coal ash

May 18, 2017

WOCA 2017 Abstracts from SCS Engineers

A variety of CCB/CCP related topics guaranteed to enhance your knowledge. Click the title to read or share these papers.

Jeff Marshall – Mitigating Hydrogen Sulfide Issues at Coal Combustion Residuals and Municipal Solid Waste Co-disposal Sites – Learn about the biological, chemical and physical conditions necessary for FGD decomposition and hydrogen sulfide generation. Marshall will explore technologies that remove and treat hydrogen sulfide from landfill gas and present recommendations for reducing the potential for FGD decomposition at co-disposal facilities.

Eric-NelsonEric Nelson and Lindsay Motl – Working Through Location Restrictions to Expand the Ottumwa Midland Landfill – The final Coal Combustion Residual (CCR) rule introduces new challenges for companies developing new landfills or expanding existing sites. Join us to learn how Alliant Energy overcame these challenges and expanded the Ottumwa Midland Landfill (OML) to accommodate increased byproduct disposal rates from new emission control projects.

Steve Lamb and Floyd Cotter  – Selecting the Right Closure Cap Option for Your Surface Impoundment or CCR Landfill – Alternative capping options have recently emerged in the industry, such as exposed geomembrane liners or synthetic turf/geomembrane liner systems. Some of these alternative capping options have many advantages over their traditional counterparts. These experts describe the advantages and disadvantages of alternative capping options.

Learn more here.

Posted by Diane Samuels at 6:00 am

April 11, 2017

Alliant Energy wanted to consolidate coal combustion residuals waste at its Ottumwa Midland Landfill in Ottumwa, Iowa, but the site was quickly running out of capacity. To create a sustainable, long-lasting landfill with the capacity to support its operations for the next 25 years, Alliant carefully assessed how to best use the available land at the site.

Learn how Alliant Energy worked with SCS Engineers achieving its vision and is now in a position to build on its success.

Client Profile – Alliant Energy


Posted by Diane Samuels at 3:00 am

January 3, 2017

On Friday, Dec. 16, 2016, President Obama signed The Water Infrastructure Improvements for the Nation Act or the “WIIN Act.” Section 2301 of the WIIN Act allows states to establish permit programs to regulate the disposal of coal combustion residuals (CCR) units in lieu of the Environmental Protection Agency’s (EPA) CCR regulations and published at 40 CFR 257, Subpart D, also known as the federal CCR rule, that were effective as of October 19, 2015.

Under the federal CCR rule, enforcement has been through citizen suits brought under Section 7002 of the Resource Conservation and Recovery Act (RCRA). Following WIIN, for CCR disposal facilities operating under an approved permit program, citizen enforcement will be replaced by more traditional state and federal enforcement authorities. It will take time for states to apply for permit authority and to issue permits, and in the meantime the federal CCR rule will continue to be enforced by citizen suits, and utilities will be subject to potentially conflicting interpretations of what is required to comply at a given facility.

Other CCR-related highlights from the WIIN Act include:

  • EPA has not more than 180 days to approve in whole or in part a state’s permit program that complies with the WIIN Act’s requirements.
  • The proposed state programs will be subject to public notice and public comment within EPA’s 180-day approval timeframe.
  • State requirements may differ from those in 40 CFR 257, Subpart D, but only if EPA determines the state requirement are at least as protective as the federal CCR rule.
  • EPA must review previously approved state programs (1) at least every 12 years, (2) within 3 years of revising the federal CCR rule, (3) within 1 year of a “significant” unauthorized release from a CCR unit in the state, or (4) if a state requests that EPA review another state’s program with the claim that a CCR unit in another state is, or is likely to, impact their soil, groundwater, or surface water.
  • To the extent that Congress appropriates funds to do so, EPA must implement a permit program in states that elect not to pursue their own program or have lost their approved status. If funds are not provided by Congress, the federal CCR rule will be enforced through citizen lawsuits in the non-participating state.
  • EPA can now enforce the federal CCR rule under RCRA Sections 3007 and 3008 in states without an EPA-approved permit program. The EPA can also enforce the federal CCR rule under RCRA Section 3008 in states with approved permit programs with some additional considerations.

The WIIN Act that was passed by the U.S. Congress on Dec. 10, 2016, is based on CCR legislation that has been introduced in the House of Representatives and Senate in various forms over the past 6 years with the support of many in the utility industry. The WIIN Act has been lauded by the U.S. Senate Committee on Environment and Public Works and utility groups alike.

For example:

“This new permitting authority fixes the main problems with the recent coal ash regulation issued by the Environmental Protection Agency, by removing citizen suits as the sole means of enforcement and allowing states to tailor permit requirements on a case-by-case basis.”

Inhofe, Capito, Manchin, Hoeven Praise Inclusion of Coal Ash Provision in Bicameral, Bipartisan WIIN Deal

“The coal ash language will ensure that states have the authority and flexibility they need to regulate coal ash while protecting the environment as much as the current EPA coal combustion residuals rule,” said APPA Vice President of Government Relations and Counsel Desmarie Waterhouse.

Coal Ash Language Backed by APPA Is Headed to President’s Desk

“…these legislative provisions will enable states to be more involved in the permitting process for the closure of basins.”

EII Applauds Passage of the Water Infrastructure Improvements for the Nation Act

“The bill also injects greatly needed certainty into the regulation of coal ash by giving states clear permitting and enforcement authority and reducing litigation, while providing for its continued beneficial use.”

America’s Electric Co-ops Cheer House Passage of Water Resources Bill with Critical Coal Ash Provisions

SCS Engineers will continue to track the WIIN Act and provide you with updates as states consider and make known their approach to developing a CCR permit program, or not.

For questions about the Act or more information, please contact:

Mike McLaughlin, PE, Senior Vice President
Eric Nelson, PE, Vice President
Steve Lamb, PE, Vice President
Kevin Yard, PE, Vice President

Or contact your local SCS Engineers office.

Posted by Diane Samuels at 3:00 am

June 17, 2016

Jeff Marshall, PE, SCS Engineers will be presenting the topic of Hydrogen Sulfide Issues at CCR and MSW Co-Disposal Sites during the EREF and NWRA sponsored Coal Ash Management Forum in July.

The co-disposal of municipal solid waste and coal combustion residuals – particularly flue gas desulfurization (FGD) material – poses a significant concern regarding the generation of hydrogen sulfide gas.   Hydrogen sulfide has an exceptionally low odor threshold, and can pose serious health concerns at higher concentrations.  This presentation will identify the biological, chemical and physical conditions necessary for FGD decomposition and hydrogen sulfide generation.   Recommendations for reducing the potential for FGD decomposition at co-disposal facilities will be presented.  Technologies for the removal and treatment of hydrogen sulfide from landfill gas will also be addressed.

Jeff Marshall, PE, is a Vice President of SCS Engineers and the Practice Leader for Environmental Services in the Mid-Atlantic region. He also serves as the SCS National Expert for Innovative Technologies. He has a diversified background in environmental engineering and management, with emphasis on the chemical and human health aspects of hazardous materials and wastes. Mr. Marshall’s experience with hydrogen sulfide, odors, sulfate decomposition in landfills, and ash issues includes scores of projects dating back to the 1980s.

contact Jeff Marshall.

SCS Coal Combustion Residual Services



Posted by Diane Samuels at 6:00 am

May 29, 2015

by Mike McLaughlin, P.E.

Senior Vice President
Senior Vice President

Coal combustion residuals (CCR) are one of the nation’s largest industrial waste streams, with more than 100 million tons produced annually. Roughly 40 percent of CCR produced is used beneficially, with the remainder disposed in landfills and surface impoundments.

Public and private waste management facilities will have new customers, as utilities that formerly operated their own disposal facilities seek reliable offsite disposal capacity. The cost of managing CCR is going up—EPA estimates the annual costs of its new CCR standards will be between $500 million and $750 million. Other estimates are as high as $2 billion.

However, before accepting CCR materials, MSWLFs should make sure they have modified procedures and otherwise accounted for the unique characteristics of CCR. CCR can have high sulfur content (on the order of 10,000 to 40,000 ppm), and under the right circumstances sulfur compounds can form hydrogen sulfide if CCR is mixed with MSW. To the extent high-sulfur wastes are disposed under conditions that can produce hydrogen sulfide, those conditions should either be controlled (or avoided), or appropriate precautions taken to manage the resulting hydrogen sulfide gas in gas collection and other systems.

There could be other reasons for segregating CCR. For example, placing CCR in a monofill areas might increase the potential for later beneficial use, especially if the materials can be kept dry. Moisture content is a critical factor affecting CCR use in pozzolanic cements, but not all ash materials are suitable for pozzolanic cement in any case. CCR also can affect structural stability of fill mass, operation of gas and leachate collection systems (e.g., through clogging with fines), and dust generation.


Read the entire Technical Bulletin by clicking here.

Posted by Diane Samuels at 11:00 pm