The Coal Combustion Residual (CCR) Rule, is a self-implementing rule which regulates the handling and disposal of CCRs as non-hazardous solid waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA). CCR Rule requirements include regular evaluation of landfill and impoundment stability, to ensure safety in CCR handling and disposal and proactively mitigate signs of CCR unit distress. Owners/operators are accountable for compliance with rule requirements, which is verified through routine inspections. Weekly, annual, and five-year inspections are completed for ensured compliance.
Platte River is committed to compliance with the CCR Rule and has completed the applicable deliverables. The tables provided below provide the specific compliance information potentially required by the CCR Rule.
Existing surface impoundments
| Federal CCR citation | Requirement | Posted On Website (Y,N,Exempt) | Document | Notes |
|---|---|---|---|---|
| § 257.60(c)(1), .61(c)(1), .62(c)(1), .63(c)(1), .64(d)(1) | Location restrictions | Y | BAT wetlands BAT unstable areas BAT seismic impact zone BAT fault areas BAT aquifer separation | |
| § 257.71(a)(1) | Documentation of liner type | Y | BAT Liner Certification | Ponds were constructed with 18" of clay, which differs from current regulatory requirements. Certified letter from AECOM discusses this. |
| § 257.73(a)(2) and (f) | Initial hazard potential classification assessment | E | Ponds are incised and are therefore exempt. | |
| § 257.73(a)(3)(i) | Emergency action plan | E | Ponds are incised and are therefore exempt. | |
| § 257.73(a)(3)(i)(E) | Documentation recording the face-to-face meeting or exercise with local emergency responders | E | Ponds are incised and are therefore exempt. | |
| § 257.73(c) | History of construction of CCR unit | E | Ponds are incised and are therefore exempt. | |
| § 257.73(d) and (f) | Initial structural stability assessment | E | Ponds are incised and are therefore exempt. | |
| § 257.73(e) and (f) | Initial safety factor assessment | E | Ponds are incised and are therefore exempt. | |
| § 257.80(b)(5) | Initial fugitive dust control plan | Y | Dust Control Plan | |
| Y | Revised Dust Control Plan | |||
| § 257.80(c) | Initial annual CCR fugitive dust control report | Y | Initial Annual Dust Control Report | |
| 2nd annual CCR fugitive dust control report | Y | 2nd annual dust control report | ||
| 3rd annual and subsequent CCR fugitive dust control report dust control report | Y | 3rd annual dust control report | ||
| 4th annual dust control report | Y | 4th annual dust control report | ||
| 5th annual dust control report | Y | 5th annual dust control report | ||
| 6th annual dust control report | Y | 6th annual dust control report | ||
| 7th annual dust control report | Y | 7th annual dust control report | ||
| 8th annual dust control report | Y | 8th annual dust control report | ||
| § 257.81(c)(3) | Solid waste disposal facility run-on and run-off control system plan 5-year recertification | E | Exemption letter | Monofill run-on / run-off letter |
| § 257.82(c)(3) | Initial inflow design flood control system plan | Y | Impoundment Inflow Plan | |
| § 257.83(b)(3) 2 | Report by PE following initial annual inspection | E | Ponds are incised and are therefore exempt. | |
| Report by PE following 2nd annual inspection | E | Ponds are incised and are therefore exempt. | ||
| Report by PE following 3rd annual and subsequent inspections | E | Ponds are incised and are therefore exempt. | ||
| § 257.90(e) | Initial annual groundwater monitoring and corrective action report | Y | BAT Impoundments (2016-17) – Annual Groundwater Monitoring Report (superceded) BAT Impoundments (2016-17) – Annual Groundwater Monitoring (Feb. 20, 2018 revision) | |
| 2nd annual and subsequent groundwater monitoring and corrective action reports | Y | BAT Impoundments (2018) - Annual Groundwater Monitoring and Corrective Action Report | ||
| 3rd annual and subsequent groundwater monitoring and corrective action reports | Y | BAT Impoundments (2019) - Annual Groundwater Monitoring and Corrective Action Report | Annual groundwater report notification letter | |
| 4th annual and subsequent groundwater monitoring and corrective action report | Y | BAT Impoundments (2020) - Annual Groundwater Monitoring and Corrective Action Report | Annual groundwater report notification letter |
|
| 5th annual and subsequent groundwater monitoring and corrective action report | Y | BAT Impoundments (2021) - annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| 6th annual and subsequent groundwater monitoring and corrective action report | Y | BAT Impoundments (2022) - annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| 7th annual and subsequent groundwater monitoring and corrective action report | Y | BAT Impoundments (2023) - annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| § 257.91(f) and § 257.90(b)(1)(i) | Groundwater monitoring system certification | Y | Refer to the groundwater monitoring reports BAT Impoundments (2016-2017) and (2018) | |
| § 257.93(f)(6) and § 257.90(b)(1)(i) | Statistical method certification | Y | Refer to the groundwater monitoring reports BAT Impoundments (2016-2017) and (2018) | |
| § 257.94(e)(3) | Notification that an assessment monitoring program has been established | Y | CCR rule groundwater monitoring letter to CDPHE BAT (12/20/18) | Posted within the 2018 Annual Groundwater Monitoring Report. Letter to CDPHE also discusses this. |
| § 257.95(g) | Notification that Appendix IV constituents have been detected at SSI above GWPS | Y | CCR rule groundwater monitoring letter to CDPHE BAT (12/20/18) | Letter to CDPHE discusses this. |
| § 257.95(g)(2) | Notification to land owners | E | Not applicable as the plume is limited to Platte River property. | |
| § 257.95(g)(5) | Notification of initiation of assessment of corrective measures | Y | CCR groundwater ASD letter BAT impoundments to CDPHE (4/2/19) | |
| § 257.96(d) | Conclusion of assessment of corrective measures | Y | CCR groundwater ACM bottom ash ponds letter to CDPHE (6/14/19) | Posted in the Operating Record on June 17, 2019 |
| Y | Assessment of corrective measures BAT impoundments (6/14/19) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (1/9/20) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (6/4/20) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (12/2/20) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (06/09/2021) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (12/09/2021) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (06/09/2022) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (12/09/2022) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (6/29/2023) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (12/06/2023) | |||
| Y | CDPHE CCR Groundwater ACM BAT Progress Letter (06/11/2024) | |||
| § 257.102(b)(2) | Initial closure plan | Y | Initial Impoundment Closure Plan | |
| § 257.102(b)(3)(iii) | Amended closure plan | Y | Amended Impoundment Closure Plan | |
| § 257.102(g) | Notification of intent to close CCR unit | Y | Notification of intent to close the BAT impoundments | |
| § 257.102(e)(2)(ii) | Demonstration(s) for a time extension for initiating closure | E | Not applicable. No time extention requested. | |
| § 257.103(c)(1) | Notification of intent to comply with the alternative closure requirements | E | Not applicable. No alternative closure requested. | |
| § 257.102(k) | Initial retrofit plan | E | Not applicable. No retrofit planned. | |
| § 257.102(k)(5) | Notification of intent to retrofit CCR unit | E | Not applicable. No retrofit planned. | |
| § 257.103(k)(3) | Notification of intent to comply with the alternative closure requirements | E | Not applicable. No alternative closure requested. | |
| § 257.104(d)(2) | Initial post-closure care plan | E | Not applicable. Closure method is closure by removal (clean closure). Therefore, ponds are exempt from post-closure care. | |
| § 257.104(d)(3)(iii) | Amended post-closure care plan | E | Not applicable. Closure method is closure by removal (clean closure). Therefore, ponds are exempt from post-closure care. |
Existing landfills
| Federal CCR citation | Requirement | Posted on website (Y,N,Exempt) | Document | Notes |
|---|---|---|---|---|
| § 257.64(d)(1) | Unstable areas demonstration | Y | Monofill unstable areas | |
| § 257.80(b)(5) | Initial fugitive dust control plan | Y | Rawhide Energy Station dust control plan | |
| Y | Revised dust control plan | |||
| § 257.80(c) | Initial annual CCR fugitive dust control report | Y | Initial annual dust control report for Rawhide Energy Station | |
| 2nd annual CCR fugitive dust control report | Y | 2nd annual dust control report for Rawhide Energy Station | ||
| 3rd annual and subsequent CCR fugitive dust control reports | Y | 3rd annual dust control report for Rawhide Energy Station | ||
| 4th annual dust control report | Y | 4th annual and subsequent CCR fugitive dust control report | ||
| 5th annual dust control report | Y | 5th annual dust control report | ||
| 6th annual dust control report | Y | 6th annual dust control report | ||
| 7th annual dust control report | Y | 7th annual dust control report | ||
| 8th annual dust control report | Y | 8th annual dust control report | ||
| § 257.81(c)(3) | Initial run-on and run-off control system plan | Y | Monofill run-on / run-off plan | |
| Solid waste disposal facility run-on and run-off control system plan 5-year recertification | Y | Monofill run-on / run-off plan | Monofill run-on / run-off letter | |
| § 257.84(b)(3) | Report by PE following initial annual inspection | Y | 2016 annual report-inspection of applicable CCR units | |
| Report by PE following 2nd annual inspection | Y | 2017 annual report-inspection of applicable CCR units | ||
| Report by PE following 3rd annual and subsequent inspections | Y | 2018 annual report-inspection of applicable CCR units | ||
| Report by PE following 4th annual and subsequent inspections | Y | 2019 annual report-inspection of applicable CCR units | ||
| Report by PE following 5th annual and subsequent inspections | Y | 2020 annual report-inspection of applicable CCR units | ||
| Report by PE following 6th annual and subsequent inspections | Y | 2021 annual report-inspection of applicable CCR units | ||
| Report by PE following 7th annual and subsequent inspections | Y | 2022 annual report-inspection of applicable CCR units | ||
| Report by PE following 8th annual and subsequent inspections | Y | 2023 annual report-inspection of applicable CCR units | ||
| Report by PE following 9th annual and subsequent inspections | Y | 2024 annual report-inspection of applicable CCR units | ||
| § 257.90(e) | Initial annual groundwater monitoring and corrective action report | Y | 2016-17 Monofill groundwater monitoring report | |
| 2nd annual groundwater monitoring and corrective action report | Y | 2018 monofill groundwater monitoring and corrective action report | ||
| 3rd annual and subsequent groundwater monitoring and corrective action report | Y | 2019 monofill annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| 4th annual and subsequent groundwater monitoring and corrective action report | Y | 2020 monofill annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| 5th annual and subsequent groundwater monitoring and corrective action report | Y | 2021 monofill annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| 6th annual and subsequent groundwater monitoring and corrective action report | Y | 2022 monofill annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| 7th annual and subsequent groundwater monitoring and corrective action report | Y | 2023 monofill annual groundwater monitoring and corrective action report | Annual groundwater report notification letter | |
| § 257.91(f) and § 257.90(b)(1)(i) | Groundwater monitoring system certification | Y | Refer to the groundwater monitoring reports Monofill (2016-2017) and (2018) | |
| § 257.93(f)(6) and § 257.90(b)(1)(i) | Statistical method certification | Y | Refer to the groundwater monitoring reports Monofill (2016-2017) and (2018) | |
| § 257.94(e)(3) | Notification that an assessment monitoring program has been established | Y | CCR ground water monitoring letter to CDPHE monofill | Posted within the 2018 Annual Groundwater Monitoring Report. Letter to CDPHE also discusses this. |
| § 257.95(g) | Notification that Appendix IV constituents have been detected at SSI above GWPS | Y | CCR ground water monitoring letter to CDPHE monofill | Letter to CDPHE also discusses this. |
| § 257.95(g)(2) | Notification to land owners | E | Not applicable as the plume is limited to Platte River property. | |
| § 257.95(g)(5) | Notification of initiation of assessment of corrective measures | Y | Letter sent to CDPHE on April 2, 2019 | |
| § 257.96(d) | Conclusions of assessment of corrective measures | Y | CCR Groundwater ACM Monofil Letter to CDPHE (8/15/19) | Posted in the operating record on August 15, 2019 |
| Y | Assessment of corrective measures ash monofill (8/15/19) | |||
| Y | CDPHE CCR Monofill ACM BAT Progress Letter (1/9/20) | Conclusion of assessment of corrective measures | ||
| Y | CDPHE CCR Monofill ACM BAT Progress Letter (6/4/20) | |||
| Y | CDPHE CCR Monofill ACM BAT Progress Letter (12/2/20) | |||
| Y | CDPHE CCR Monofill ACM BAT Progress Letter (06/09/21) | |||
| Y | CDPHE CCR Monofill ACM BAT progress letter (12/09/21) | |||
| Y | CDPHE CCR Monofill ACM BAT progress letter (6/09/22) | |||
| Y | CDPHE CCR Monofill ACM BAT progress letter (12/09/22) | |||
| Y | CDPHE CCR Monofill ACM BAT progress letter (6/29/23) | |||
| Y | CDPHE CCR Monofill ACM BAT progress letter (12/06/23) | |||
| Y | CDPHE CCR Monofill ACM BAT progress letter (06/11/24) | |||
| § 257.102(b)(2) | Monofill Closure Plan | Y | Monofill Closure Plan | |
| § 257.102(b)(3)(iii) | Amended closure plan | E | Does not apply. | |
| § 257.102(g) | Notification of intent to close CCR unit | N | Not applicable at this time. | |
| § 257.102(k) | Initial retrofit plan | E | Not applicable. | |
| § 257.102(k)(5) | Notification of intent to retrofit CCR unit | E | Not applicable. | |
| § 257.104(d)(2) | Initial post-closure care plan | Y | Monofill Post-Closure Plan | |
| § 257.104(d)(3)(iii) | Amended post-closure care plan | E | Not applicable. |