Illinois CCR Rule Compliance Data and Information
IL 845.240 and IL 845.800
This is a publicly accessible website for the Grand Tower Energy Center, LLC (GTEC) “Inactive Ash Basin” to provide information in accordance with Illinois Administrative Code Title 35, Part 845, Sections: 845.210 GENERAL PROVISIONS, 845.800 FACILITY OPERATING RECORED, and 845.810 PUBLICLY ACCESSIBLE INTERNET SITE REQUIREMENTS.
In 2015, the U.S. Environmental Protection Agency published the Hazardous and Solid Waste Management System; Disposal of Coal Combustion Residuals from Electric Utilities final rule in the Federal Register. This rule regulates the disposal of coal combustion residuals (CCR) as a solid waste as part of the Resource Conservation and Recovery Act (RCRA) in 40 CFR Parts 257 and 261.
In 2020, the State of Illinois proposed an additional rule – Part 845 in Title 35 of the Administrative Code – that contains standards for the storage and disposal of CCR in surface impoundments. This rule also contains requirements on the design, construction, operation, groundwater monitoring, corrective action, closure and post-closure care of surface impoundments containing CCR. Illinois EPA’s program includes the federal standards in EPA’s rule as well as a permitting program and financial assurance, public participation, closure alternative analysis, and prioritization requirements for the impoundments. The rule is anticipated to be promulgated in 2021.
The purpose of this page is to maintain a public website with access to compliance information regarding the Grand Tower Energy Center, LLC (GTEC) inactive ash basin.
The Grand Tower Energy Center, LLC (GTEC) has reportedly produced electricity since 1951 utilizing both coal and oil fired boilers prior to converting to natural gas in 2001. While operating coal fired boilers, GTEC developed a 21.7 acre coal combustion waste (CCW) impoundment for both fly ash and bottom ash residuals. The CCW impoundment has not received CCW materials since converting to natural gas in 2001. Current day, GTEC is a 478 Megawatt (MW) natural gas combined cycle facility that is located in Grand Tower, Illinois adjacent to the east bank of the Mississippi River. GTEC is located on 300 acres of land and is a merchant facility, which sells energy and capacity into the Midcontinent Independent System Operator (MISO) system.
GTEC notified intention to close under the USEPA Rule 257 requirements in 2015, which meets the requirements of ILEPA Rule 845 (2021).
Notification Of Intent To Close
In accordance with Rule 257.100(e)(1)(i); the owner or operator must have prepared and placed in the facility’s operating record by December 17, 2015, a notification of intent to initiate closure of the inactive CCR surface impoundment pursuant to § 257.105(i)(1). GTEC retained Environmental Resources Management (ERM) in October 2014 to begin evaluating closure options for the inactive ash basin. The first Technical Memorandum prepared by ERM evaluating the closure options moving forward was issued to GTEC on March 3, 2015 and placed in the Facility’s Operating Record. Following these activities, ERM returned to the site November 2015 to perform field exploratory activities to validate moving forward with “Close-In-Place” of the inactive ash basin. At this point ERM was engaging Illinois EPA on a regular basis to discuss planned activities and permitting required moving forward. In accordance with Rule 257.100(e)(1)(ii); the owner or operator must have provided notification to the State Director and/or appropriate Tribal authority by January 19, 2016, of the intent to initiate closure of the inactive CCR surface impoundment pursuant to § 257.106(i)(1) ERM and GTEC began conversations with Illinois EPA beginning with the planning of field exploratory activities in November 2015. At this time information was relayed to Illinois EPA that GTEC planned to close the inactive ash basin using a “Close-In-Place” method contingent upon results of exploratory work.
GTEC implemented a Fugitive Dust Control Plan under USEPA Part 257, which is in accordance with IEPA Section 845.
In accordance with Rule 257.101(b)(3)(ii), GTEC installed a permanent marker sign at the Inactive Ash Basin on June 14, 2017. This complies with ILEPA Section 845.
GTEC began the permitting process with Illinois EPA for the “Closure-In-Place” of the GTEC Inactive Ash Basin. The documents submitted to the IEPA are posted below and are also available on the IEPA website. The comment period for the application was closed on November 1, 2019.
In accordance with Part 845.800, documentation regarding the results of inspections and instrumentation monitoring by a qualified person are presented.
Quarterly Post-Closure Groundwater Monitoring Reports
Quarterly Post-Closure CCR Impoundment Inspections
Quarterly post-closure impoundment inspections are performed by Environmental Resources Management (ERM) personnel and a quarterly findings report is generated. These inspections are specific to the closed CCR impoundment and areas that were within the remediation footprint. This is in addition to other inspections conducted for various regulatory programs required at the facility. Copies of the quarterly inspections can be found by clicking on the link below. Copies of the Post-Closure CCR Impoundment Inspection Reports may also be found within Appendix A of the Quarterly Groundwater Post-Closure Monitoring Reports.
Pre-Closure Ash Basin Inspections
Weekly and quarterly Ash Basin inspections were historically performed by site personnel. These inspections were specific to the ash basin and are in addition to other inspections conducted for various regulatory programs required at the facility. Environmental Resource Management (ERM) Engineers provided general information and inspection guidance to the facility for the development of the inspection program. Copies of the routine inspections can be found by clicking on the links below.
Pre-Closure Ash Basin Annual Inspections
No later than July 19, 2017, complete the initial annual inspection by a qualified professional engineer as set forth by § 257.83(b). The initial annual inspection will be posted when available.
The IEPA issued a Notice of Coverage letter on 10/25/2019, with the determination that storm water discharges associated with industrial activity from the closure of the facility ash pond are covered under the General NPDES Permit. A copy of the NPDES General Permit for Storm Water Discharges from Construction Site Activities is presented below.
Coal Combustion Residual Surface Impoundment Permitting Program, Application Form CCR 20E: