EPA CCR Legacy Rule Services

The EPA’s CCR Legacy Rule ensures the safe management and closure of legacy inactive coal ash impoundments and management units. Schnabel worked extensively with a client to conduct a comprehensive facility evaluation in accordance with this new rule. To support compliance, we performed data reviews, document research, site history compilation, and other information-gathering techniques including physical site inspections and meetings with station personnel, which helped quantify site-specific identifiable or potential CCR Management Units (CCRMUs) requiring further investigation.

Schnabel helped the client comply with the Legacy Rule, which requires a two-part Facility Evaluation Report (FER) to be prepared, certified by a Professional Engineer (PE) and the owner of the facility, filed in the operating record, and posted to the owner’s CCR rule compliance data and information website. Inventory investigations involved multiple legacy CCR Surface Impoundments (SIs) and potential CCRMUs at one active and two inactive power facilities.

As part of the investigation, Schnabel’s team conducted a comprehensive review of reasonably and readily available historical design, investigative, and construction documents. Specific inventory activities conducted included reviews of historic property ownership records, historical aerial site photography, known existing and historical site permits, former mapping of known existing and historical CCR deposition areas, and discussions with station personnel to understand the nature and purpose of each CCR unit.

From this information gathering work, Schnabel developed a description of each depositional area, with known engineering properties of foundations and abutments; identified any known spills and/or releases associated with the CCR units; identified any known structural instability areas, groundwater conditions, and known impacts; reported horizontal and lateral extents of each CCR unit; size and volumetric estimates; and dates when each CCR unit’s operations began and ended. We also identified any significant retrofits, closure activities, or other alteration construction activities.

Schnabel’s work resulted in the submittal of the Part 1 FER documenting each CCR unit’s historic information, as well as identifying data gaps and the plan for remedying those data gaps for subsequent Part 2 FERs.