Tag Archives: CCR

EUEC2020 – Energy, Utility & Environment Conference is now a VIRTUAL CONFERENCE

April 20, 2020

EUEC 2020: The Energy, Utility & Environment Conference and Exhibition, is set to proceed as a VIRTUAL CONFERENCE, with remote access to EUEC 2020, using a brand new EUEC Mobile App that will be active April 15, 2020.

You can Register as a “Virtual Attendee” giving you the ability to network and learn all from the comfort of your mobile device.

The conference will include presentations on numerous tracks:

  • Utility Regs, Permits and Compliance
  • AQ Control, Compliance & Testing
  • Coal, Oil, Gas, Pumps & Turbines
  • Power Gen & Energy Services
  • Climate, MSW, LFG, RNG, Biofuels
  • Renewable Energy, Storage, Efficiency
  • O&M, DDD & EHS, Fire Safety
  • CCR, CCS, ELG, and Coal Ash
  • Water, 316(B) & Cooling Tower

Click here for more information and to register

 

 

Posted by Laura Dorn at 8:00 am
Tag Archives: CCR

EPA Update – Coal Combustion Residuals – CCR

March 2, 2020

CCR – Disposal Regulation Revisions & Permitting Program by the U.S. Environmental Protection Agency moves forward on two matters that proposed to revise its 2015 solid waste regulations for the disposal of coal combustion residuals.

On February 19, 2020, EPA announced what it said is the last of planned actions to implement the Congressional mandates, respond to petitions, address the results of litigation, and apply lessons learned to ensure smoother implementation of the regulations. In a rulemaking entitled “A Holistic Approach to Closure Part B,” EPA proposed the following revisions:

  • Procedures to allow facilities to request approval to use an alternate liner for CCR surface impoundments;
  • Two co-proposed options to allow the use of CCR during unit closure;
  • An additional closure option for CCR units being closed by removal of CCR; and
  • Requirements for annual closure progress reports.

One of the proposed options for allowing the use of CCR for closure activities would allow coal ash to be moved between units at the same facility and consolidated at impoundments that are scheduled for closure. The second option would allow utilities to beneficially use coal ash in disposal unit closure activities.

Under the proposed rule, utilities would need to submit an alternative liner demonstration within 13 months of the final rule, with the possibility of extensions. The EPA noted there would likely be few basins able to meet the alternative liner requirements.

The proposal would also allow utilities to continue disposing ash into some ponds even after the pond has been scheduled for closure. Ponds will still be able to take in ash if the ash remains under a certain volume — and this includes ponds located in unstable areas, such as in a seismic zone or within five feet of a waterway.

EPA will seek comment on this proposal during a 45-day public comment period that will commence when it is published in the Federal Register. EPA will also hold a virtual public hearing on the proposal on April 9, 2020.


 

On February 20, 2020, EPA’s previously announced proposed rule to establish a Federal CCR Permitting Program was published in the Federal Register. The creation of a federal permitting program for coal ash disposal regulations was required by Congress in the 2016 Water Infrastructure Improvements for the Nation (WIIN) Act, which shifted enforcement authority for EPA’s disposal standards from citizen lawsuits to state environmental regulators. The federal permit program is intended for use in states that do not seek EPA approval for their own programs and for use in Indian Country.

The proposed federal program includes electronic permitting and sets requirements for permit applications, content and modification, as well as procedural requirements.

EPA will accept public comment on the proposed program until April 20, 2020. The agency will also hold a virtual public hearing on the matter on April 15, 2020.

Media reports of the announcements included coverage by The Hill, E&E News, Utility Dive, Phoenix Newsletter, and a pair of stories by Bloomberg.

 

Coal Combustion Residuals solutions, case studies, articles are here, including information about coal ash landfills, support, and closures.

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: CCR

Many Factors Influence Remedies for CCR Control and Disposal

January 6, 2020

Utilities face many challenges as they move forward developing programs to deal with disposal or recycling of coal combustion residuals (CCR). The U.S. Environmental Protection Agency (EPA) recently proposed changes to the 2015-enacted federal coal ash rule and issued a proposed Federal permitting program rule for CCR.

SCS Engineers closely follows developments relating to coal ash disposal. The company works with landfill operators, utilities, and others who deal with CCR to meet the challenges of proper waste management as federal, state, and local regulations evolve.

In addition to evaluating the impact of proposed rule changes and permitting programs, many utilities are currently working to address groundwater impacts from CCR units monitored under the current Federal CCR rules (40 CFR 257 Subpart D—Standards for the Disposal of Coal Combustion Residuals in Landfills and Surface Impoundments). Based on timing in the CCR rule, utilities have recently completed an Assessment of Corrective Measures (ACM) for groundwater impacts and are working on selecting a remedy for the groundwater impacts identified.

The remedies for CCR units not already closed include some form of source control, along with strategies to limit impacts to groundwater. The most prevalent remedies today include closure-in-place, or cap-in-place, of coal ash storage sites, or closure-by-removal, in which CCR is dewatered and excavated, then transported to a lined landfill.

So which factors should utilities consider as they evaluate different remedies?

“The answer to this question is wide and varied,” said Eric Nelson, a vice president with SCS. Nelson is one of the company’s national experts for electric utilities, and an experienced engineer and hydrogeologist. “In part, it depends on the situation” Nelson noted that remedies for disposal of waste such as CCR from power plants could differ from the disposal of municipal solid waste (MSW) or everyday trash.

“Is the landfill or impoundment already closed or capped, is it active or inactive, what type of CCR or waste (is being disposed of)?” Nelson said. “Then there’s the physical setting, the geology, the receptors or lack of receptors. My opinion is that the industry is in a tough spot because the remedy selection process is strongly influenced by opinion and widely varied regulatory climates.”

“For instance, selecting a remedy, which in many cases will include closing a surface impoundment, that leaves CCR in place feels risky to some due to what is happening in places like the Carolinas and Virginia,” Nelson said. “Anything short of exhumation and re-disposal seems to be cast as insufficient by some when closure in place is a tested and proven response in other arenas [such as MSW]. A one-size-fits-all solution isn’t appropriate.”

Some utilities have moved forward with complete excavation, removing ash, and re-disposing it in a lined landfill. Some of these projects have likely been influenced by local efforts to dictate the remedy selection process through negotiation or legislation. The fact that some utilities have selected closure-by-removal does not mean this remedy is suitable in all situations.

Sherren Clark, vice president and Solid Waste Services Division leader for the Upper Midwest Region of SCS, said: “In terms of remedy selection, one key difference between MSW and CCR sites has been that for CCR sites, total CCR removal is an option that has been put on the table, and is being implemented at some sites, both small and large. For MSW, total waste removal has very rarely been the chosen approach and has typically been thought of as infeasible unless there were other financial drivers supporting that choice. The typical approaches for MSW sites have focused on source control options, such as an improved cap or enhanced landfill gas collection systems.”

Nelson said that engineers working on plans for CCR disposal could look at what’s been done at MSW sites.

“We might discuss the various approaches to corrective action that are described in some early guidance for MSW work,” Nelson said, pointing to EPA Technical Manual EPA530-R-93-017, which deals with solid waste disposal facility criteria and addresses active remediation, plume containment, and source control. “I believe there are significant guidance and experience we can draw from the MSW arena on the different remedies and how to evaluate them.”

Nelson said that “potential remedies must be evaluated according to the requirements in 40 CFR 257.96 and 257.97,” which are EPA rules outlined in the Electronic Code of Federal Regulations (e-CFR). Part 257 details Criteria for Classification of Solid Waste Disposal Facilities and Practices, including Subpart D-Standards for the Disposal of Coal Combustion Residuals in Landfills and Surface Impoundments, including groundwater monitoring and corrective action. Section 257.96 deals with ACMs. Nelson notes an important distinction with this approach: “One important note is that cost cannot be considered as it is in the similar rules for MSW.”

Jennifer Robb, vice president and project director with SCS’s Solid Waste Services Division in Reston, Virginia, said programs for the disposal of MSW “are pretty much identical to the process a [CCR] site has to go through. The only difference is the constituents they sample the groundwater for. The CCR sites, they’re going to have an issue with metals. The big problem with that is, a lot of the metals are naturally occurring.”

Robb noted that’s where the alternate source demonstration (ASD) comes in, to determine the source of contaminants, and whether a CCR pond or other ash storage facility is responsible for causing levels of contaminants to excess groundwater protection standards.

Evolving Regulatory Landscape

The Environmental Protection Agency (EPA) is proposing a streamlined, efficient federal permitting program for the disposal of coal combustion residuals (CCR) in surface impoundments and landfills, which includes electronic permitting. The new rules are designed to offer utilities more flexibility and provide regulatory clarity.

(1) In August 2019, EPA proposed amendments to CCR regulations that encourage appropriate beneficial re-use and clarity on managing coal ash piles. The proposal would also enhance transparency by making facility information more readily available to the public.

(2) A November 4, 2019, proposal establishes August 2020 as the date for utilities to stop receipt of waste in affected impoundments. It gives utilities the ability to demonstrate the need to develop new, environmentally protective waste disposal technology subject to EPA approval.

(3) On December 19, 2019, EPA proposed a federal permitting program for coal ash disposal units. The proposal includes requirements for federal CCR permit applications, content, and modification, as well as procedural requirements. EPA would implement the permit program at CCR units in states that have not submitted their own CCR permit program for approval. EPA already accepted and approved state permitting programs in Oklahoma and Georgia and is working with others to develop their programs. On December 16, 2019, the EPA Administrator signed a Federal Register notice approving Georgia’s state permit program for the management of CCR.

The November proposal addresses the deadline to stop accepting waste for unlined surface impoundments managing coal ash. It includes a new date of August 31, 2020, for facilities to stop placing waste into these units and either retrofit them or begin closure. The proposal would allow certain facilities additional time to develop an alternate capacity to manage their waste streams before initiating closure of surface impoundments. It would also re-classify clay-lined surface impoundments from “lined” to “unlined,” which means that clay-lined impoundments would have to be retrofitted or closed. Under the proposal, all unlined units would have to be retrofitted or close, not just those that detect groundwater contamination above regulatory levels.

The 60-day comment period on the November proposal closes January 31, 2020. The EPA will conduct a virtual public hearing about the proposed rule on January 7, 2020, at 9 a.m. Eastern Time. Register for the meeting to learn more. A 60-day comment period for the proposed federal permitting program will begin once the rule is published in the Federal Register.

This blog series highlighting the experience and expertise of SCS Engineers staff will continue with a look at examples of remedies for coal ash disposal and storage. If you have questions, contact the authors by selecting one of their names, or email us at service@scsengineers.com.

 

 

 

 

 

Posted by Diane Samuels at 6:04 am
Tag Archives: CCR

Solar Ready CCR Site Closures Help Energy Companies Move Toward a Sustainable Future

October 17, 2019

Solar Ready CCR Site Closures Help Energy Companies Move Toward a Sustainable Future

Electricity is the one big energy source that can be free of carbon emissions. You can make it from the sun. You can make it from the wind. Tap the heat of the Earth, hydropower. While all utilities are moving in a sustainable, environmentally friendly direction, Aliant Energy stands out for making progress and keeping rates reasonable for consumers.

At the recent USWAG Workshop on Decommissioning, Repurposing & Expansion of Utility Assets held October 2019, Eric Nelson presented on the opportunities for solar generation at closed CCR sites and provided an overview of civil and geotechnical considerations when redeveloping closed sites as solar generating assets. His presentation demonstrated these considerations through the use of a case study.

SCS Engineers has assisted Alliant Energy with the design and/or construction of multiple coal combustion residual (CCR) surface impoundment closures. Two of the completed closures are the former Rock River Generating Station in Beloit, Wisconsin, and the M.L. Kapp Generating Station in Clinton, Iowa.

Both sites were closed by incorporating Alliant Energy’s vision to create “solar ready” sites. The Rock River site is now home to just over 2 megawatts (MW) of solar photovoltaic (PV) generating capacity, which was developed on the footprint of the now-closed on-site landfill and ash ponds. Although no solar assets have been developed at the site, the M.L. Kapp ash pond closure represents another opportunity for Alliant Energy to repurpose a closed ash pond for clean power.

Two additional closure designs are in process that incorporates similar elements, making them available for future solar generating asset development.

For more information visit SCS Engineers

Eric J. Nelson, PE, is a Vice President of SCS Engineers and one of our National Experts for Electric Utilities. He is an experienced engineer and hydrogeologist.

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: CCR

Unique Approaches to Bridging CCR State and Federal Regulatory Gaps

June 24, 2019

When the Federal Coal Combustion Residual (CCR) rule went into effect in 2015, it was a new regulatory layer on top of a widely varying landscape of state regulations affecting CCR management in impoundments and landfills. Some states already had significant regulations on the books for CCR impoundments and/or landfills, while others did not.

Where state regulations existed, they varied widely from state to state. While a few states have moved toward closing the gap between state and Federal CCR requirements, many utilities continue to face confusing and conflicting requirements coming from different regulatory programs as they move ahead with managing their CCR facilities.

In her paper entitled State vs Federal CCR Rule Regulations: Comparisons and Impacts, Nicole Kron shares state-versus-federal regulatory challenges utilities have encountered during landfill design and management, impoundment closure, and groundwater monitoring and reporting since the implementation of the Federal CCR rule. For example, some sites have completely distinct groundwater monitoring programs under state-versus-federal rules, with different well locations, well depths, and monitoring parameters for the same facility. She highlights unique approaches to bridging regulatory gaps and resolving regulatory conflicts between state and Federal CCR requirements. Ms. Kron also provides insights gained on the long-term potential for regulatory resolution of these issues based on discussions with state regulators in multiple states.

SCS Engineers Hydrogeologist Nicole Kron, recently finished her second session of Skype a Scientist, a program in which she Skypes with classrooms and talks to kids about her work as a professional geologist and her journey to become a scientist.

About the Author: Nicole Kron has nearly a decade of experience in the environmental consulting field. Her experiences focus on groundwater quality analysis of sites contaminated with coal gasification byproducts, coal combustion byproducts, chlorinated solvents, petroleum products, metals, and PCBs. Her experience includes managing team task coordination, groundwater modeling, and statistical analysis of CCP/CCR sites. She is experienced in planning and performing soil and groundwater contamination investigations, air monitoring, well design and installation, and soil and groundwater sampling.

 

 

 

Posted by Diane Samuels at 6:03 am
Tag Archives: CCR

Minimize CCR Landfill Leachate and Contact Water Management – EUEC 2019

January 24, 2019

 

EUEC 2019

 

At EUEC 2019 learn how SCS can minimize leachate and contact water management at coal combustion residual (CCR) landfills using good design, physical controls, and operational practices.

Through this SCS presentation of case studies, you will learn how to assess leachate and contact water management issues and implement techniques to minimize leachate and contact water management at your landfill.

Leachate management and contact water management at CCR landfills can be expensive, cause operational headaches, and divert valuable resources from other critical plant needs. Our presentation will provide you with useful tools to ensure your landfill is designed and operated to effectively reduce leachate and contact water and alleviate operator stress. We will present case studies that highlight how design features, physical controls, and operational practices have effectively decreased leachate and contact water management at CCR landfills.

2019 EUEC in San Diego, February 25-17, 2019. Conference details here.

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: CCR

How Future Use Guides Ash Pond Closure Strategies at EUEC 2019

January 22, 2019

 

EUEC 2019

 

Even the simplest impoundment closures come with design challenges. It is a challenge to navigate project constraints, whether technical, regulatory, or financial, to design and implement an effective closure strategy. Cost often helps to determine the “balance” between project constraints when the future end use of a closed CCR surface impoundment or the property it occupies is undefined. When a post-closure end use is defined, finding balance among project constraints to best serve that future use provides rewarding challenges.

SCS Engineers has navigated this balancing act on impoundment closure projects during generating facility decommissioning. Through a presentation of case studies, you can learn how this team has approached ash pond closure planning and execution where the future use of the impoundment site ranged from undefined to the home of a new solar photovoltaic installation. Examples also include potential future industrial use or property sale.

Case studies will highlight how geotechnical, hydrological, regulatory, or simple physical constraints have influenced the design and implementation of CCR surface impoundment closures.

EUEC 2019 in San Diego, February 25-27, 2019.  Conference details here.

 

Posted by Diane Samuels at 10:40 am
Tag Archives: CCR

Geochemical Evaluation for Scale Reduction of Coal Combustion Residuals Leachate in Class I UIC

January 14, 2019

Downhole scaling of organic compounds presents challenges in Class I disposal wells. Once chemical and physical conditions drive biological growth and mineral precipitation, the resulting downhole scale must be confronted with expensive workovers, stimulations, or even plugging and abandonment. In one Midwest case study, an electric utility is battling ferric, carbonate, and sulfate precipitate driven by fluctuating pH in its coal combustion residuals (CCR) leachate. Using a variety of geochemical models, we are taking a proactive approach to eliminate expensive fixes by simulating the saturation indices of key mineral species under defined parameters that drive the formation of downhole precipitate under temperature and pressure.

Using a variety of chemical equilibrium models such as PHREEQC, MINTEQ, WATEQ4F, and Geochemist’s Workbench, conceptual scenarios are run at the surface and in the mixing zone of the downhole reservoir using site-specific water-quality data, pressures, and temperatures. Each scenario provides anticipated mineral saturation states, used to estimate mass removal or chemical neutralization to prevent downhole precipitation. To mirror the dynamic nature of the CCR leachate water chemistry, modeling will continue as an iterative process whereby we will continue to collect data and run simulations to stay ahead of changes that could affect the downhole well chemistry.

This proactive approach will reduce the potential for downhole scaling to increase operational efficiency, reduce maintenance costs, and extend the life of this Class I well.

Meet Stephanie Hill and the SCS team at the Groundwater Protection Council’s 2019 Underground Injection Control conference. Tuesday, Feb. 26 from 10:30 a.m. – 12:00.

 

Stephanie Hill obtained a Bachelor of Science degree from the University of Texas at Austin in geological sciences with a focus on hydrogeology. She serves clients nationwide with the SCS Engineers team as a senior project manager and oversees the St. Louis area operations. Stephanie’s project experience includes hydrogeological evaluations, liquids management solutions, and Class I injection well permitting, design and operation.

 

 

 

 

 

 

 

Posted by Diane Samuels at 6:00 am
Tag Archives: CCR

Minimize CCR Landfill Leachate and Contact Water Management

December 21, 2018

Learn how to minimize leachate and contact water management at coal combustion residual (CCR) landfills using good design, physical controls, and operational practices.

Through this SCS presentation of case studies, you will learn how to assess leachate and contact water management issues and implement techniques to minimize leachate and contact water management at your landfill.

Leachate management and contact water management at CCR landfills can be expensive, cause operational headaches, and divert valuable resources from other critical plant needs. Our presentation will provide you with useful tools to ensure your landfill is designed and operated to effectively reduce leachate and contact water and alleviate operator stress. We will present case studies that highlight how design features, physical controls, and operational practices have effectively decreased leachate and contact water management at CCR landfills.

2019 EUEC in San Diego, February 25-17, 2019. Conference details here.

Posted by Diane Samuels at 6:00 am
Tag Archives: CCR

Coal Combustion Residuals (CCR) Litigation Outcome

September 19, 2018

A federal appeals court ruled that the Obama administration’s rule to regulate coal ash does not go far enough in some areas. However, the court did not give environmentalists everything they were seeking. The U.S. Court of Appeals for the District of Columbia Circuit’s Aug. 21 decision in the case, Utility Solid Waste Activities Group v. EPA gave neither side all it wanted.

The decision comes as the Trump administration seeks to revise the EPA’s 2015 rule intended to regulate coal combustion residuals (CCR) from coal-fired power plants—one of the largest waste streams in the U.S. In July, the EPA issued a final rule granting more flexibility to industry and states. Both the Obama and Trump administrations have sought to give states the ability to create their own standards, but according to the D.C. Circuit, neither set of rules satisfied the Resource Conservation and Recovery Act–a 1976 law that allows the federal government to regulate solid waste generation, storage and disposal.

In its ruling, the court agreed that the EPA erred when it failed to mandate unlined CCR surface impoundments be closed, and when it exempted inactive impoundments from the regulation. The court also ruled that EPA should not have classified clay-lined impoundments as being lined.

The court also ruled against industry groups. For example, it determined that EPA does have the authority to regulate inactive impoundments and that it did provide enough public notice that it intended to apply aquifer-location criteria to existing impoundments.

The court also found that EPA decision to prohibit certain unencapsulated beneficial uses of CCR in amounts 12,400 tons or greater was arbitrary and remanded that decision to the EPA. The Agency had previously acknowledged the error in setting the 12,400 ton threshold (the threshold using the Agency’s methodology should have been about 75,000 tons).

Several industry publications have provided coverage of the decision and reaction from industry leaders, including E&E News, APPA, Utility Dive,  Engineering News Record, and Courthouse News Service.

 

For questions or more information, please contact SCS Engineers’ staff.

 

 

 

 

 

 

 

Posted by Diane Samuels at 10:14 am
SCS Address

Corporate Headquarters

3900 Kilroy Airport Way Ste 100
Long Beach, CA 90806-6816

Telephone

1 (800) 767-4727
1 (562) 427-0805 | FAX
service@scsengineers.com

Required Posting