Designing a Quality Program to Comply with the Coal...

Designing a Quality Program to Comply with the Coal Combustion Residual Rule

2016 TCEQ Environmental Trade Fair & ConferenceAustin, Texas

Rock J. Vitale, CEAC

David Thal, CQA, CEAC, CFS

David Gratson, CEAC

Agenda

CCRRegulations

CCR 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 1313-1317 [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,


• §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

• 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.

40 CFR, Part 257,


CCR Regulations

40 CFR, Part 257,


• 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

• 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)

40 CFR, Part 257,


CCR Regulations

40 CFR, Part 257,


• 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

Critical QA Components

Chemistry and

Toxicology QA Oversight

Geoscience Quality

Assurance Oversight

Data Management

and Data Interpretation

Project Chemistry

and Toxicology

Quality Management and Assurance Elements

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

Benefits of 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

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 Troubleshooting

Laboratory Auditing

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 Third-Party Centralized

Data Management

Entity that is not a sampling or laboratory

contractor

Web-Based Services

Technical data management, analysis,

and reporting

Geographic Information Systems (GIS)

Enterprise & Project Information

Management

Policies/procedures development

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

Design Implement Maintain

Three Phase Program


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 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)

Planning Activities

• Standard Operating Procedure (SOP) Development (Required)

• SOP Training (Recommended)

• Field Oversights/Audits (Recommended)

• Laboratory Coordination (Recommended)

Sampling Activities


•Prepare Laboratory Technical Specifications Manual (Recommended)

•On-Site Audit of Contracted Laboratories (Recommended)

•Performance Evaluation Study (Recommended)

•QA Procedure (Required)

•Statistical Analysis Procedure (Required)

Analysis

•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)

Data Management/ Data Review

Examples

• Sampling, QA, Data ManagementPPL Fly Ash Release

• Sampling and Laboratory QA, Data ManagementTVA Fly Ash Release

• Sampling and Laboratory QA Oversight on GW, surface and sediment impacts, lawsuit drivenGallatin Fossil Plant

• Groundwater monitoring programTVA Valley Wide

• Groundwater monitoring programPPL Ash Pond Management

• Three-phase system-wide programTVA CCR and Landfill

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

Designing a Quality Program to Comply with the Coal...

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