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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