The Energy, Utility & Environmental Conference speaker series continues with virtual live and on-demand presentations throughout 2021.
Attend ten live streaming monthly conferences from March through December 2021 featuring 300 speakers and over 70 virtual exhibit booths with live networking & marketing. Professionals from SCS Engineers are presenters at several of these sessions.
Conference 7 takes place October 11-12, 2021 and explores Coal Ash, ELG, CCR, and FGD.
New Chicago office location at 40 Shuman Boulevard, Suite 216, Naperville, IL 60563
SCS Engineers continues expanding its environmental team in its Chicago, Illinois office to meet environmental engineering and consulting needs focusing on waste management and the needs of the electric utilities. Driving demands are industries and municipalities seeking to reduce their environmental footprint while providing essential services and products.
Leading the Chicagoland team, Professional Engineer and Professional Geologist Scott Knoepke. Knoepke serves clients needing remediation and site redevelopment. This includes commercial dry cleaners, retail petroleum sites, and heavy industries such as steel, rail, coal, mining, manufacturing, metal cutting, and plating.
Meet the Crew!
Richard Southorn, PE, PG, with 20 years of experience, joins Knoepke supporting solid waste and electric utility sectors. Southorn began his career in the field performing CQA oversight, environmental monitoring, and soil core/rock core logging at landfill sites. He moved into landfill design and modeling, primarily to support landfill expansion projects. Richard has extensive experience with site layouts, geotechnical stability, stormwater management, and leachate generation analyses.
Brett Miller is a Senior Designer with over 20 years of experience and proficiency in AutoCAD Civil 3D and Maya. Brett is capable of any production drafting and is highly skilled in understanding 3D space. This helps him support designs that fit into site-specific, real-world environments. Brett also creates 3D models and animations that illustrate the benefits of a design to our clients.
Niko Villanueva, PE, joins SCS with eight years of experience. Niko provides engineering and drafting support and is experienced in designing various landfill systems such as stormwater management, leachate and gas control, and foundation analysis. He has also prepared cost estimates and construction bid quantities for various projects and construction quality assurance services at multiple facilities.
Meet Spencer LaBelle, with six years of experience. Spencer provides solutions for stormwater-related projects, including stormwater management system design, permitting, and compliance. He provides a diverse portfolio of clients and industries with stormwater-related services and environmental compliance.
Zack Christ, PE, comes to SCS with 15 years of experience in solid waste and CCR landfill sectors. Zack has experience performing CQA oversight and CQA management of landfill final cover, base liner, and GCCS; environmental monitoring; and logging soil borings. He also has extensive landfill design and CAD experience in developing landfill siting and permitting application projects. Zack’s areas of expertise include geotechnical analyses, stormwater management, leachate management design, GCCS design, and cost estimating.
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends. We publish these on our website.
Our most recent Bulletin summarizes and updates the TCEQ’S New Rules Implementing Compliance and Registration Requirements for Coal Combustion Residuals (CCR) Management. In addition, this Bulletin covers TCEQ’s development of a program for implementing the Federal rules governing CCR facilities in Texas. While TCEQ’s CCR program needs to be as protective as the federal CCR rules, there are important distinctions in Chapter 352.
SCS’ Texas-based professionals are experts on TCEQ’s new program for registering coal combustion residue (CCR) sites. We are currently working to support multiple sites needing to meet the application deadline. Our engineers and geologists know how to use site-specific design and related technical documents to complete TCEQ’s detailed application for a registration consistent with TCEQ’s new regulatory program.
For additional information on the updated regulations, deadlines, and compliance requirements, contact:
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends. We publish these on our website.
Our most recent Bulletin summarizes and updates the TCEQ’S New Rules Implementing Compliance and Registration Requirements for Coal Combustion Residuals (CCR) Management. In addition, this Bulletin covers TCEQ’s development of a program for implementing the Federal rules governing CCR facilities in Texas. While TCEQ’s CCR program needs to be at least as protective as the federal CCR rules, there are important distinctions in Chapter 352.
SCS’ Texas-based professionals are experts on TCEQ’s new program for registering coal combustion residue (CCR) sites. We are currently working to support multiple sites needing to meet the December application deadline. Our engineers and geologists know how to use site-specific design and related technical documents to complete TCEQ’s detailed application for a registration consistent with TCEQ’s new regulatory program.
For additional information on the updated regulations, deadlines, and compliance requirements, contact:
SCS Engineers is expanding its environmental expertise hiring Richard Southorn, PE and PG, as Project Director in the firm’s St. Charles, Illinois office. Richard is a Professional Engineer in 13 states and a Professional Geologist in Illinois and Delaware. He will support SCS clients with their coal combustion residual (CCR) and municipal solid waste projects, including facilities for composting and the safe management of hazardous wastes.
As a Project Director, he runs teams providing comprehensive services ranging from construction plan development to full-scale design services. His client responsibilities include the coordination and supervision of the project teams made up of professional engineers, geologists, technicians, planners, and support staff.
Richard has expertise in developing site layouts and analyzing designs for multiple landfill facilities. These designs fit within the comprehensive environmental services landfill operators need to manage these complex, integrated systems. Richard’s design approach for landfill infrastructure integrates the elements that all play a role in environmental due diligence, including the landfill base and final cover liner systems, leachate extraction and cleanout systems, landfill gas control systems, and stormwater management controls.
As a licensed Professional Geologist, Southorn also oversees geotechnical stability evaluations, stormwater modeling, and the design and evaluation of landfill gas systems that minimize greenhouse gases. He has overseen many hydrogeological investigations that characterize subsurface stratigraphy, hydrology and hydrogeology, protecting groundwater for safer and more efficient facilities.
As with all SCS Engineers employee-owners, Richard engages in industry associations and his community. Learn about Richard Southorn and how SCSs’ work protects all citizens.
About SCS Engineers
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver services and products. For information about SCS, watch a documentary, or follow us on your favorite social media. You can reach us at .
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends who have signed up to receive them. We also publish these on our website at https://www.scsengineers.com/publications/technical-bulletins/.
Our most recent Bulletin entitled EPA Seeks Feedback On Inactive Surface Impoundments at Inactive Electric Utilities summarizes the EPA’s request for comments and information pertaining to inactive impoundments at inactive facilities.
Operators and owners who may be affected by forthcoming decisions around inactive CCR surface impoundments include electric utilities and independent power producers who generate CCR within the North American Industry Classification System (NAICS) code 221112. Though the EPA states “other types of entities … could also be regulated” and advises those wanting to confirm if the regulation applies to them to read the applicability criteria and comment. Landowners with a legacy surface impoundment on their property purchased from a utility will want to review the proposed definitions closely.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars for our clients.
Visit our website for more information.
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:
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.
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.
“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 .
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.
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.
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.
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.