundwater Resulting from CCR Units


 

 

Overview (40 CFR 257.90)

If Appendix IV constituents are found in concentrations exceeding the groundwater protection standard during assessment monitoring, corrective action will be required. The CCR Rule establishes specific requirements for corrective actions to remediate any releases, restore the impacted area to its original condition, and prevent the further release of contamination.

A summary of any corrective actions must be included in an annual groundwater monitoring and corrective action report, which is required for all CCR units. In addition to groundwater monitoring activities, the annual report must document corrective actions over the previous year, as well as project activities for the upcoming year.  For existing CCR landfills and existing CCR surface impoundments, the initial report is to be complete no later than January 31, 2018, and annually thereafter. For new CCR landfills, new CCR surface impoundments, and all lateral expansions of CCR units, the owner or operator must prepare the initial report no later than January 31 of the year following the year of CCR unit establishment, and annually thereafter.

 

Assessment of Corrective Measures (40 CFR 257.96)

An assessment of corrective measures must be initiated within 90 days of finding an exceedance of the groundwater protection standard (or immediately upon detection of a release) for any Appendix IV constituent. If the assessment is not initiated within 90 days, the CCR unit will be subject to requirements for closure or retrofitting. The assessment must include a thorough analysis of potential corrective measures, which must be discussed in a public meeting at least 30 days prior to the selection of remedy.

 

Selection of Remedy (40 CFR 257.97)

Based on the corrective measures assessment, a remedy must be selected as soon as feasible, must meet specified cleanup standards and be certified by a qualified professional engineer. The remedy selected should be based on short- and long-term effectiveness, protectiveness of human health and the environment, degree of certainty for success, potential to reduce further releases, ease or difficulty of implementation and degree to which community concerns are addressed.

Additionally, CCR disposal facility owners must prepare a semiannual report describing the progress of selecting a remedy. After selecting a remedy, a final report must be completed, which describes the selected remedy, how it meets the specified standards and a timeline for initiation and completion of remedial activities.

 

Implementation of the Corrective Action Program (40 CFR 257.98) 

Remedial activities must be initiated within 90 days of selecting a groundwater remedy. These activities include the establishment and implementation of a corrective action groundwater monitoring program, implementation of the corrective action remedy, and any interim measures necessary to reduce further contaminant leaching and potential exposures. 

Compliance with the groundwater protection standards can be achieved when Appendix IV constituents have not exceeded the groundwater protection standard for three consecutive years. Upon completion of the remedy, a notification of completion must be completed and certified by a qualified professional engineer.


 

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