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TRC's Kent Nilsson discusses the drivers, regulatory requirements and strategies around successful coal ash pond management.
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Are You Prepared to Close Your Ash Ponds?
R. Kent Nilsson, P.E.
Senior Consulting Engineer
TRC Environmental Corporation
Drawbacks of Learning by Trial and Error…
Drivers for Pond Closure
Regulatory requirements
Plant retirements
Changes to facility operations
Environmental liability management
Political/social pressures
Regulatory Requirements
EPA has agreed to take final action on Coal Combustion Residuals (CCR) by December 19, 2014
Revised RCRA Subtitle “D” standards are the most likely outcome
Likely to be implemented at state level
Closure also affected by Effluent Limitation Guidelines (ELGs)
Recent developments may influence outcome
Final rule likely to be litigated
Regulatory Requirements – Ash Ponds
Anticipated RCRA Subtitle “D” requirements:
Rule effective 6 months after promulgation
Ponds not meeting liner requirements must stop accepting waste within 5 years of finalization of rules
Groundwater monitoring required within 1 year after effective date
Ponds must be closed within 2 years of last receiving waste
Strategy
Mapping out a strategic plan must consider the questions:
Close now or later?
Future end use of property?
Close in-place or remove the residuals?
What are the costs?
Strategy
A Generic Decision Matrix
Strategy – Close Now or Later?
Dictated by:
Regulatory framework and its timing
Short and long-term risk profile
Retiring plant or continuing to operate
Changes to facility operating requirements (e.g. wet ash v. dry ash handling)
Costs and funding
Strategy – Close Now or Later?
Closure schedule affected by:
Regulatory requirements/deadlines
Future site use
Pond size
Ash pond assessment and preparation of design and bid package
Regulatory approvals
Strategy – Future End Use of Property?
Retiring plants need to clearly define
Prime redevelopment locations may require stricter clean-up
Site specific conditions (e.g., wetlands)
Ash geotechnical properties
Strategy – Close In-place or Remove the Residuals?
Viable market for pond material?
Long-term obligations?
Long-term environmental liabilities?
Future land use?
Sufficient on-site borrow material?
Construct on-site landfill?
Staffing demands/outside resources?
Political/social pressures?
Cost?
Need a Plan and Schedule
Risk Considerations
Planning for potential risks and liabilities:
Geotechnical evaluation
Environmental assessment (including risk assessment)
Social/political analysis
Landfill/pond closure design
Permitting
Construction engineering
Groundwater Investigation/Remedial Options
Groundwater Investigation – Likely required to ascertain environmental impact of existing unlined
ponds
– Investigation plan should take into account Point of compliance
Constituents of concern
Well placement
Well construction
Sampling protocol
Quality assurance/quality control
Background conditions
Remedial Options – Evaluate as warranted
– Incorporate into closure plan
Closure Considerations
Pond size
Dewatering requirements/methods
Final use considerations
Remediation integration
Constructability concerns
Health and safety
Site configuration constraints
Long-term maintenance
Pond Closure – Health and Safety
Dust control and monitoring
In-place Closure
Pros:
Generally less expensive than relocation to a lined landfill
Approach keeps haul vehicles off of public roads and highways
Proximate to existing facilities
If space-constrained, can be used as landfill base
In-place Closure
Cons:
Perceived “unknowns” in the final storage conditions
Increased social/political opposition to in-place closure, especially in environmentally sensitive areas
In-place Closure
May not be feasible in an environmentally sensitive or recreational area
In-place Closure Solutions
In-place Closure Solutions
In-place Closure Solutions
Pond Closure – Final Use Considerations
Solar farm
Closure by Removal Considerations
Beneficial reuse
Disposal in off-site Subtitle “D” landfill
Disposal in on-site Subtitle “D” landfill
Consolidation with ash in existing lined pond
Closure by Removal
Beneficial reuse opportunities:
Engineered fill*
Stabilized road base
Concrete admixture
Other
* Pending EPA ruling
Removal of Residuals
Beneficial reuse as a road construction material
Closure by Removal
Closure by Removal
Closure by Removal
Closure by Removal– Final Use Considerations
Closure by Removal
Ash dewatering using geotubes
Pond Closure - Constructability
Slope stability
Pond Closure - Constructability
Ash liquefaction
Construction costs
Ash volumes–actual conditions v. designed
Moisture content – don’t pay to haul water
Haul distances – keep them short
Double handling of material
Synthetic construction materials
Long-term monitoring
On-site landfill v. off-site commercial landfill
Leachate management
Questions/Comments?