Designing a Quality Program to Comply with the Coal


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Designing a Quality Program to Comply with the Coal Combustion Residual Rule 2016 TCEQ Environmental Trade Fair & Conference Austin, Texas Rock J. Vitale, CEAC David Thal, CQA, CEAC, CFS David Gratson, CEAC

Agenda

CCR CCR Regulations

Regulations

Business Risks with Regulations

Quality Management and Assurance Elements A “Best in Class” QA Program for CCR

CCR Regulations 40 CFR, Part 257, Subpart D – Major Components of CCR Rule Defines classifications of landfills and surface impoundments

Provides regulations for closures and active facilities

Presents air monitoring requirements

Presents design criteria and inspection requirements (for structural integrity)

Presents groundwater monitoring requirements

CCR Regulations 40 CFR, Part 257, Subpart D – Coal Combustion Residuals (CCR)

April 17, 2015 published, Effective October 17, 2015 Subtitle D – Solid Waste Using newly developed leaching test methods - SW-846, Methods 13131317 [also known as Leaching Environmental Assessment Framework (LEAF) Test Methods] to evaluate impacts to groundwater and surface water, the agency established technical requirements for new and existing CCR landfills and surface impoundments Problem is there are no current criteria for using LEAF results

Establishes operating criteria and record keeping requirements along with closure requirements.

Liner and underlying leachate collection and removal systems.

CCR Regulations 40 CFR, Part 257, Coal Combustion Residuals • Ground water monitoring system, establish procedures for sampling, analyzing ground water

• Procedures required for statistical analysis and QA

• Closure and post-closure requirements • Monitor and maintain

• No direct federal oversight – Citizen’s Legal Action

• States likely will revise Solid Waste Management Plans to address what is promulgated

CCR Regulations 40 CFR, Part 257, Coal Combustion Residuals

• §257.93: “Accurate representation” of background and downgradient. Requires the development of a SAP with: • Sample collection, preservation and shipment, analytical procedures, sample integrity (COC) and defined QA/QC • “Constituents” – Appendix III or IV (total recoverable, not filtered).

• Hydrologic requirements for well selection.

CCR Regulations 40 CFR, Part 257, Coal Combustion Residuals

• Detection Monitoring [§257.94(b) – (d)]for toxic metals, pH, TDS. • App III constituents, semiannually. • Existing: Must have at least 8 data sets by Oct, 2017. • New: 8 data sets within first six months. • Option for alternative monitoring frequency.

CCR Regulations 40 CFR, Part 257, Coal Combustion Residuals • Statistical Analysis [§257.93(f)(1-5)], with P.E. certification of compliance is required. Must compare App III components background to downgradient within 90 days of completing analysis.

• A minimum of 1 upgradient and 3 downgradient wells are required, but increased as required to represent different groundwater flow conditions.

• Background samples must be taken from the uppermost aquifer that is representative • If Downgradient>Background ->Assessment Monitoring • Or If exceed drinking water standards (§ 257.3-3).

CCR Regulations 40 CFR, Part 257, Coal Combustion Residuals

• Assessment Monitoring [§257.95(b) – (d)]. • Appendix IV Constituents • Must establish GW protection standards for all constituents • If two consecutive sampling event show, return to Detection Monitoring. • If downgradient>background but below GW protection standards, continue Assessment Monitoring • If downgradient>GW protection standards, Corrective Action monitoring (more wells, nature and quantity of release)

CCR Regulations 40 CFR, Part 257, Coal Combustion Residuals • Certification of Monitoring Program Compliance • Design Criteria and Inspection Requirements (§257.70-91) • Record Keeping (§257.105) • Notifications (§257.106) • Public Internet Posting of Data Required

• (§257.107)

Business Risks Acting on Incorrect Data • Activists can collect their own data • Sampling, laboratory, data, reporting errors • Issues with LEAF methods

CCR Rule Specific Challenges • Enforcement by citizen lawsuit • Loss of control of flow and quality of technical information • Loss of control of the technical conversation • Engaging from a position of technical weakness

Market Risk • Potential surprises lurk in any new program • Misunderstanding potential liabilities and costs • Potential for negative media attention

Quality Management and Assurance Elements Chemistry and Toxicology QA Oversight

Project Chemistry and Toxicology

Critical QA Components

Data Management and Data Interpretation

Geoscience Quality Assurance Oversight

Geoscience Components

Drafting sampling procedures and/or reviewing existing sampling procedures for compliance with state and federal requirements Providing classroom and hands-on training of sampling personnel to project specific sampling and field measurement procedures Drafting/reviewing sampling and analysis plans (SAP) for

compliance with state and federal requirements and data quality goals of the project Groundwater modeling, trend analysis, permit compliance support, specialized

sampling and monitoring well installation oversight Conducting third-party field audits of sampling personnel to evaluate field practices and compliance with project record documents

Geoscience Oversight Third-Party Field Auditing  Often Neglected - A Poorly Collected Sample Results in Poor Quality Data  Independent Third-Party – No “Skin in the Game” Trying to Take Over Sampling

Benefits of Field Auditing  Improvements in Field Consultant Procedures  Consistency in Sampling Techniques Between Sampling Teams

 Cost Control - Saves Time and Money and can Prevent Poor Decisions  Contract Compliance and Efficient Use of Resources  Locate and Correct Deficiencies Immediately - Do It Once, Do It Right

 Liability Control/Minimization  Approved Plans are Being Followed  Waste Handling and Execution of Proper Health & Safety  Properly Trained and Appropriately Experienced Personnel

Geotechnical Oversight Accuracy of monitoring well and piezometer installations Collection of Subsurface soil and rock core samples Proper drilling techniques OSHA safety requirements Oversee pump test projects for groundwater modeling activities Accuracy of field instrumentation installations Construction Quality Assurance inspections for compliance with project technical specifications and project drawings during landfill construction and landfill cover construction Performance of QA testing (materials and geotechnical) for compliance with project requirements QA inspections of Contractor’s final product prior to conducting final inspections for regulatory agency approval

Chemistry and Toxicology Quality Oversight

Laboratory Prequalification Review/Vetting

Data Validation

Laboratory Auditing

Troubleshooting

Performance Evaluation Studies

Laboratory Auditing

On-site laboratory audits by credentialed chemists and biologists Looking hard at the “soup to nuts” laboratory activities for

Critical audit reports and mandated corrective actions Covers quality system, technical competence, compliance, service issues. Assessing traceability and overall defensibility of records Detects process weaknesses and opportunities for error Detects operational shortcuts & documentation gaps

Data Validation

Detects and eliminates laboratory and sampling backgrounds.

Frequently detects calculation errors, dilution factor issues.

Review of procedures and control data for frequency of failures, recent failures, and corrective actions.

Laboratory learns to comply with method and best practice requirements for “that” client.

Additional Chemistry/Toxicology Elements

Phone-a-friend technical experts Help desk for sampler and laboratory vendors Litigation Support Environmental Forensics Source allocation Consulting on chemical transformations in the environment

Bioavailability assessments Statistical Support Method Development and Method Optimization

Centralized Environmental Data Management Purpose of Centralized Data Management Client ownership of data all in one place

Independent ThirdParty Centralized Data Management Entity that is not a sampling or laboratory contractor

Web-Based Services

Enterprise & Project Information Management

Technical data management, analysis, and reporting

Policies/procedures development

Geographic Information Systems (GIS)

Analytical laboratory organization

Field data collection

EDD Development

Imaging & data archival

Groundwater Monitoring Program Support Services

SAPs, QAPPs, Data Management Plans & Sampling Guidance Procedures Help desk for sampler and laboratory vendors Training and Field Auditing of sampling personnel Evaluate analytical data for matrix interferences; identify the right methods, method options, for compliance and performance. Develop technical and service requirements for laboratories to contractually bind laboratories to quality service and reduce costs. Provide laboratory coordination, data validation and data interpretation Provide data management services by establishing a project “production” database to allow for easy access to project data Provide legal support on an as needed basis including expert testimony, review of plaintiff data and assistance in preparing and/or conducting depositions

Quality Assurance - CCR

Three Phase Program

Design

Implement

Maintain

Quality Assurance - CCR Phase 1 • SOPs, SAP, QAPP, Data Management Plan • RFP for Sampling Firms • Technical Specifications for Laboratories • Interview Sampling Short List Candidates • Score Vendors, assist during procurement • Detailed Plans and Budgets for Phases 2 and 3.

Quality Assurance - CCR

Planning Activities

• Quality Assurance Program Plan (QAPP) Preparation (Required) • Work Plan (WP) and Sampling and Analytical Plan (SAP) Preparation (Recommended) • Analytical Request Form/Sample Planning Module and Electronic Chain-of-Custody (Recommended) • Help Desk (Recommended)

Sampling Activities

• Standard Operating Procedure (SOP) Development (Required) • SOP Training (Recommended) • Field Oversights/Audits (Recommended) • Laboratory Coordination (Recommended)

Quality Assurance - CCR

Analysis

• Prepare Laboratory Technical Specifications Manual (Recommended) • On-Site Audit of Contracted Laboratories (Recommended) • Performance Evaluation Study (Recommended) • QA Procedure (Required) • Statistical Analysis Procedure (Required)

Data Management/ Data Review

• Data Verification and Validation and Electronic Data Review (Recommended) • Historical Data Migration (Recommended) • Sample Tracking (Recommended) • Data Management/Data Review (Recommended) • Data Management Plan and Electronic Data Deliverables Specifications (Strongly recommended) • Centralized Database (Strongly recommended)

Examples PPL Fly Ash Release

• Sampling, QA, Data Management

TVA Fly Ash Release

• Sampling and Laboratory QA, Data Management

Gallatin Fossil Plant

• Sampling and Laboratory QA Oversight on GW, surface and sediment impacts, lawsuit driven

TVA Valley Wide

• Groundwater monitoring program

PPL Ash Pond Management

• Groundwater monitoring program

TVA CCR and Landfill • Three-phase system-wide program Permit Program

Examples TVA’s Environmental Data Quality Program for the Kingston Ash Recovery Project  QA Oversight of sampling and analysis and provided project-wide data management of all environmental and IH data  Developed or helped develop 60 SOPs and 24 SAPs  Developed the QAPP and Data Management Plan  Evaluated analytical methods as they pertain to coal ash such as DOC LEAF and several digestion techniques  Validated 340,324 sample results  Total number of samples subjected to our QA/DM is 32,678  Data acceptance rate > 99.5% (goal was 90%)  Assisted TVA in preparation/response to regulatory audits  Conducted 263 field QA oversights  Conducted 25 laboratory audits

Thank You

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