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 citationRequirementPosted On Website (Y,N,Exempt)DocumentNotes
§ 257.60(c)(1), .61(c)(1), .62(c)(1), .63(c)(1), .64(d)(1)Location restrictionsYBAT wetlands
BAT unstable areas
BAT seismic impact zone
BAT fault areas
BAT aquifer separation
§ 257.71(a)(1)Documentation of liner typeYBAT Liner CertificationPonds 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
EPonds are incised and are therefore exempt.
§ 257.73(a)(3)(i)Emergency action planEPonds are incised and are therefore exempt.
§ 257.73(a)(3)(i)(E)Documentation recording the face-to-face meeting or exercise with local emergency respondersEPonds are incised and are therefore exempt.
§ 257.73(c)History of construction of CCR unitEPonds are incised and are therefore exempt.
§ 257.73(d) and (f)Initial structural stability assessmentEPonds are incised and are therefore exempt.
§ 257.73(e) and (f)Initial safety factor assessmentEPonds are incised and are therefore exempt.
§ 257.80(b)(5)Initial fugitive dust control planYDust Control Plan
§ 257.80(c)Initial annual CCR fugitive dust control report YInitial Annual Dust Control Report
2nd annual CCR fugitive dust control reportY2nd annual dust control report
3rd annual and subsequent CCR fugitive dust control report
dust control report
Y3rd annual dust control report
§ 257.82(c)(3)Initial inflow design flood control system planYImpoundment Inflow Plan
§ 257.83(b)(3) 2Report by PE following initial annual inspectionEPonds are incised and are therefore exempt.
Report by PE following 2nd annual inspectionEPonds are incised and are therefore exempt.
Report by PE following 3rd annual and subsequent inspectionsEPonds are incised and are therefore exempt.
§ 257.90(e)Initial annual groundwater monitoring and corrective action reportY 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 reportsY BAT Impoundments (2018) - Annual Groundwater Monitoring and Corrective Action Report
§ 257.91(f) and
§ 257.90(b)(1)(i)
Groundwater monitoring system certificationYRefer to the groundwater monitoring reports BAT Impoundments (2016-2017) and (2018)
§ 257.93(f)(6) and
§ 257.90(b)(1)(i)
Statistical method certificationYRefer to the groundwater monitoring reports BAT Impoundments (2016-2017) and (2018)
§ 257.94(e)(3)Notification that an assessment monitoring program has been establishedYCCR 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 GWPSYCCR rule groundwater monitoring letter to CDPHE BAT (12/20/18)Letter to CDPHE discusses this.
§ 257.95(g)(2)Notification to land ownersENot applicable as the plume is limited to Platte River property.
§ 257.95(g)(5)Notification of initiation of assessment of corrective measuresYCCR groundwater ASD letter BAT impoundments to CDPHE (4/2/19)
§ 257.96(d)Conclusion of assessment of corrective measuresYCCR groundwater ACM bottom ash ponds letter to CDPHE (6/14/19)

Assessment of corrective measures BAT impoundments (6/14/19)
Posted in the Operating Record on June 17, 2019
§ 257.102(b)(2)Initial closure planYInitial Impoundment Closure Plan
§ 257.102(b)(3)(iii)Amended closure planYAmended Impoundment Closure Plan
§ 257.102(g)Notification of intent to close CCR unitYNotification of intent to close the BAT impoundments
§ 257.102(e)(2)(ii)Demonstration(s) for a time extension for initiating closureENot applicable. No time extention requested.
§ 257.103(c)(1)Notification of intent to comply with the alternative closure requirementsENot applicable. No alternative closure requested.
§ 257.102(k)Initial retrofit planENot applicable. No retrofit planned.
§ 257.102(k)(5)Notification of intent to retrofit CCR unitENot applicable. No retrofit planned.
§ 257.103(k)(3)Notification of intent to comply with the alternative closure requirementsENot applicable. No alternative closure requested.
§ 257.104(d)(2)Initial post-closure care planENot 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 planENot applicable. Closure method is closure by removal (clean closure). Therefore, ponds are exempt from post-closure care.

Existing landfills

Federal CCR citation RequirementPosted on website (Y,N,Exempt)DocumentNotes
§ 257.64(d)(1)Unstable areas demonstrationYMonofill unstable areas
§ 257.80(b)(5)Initial fugitive dust control planYRawhide Energy Station dust control plan
§ 257.80(c)Initial annual CCR fugitive dust control
report
YInitial 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
Y3rd annual dust control report for Rawhide Energy Station
§ 257.81(c)(3)Initial run-on and run-off control system
plan
YMonofill run-on / run-off plan
§ 257.84(b)(3)Report by PE following initial annual
inspection
Y2016 annual report-inspection of applicable CCR units
Report by PE following 2nd annual
inspection
Y2017 annual report-inspection of applicable CCR units
Report by PE following 3rd annual and subsequent inspections
subsequent inspections
Y2018 annual report-inspection of applicable CCR units
Report by PE following 4th annual and subsequent inspections
subsequent inspections
Y2019 annual report-inspection of applicable CCR units
§ 257.90(e)Initial annual groundwater monitoring and corrective action reportY2016-17 Monofill groundwater monitoring report
2nd annual groundwater monitoring and corrective action reportY2018 Monofill groundwater monitoring and corrective action report
3rd annual and subsequent groundwater monitoring and corrective action reportNDoes not currently apply.
§ 257.91(f) and
§ 257.90(b)(1)(i)
Groundwater monitoring system certificationYRefer to the groundwater monitoring reports Monofill (2016-2017) and (2018)
§ 257.93(f)(6) and
§ 257.90(b)(1)(i)
Statistical method certificationYRefer to the groundwater monitoring reports Monofill (2016-2017) and (2018)
§ 257.94(e)(3)Notification that an assessment monitoring program has been establishedYCCR 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 GWPSYCCR ground water monitoring letter to CDPHE monofill Letter to CDPHE also discusses this.
§ 257.95(g)(2)Notification to land ownersENot applicable as the plume is limited to Platte River property.
§ 257.95(g)(5)Notification of initiation of assessment of corrective measuresYLetter sent to CDPHE on April 2, 2019
§ 257.96(d)Conclusions of assessment of corrective measuresYCCR Groundwater ACM Monofil Letter to CDPHE (8/15/19)

Assessment of corrective measures ash monofill (8/15/19)
Posted in the operating record on August 15, 2019
§ 257.102(b)(2)Monofill Closure PlanYMonofill Closure Plan
§ 257.102(b)(3)(iii)Amended closure planEDoes not apply.
§ 257.102(g)Notification of intent to close CCR unitNNot applicable at this time.
§ 257.102(k)Initial retrofit planENot applicable.
§ 257.102(k)(5)Notification of intent to retrofit CCR unitENot applicable.
§ 257.104(d)(2)Initial post-closure care planYMonofill Post-Closure Plan
§ 257.104(d)(3)(iii)Amended post-closure care planENot applicable.