By A.J. Smith  |   August 29th, 2015
The US EPA published new criteria for classification of solid waste disposal facilities and practices on April 17th, 2015.  Based on their effective date of October 19th it’s pivotal that you understand your owner operator inspection requirements for Coal Combustion Residuals (CCR) disposal units. 
Based on type and designated hazard level you will be required to secure services for:
  • Weekly inspection of CCR surface impoundments by a qualified person,
  • Monthly inspections of CCR units and  instrumentation by a qualified person, and
  • Annual inspections by a qualified professional engineer (effective January 19, 2016).
To complicate matters many CCR impoundments that contain earthen fill embankments are subject to state dam safety regulations based on their hazard level classification. 
Due to recent events, the Virginia Department of Environmental Quality (DEQ) is moving towards classifying all ash impoundments as high-hazard dams.  In Ohio, most ash impoundments are Class II (medium-hazard) structures by the Department of Natural Resources. In addition to regular inspections, many of these impoundments are required to have Emergency Action Plans (EAP) and Operation, Maintenance & Inspection (OM&I) Manuals in place.  If original, engineered construction plans are not available, the dams may be required to be assessed for stability.  The assessment would include a geotechnical investigation, slope stability analysis, hydraulic analysis of spillway systems and an as-built survey.
It is important to note that ash impoundments that are no longer in use may be removed from regulatory requirements by a formal closure process.  A pond closure may include removal or regrading of the ash, capping of the ash material with clay soil or a liner, breaching of an embankment, or some combination thereof.  Design considerations include: stability of remaining embankments, lowering of the water table within the impoundment, capping of remaining ash with an impervious material, monitoring of water levels during and after construction, and revegetation and reclamation of the site.
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A.J. Smith, Senior Project Manager
A.J. Smith focuses on geotechnical and water resources projects.  He has used his geotechnical engineering and hydraulics and hydrology (H&H) expertise to work on a number of earthen dam and up-ground reservoir projects.  He has worked with ODNR on the investigation and rehabilitation of multiple state-owned dams, where different divisions of ODNR have been the owner, client and regulatory agency.  A.J. has performed inspections and investigations of existing dams for dam and spillway repairs.  He has designed spillway pipes and channels, lake drain systems, armored dam embankments, multi-billion gallon up-ground reservoirs, dam repairs, and stream bank stabilizations.  He has performed analyses of dams and downstream river systems to model breach flows and prepare inundation maps.
A.J. is a licensed Professional Engineer in the states of Ohio and Kentucky.  He holds a Master of Science in Civil Engineering, specializing in Geotechnical Engineering from The Ohio State University and a Bachelor of Science in Civil Engineering from Ohio Northern University.  He is a member of the Association of State Dam Safety Officials (ASDSO) and is a Certified Floodplain Manager (CFM).
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