coal combustion product (ccp) management …...by: mark d. rokoff, pe national practice leader...

By: Mark D. Rokoff, PE

National Practice Leader – CCP Management

URS Corporation, Cleveland Ohio

December 2009

Coal Combustion Product (CCP) Management –

Weathering the Storm of Change

Important Changes in CCP Management Certain to Impact

the Power Industry

Weathering the Storm of Change –Overview

• Background on Ash

Management

• Status of Current Regulations

• Status of Beneficial Recycling

of CCPs

• Changing Events

• Review of Pending Regulatory

Changes

• Recommendations to Prepare

for the Change

Before the Storm – Regulations

• All aspects of CCP management performed by the states - No federal programs in place

• 1980 Bevill Amendment – CCP not hazardous waste!

– the „Bevill exclusion‟ excludes CCPs from regulation as hazardous waste under Subtitle C

– This exclusion held pending completion of reporting to Congress (still pending)

• 1993 report– Subtitle D designation upheld from Bevill Amendment

• 2000 report– Final Rule in which the agency concluded that these materials are non hazardous

(maintains exemption); also the report calls for federal guidelines for disposal and reuse

• 2002 report– EPA sponsored beneficial use summits focused on barriers to utilization

of CCP‟s within the states…Beneficial reuse (or recycling) is now on the rise.

We have seen similar “storms” in the past.

Before the Storm – Beneficial Recycling

• Types of Beneficial Recycling:– Ready-mix concrete (*dependent on quality)

• Portland cement substitute

• Additive for high strength concrete mixtures

– Feedstock for cement kilns

– Structural fill and

waste stabilization

– Flowable fill

– Mine reclamation

– Road construction

– Agriculture

– Cosmetics

Other Beneficial Reuse projects have resulted in environmental concerns and have clouded the success of the industry.

• Federal Regulations for Beneficial Reuse have been proposed… Nothing formal has been completed

• Several states responded by generating their own regulations

Approaching Storm - Lightening Strikes

January 9, 2009

- Widows Creek Fossil Plant Gypsum Pond

• 10,000 gallons of slurry spilled

• Water and gypsum flowed into the settling pond, which filled to capacity and then overflowed after a cap dislodged from a 30-inch standpipe.

• Some material overflowed into Widows Creek, although most of the gypsum remained in thesettling pond.

December 22, 2008

- TVA Failure at Kingston

– The largest fly ash release in United States history.

– An ash dike ruptured at an 84-acre solid waste containment area

– 5.4 million cubic yards of fly ash sludge into the Emory River and surrounding land.

– Rains flushed an undetermined amount of ash into the Clinch River and into the Tennessee River portion of Watts Bar Lake.

– Clean up costs expected to exceed $1 billion.

Weathering the Storm - The First Front

• Politics pushes EPA

– SR 64 - U.S. Senator Barbara Boxer (D-CA)

• Resolution recognizing the need for EPA to end decades of delay and utilize

existing authority under RCRA to comprehensively regulate coal combustion

waste, and the need for the TVA to be a national leader in technological

innovation, low-cost power, and environmental stewardship

– HR 493 – February 2009 - Representative Nick Joe Rahall II (D-WV)

• Direct the Secretary of the Interior to promulgate regulations concerning the

storage and disposal of matter referred to as “other wastes” in the Surface

Mining Control and Reclamation Act of 1977, and for other purposes

• EPA pushes politics

– EPA responds – begins drafting regulations based on Surface Mining

Control and Reclamation Act of 1977 (SMCRA)

– Congress agrees to wait for EPA action and new programs

Weathering the Storm – The Second Front

• March 9, 2009

– EPA sends letters to utility companies requesting information about ash impoundments

• Number of plants = 162

• Number of utility companies = 61

• 48 additional plants identified (second round of letters) - total 210

• Actions moving forward on this program:

– Compile the data and prioritize sites (determine number of impoundments)

– Site visits to assess structural stability (using outside source[s])

• By October 1, 2009 – 38 facility visits and 22 reports published

– Require modifications or corrective measures

• Led to announcement of the 44 (or 49) High Hazard sites

• EPA released collection of ash pond data for 584 impoundments at 219 plants in 35 states and final reports for dam inspection site visits (July through September 2009)

Weathering the Storm - Forecasting Change

• Final federal regulations will come? When?? Dec 2009?

• New federal regulations due December 2009; intended to begin a

comment period

– Draft to OMB early September early October (10/16/09)

• Draft regulations are anticipated to address all areas of CCP

Management – Design, Permitting, Operation, Construction,

Monitoring, Closure, and Post-closure

• Coal Combustion Products becomes…Coal Combustion Residues

(CCR)

• Meanwhile, Politics checking in on EPA – Government

Accountability Office (GAO) Report issued October 30, 2009

1. Number of CCR surface impoundments and locations

2. Identify problems with coal ash storage and how they are being

addressed

3. Define the federal oversight for CCR and issues needing resolution


• Current USEPA approach:

– Revisiting CCP CCR designation

• (leading option) Subtitle C (hazardous waste)

• Subtitle D (solid waste)

• Hybrid Approach #1 (new category)


Approach will target wet storage, unlined facilities, etc. (closure, monitoring,

etc.)

Business as usual will no longer be business as usual!


CCP‟s currently viewed as Subtitle D Non-Hazardous Waste

Many states adopt this as the state minimum

Unlike other Subtitle D wastes (e.g. MSW), no federal minimum

requirements exist for CCPs

Results in regulations which vary significantly from state to state


CCP‟s currently viewed as Subtitle D Non-

Hazardous Waste

Unlike other Subtitle D wastes (e.g. MSW), no

federal minimum requirements exist for CCPs - -

results in regulations which vary significantly from

state to state

• Resource Conservation and Recovery Act

(RCRA) Subtitle C establishes a federal program

to manage hazardous wastes from cradle to

grave.

• Subtitle C includes an enforcement and tracking

component (absent in Subtitle D)

• RCRA Subtitle C designation is leading option

considered for CCPs


• Hybrid Approach #1 (new category); Contingent Subtitle C

– Disposal = hazardous

– Beneficial recycling = nonhazardous

Disposal = hazardous

Beneficial Recycling =

non hazardous

Power plant



Power plant

Wet Storage = hazardous Dry Storage = nonhazardous


• CCP‟s designated as Hazardous Waste?!?

– CCP Materials do not meet the definition of a hazardous material

– Beneficial Recycling market would collapse…

• increase other market costs

• Increase disposal storage

– Approx 40% of 130M tons recycled…now headed to disposal

• Concerns about risk and liability may dictate decisions

– Utility and Regulatory costs increase

• Current programs not equipped / funded

• Schedule delays anticipated


The current U.S. hazardous waste facilities do not have the capacity to

handle, transport, and dispose of more than 130 million tons of CCP

material each year.

21 Hazardous Waste Landfills in US

584 impoundments at 219 plants in

35 states1

1. This only addresses surface impoundments (wet

storage) and not dry storage.


• Next Actions related to Coal Ash…

– Unprecedented lobbying to the OMB by all interested parties!

– Federal Regulations for CCR Management

• December 2009 – Draft rules issued for comment

• 2010 – Comment period

• ??? – Rules promulgated; ??? Adopted by state program

– CCR in Beneficial Reuse Minefilling Application Regulations

• Started earlier, but set aside after December 22, 2008

– US EPA to revise effluent guidelines, including CCR wastewater

discharges (per September 2009 announcement)

• Proposed regulations expected 2012

Weathering the Storm – Preparing for Change

• Review all current CCP Management Practices

– Disposal

– Beneficial Recycling

– Operations

– Inspections

– CCP Response Plan

– Sampling Data

- Corporate standards

- Controlling documents

• Gather and review all records

– Permits and supporting permits (and where there are none)

– Existing facility designs

– Documentation previously gathered during inspections

– Contracts with contractors (operations and sub-consultants)

– Facility classifications

– Identify outstanding compliance issues…and resolve

– Review Inspection Reports

Earthquake Flood1 Normal Stability Piping

Major cracks

Excessive displacement

Significant spalling

Large voids

Horizontal lift leaks

Not designed for EQ

loading in high seismicity

zone Minimum

dynamic FOS<1.0* in

small EQ with AEP less

then 1 in 10 years

TFF < 10-1

AEP

FOS < 1.02*

Base cracked > 50%

Slopes steeper than

0.5H:1V

Problem foundation No

drains

Observed piping along

embankment interface or

foundation

No filter protection

Minor displacement

Minor spalling

Some cracks

Small voids

Moderate freeze/thaw damage

Leakage

TFF < 10-2

AEP

FOS < 1.52*

Base cracked > 33%

Slopes steeper than

0.6H:1V

Foundation defects Drains

plugged

Observed seepage or

deformation along

embankment interface or

foundation with no filter

protection

TFF < 10-4

AEP

Minimum dynamic

FOS>1.1 under MDE Post

EQ FOS < 1.5 without

cohesion

TFF < 10-5

AEP

FOS < 3.02,3

Slopes flatter than

0.8H:1V

Good foundation

Minimum dynamic

FOS>1.3 under MDE Post

EQ FOS > 1.5 without

cohesion

TFF > PMPDF or

Probable Maximum Flood

FOS > 3.02,3

Regular monitoring

Failure Mode F 2.00E-04 1.00E-02 5.00E-04

Life Loss Potential 3 6 0.1

Minor concrete deterioration Age

over 50 years

Minor Leakage

Concrete condition adequate

confirmed by regular inspection

Fully intercepting filter

Effective foundation cutoff

Non erodable foundation

OBSERVATIONS

FAILURE MODES

Minimum dynamic

FOS<1.0* under

Operating Basis

Earthquake (OBE)

TFF < 10-3

AEP

Minimum dynamic

FOS>1.0* under OBE

FOS < 1.1 under

Maximum Design

Earthquake (MDE)

FOS < 2.02

Base cracked

Slopes steeper than

0.7H:1V

Minor Found. Defects

Drains working

No observed seepage but

vertical wall interface with

no filter protection

Partially effective

foundation cutoff wall or

drain

Sloping wall

1E-06

1E-05

1E-04

1E-03

1E-02

1E-01

1E+00

0.01 0.1 1 10 100 1000

(F)

Pro

babi

lity

of fa

ilure

per

yea

r w

ith e

xpec

ted

loss

of l

ife >

LLP

Priority A - Unacceptable risk - action required

immediately within 90 days

Priority C - Diminished need to

reduce risk - subject to ALARP

principle

ANCOLD (2003) Limit of

tolerability for existing dams

Life Loss Potential (LLP)

ANCOLD (2003)

Limit of tolerability for new

dams

RISK PLOT

0

Priority B - Risk must be

reduced within 7 years

in accordance with

priorities

Low

A

Class III

Significant

B

Class II

High

C

Class IHaz

ard

Cla

ssif

icat

ion


• Inspect (and document) existing conditions at CCP facilities

– Identify and prioritize stability, water management, and other issues

– Develop monitoring program(s) and action levels

– Engineer and implement solutions

– Prepare for USEPA site visits and follow-up responses

• Review status of existing CCP facilities and

plan for the future

– Develop contingency disposal plans (alternate

off-site options; initiate contracting)

– Develop emergency response plans

• Communication Matrix (internal, regulatory, public)

• Initial and Follow-up Actions

• General Solutions


• Review status of existing CCP

facilities and plan for the future

(continued)

– Review remaining life in existing

facilities

• Initiate first steps of developing

new facilities (siting, property

acquisitions, investigations,

permitting, etc.)

• Close existing ash impoundments

– Pursue beneficial recycling

markets but cautiously and with

potential alternatives

– Shift plant technology/systems

from wet generation to dry

generation….wet storage to dry

disposal

Diagram 5

Example: Coal Plant Site Ranking in Ohio

Land

Ownership

Permitting

Difficulty

Ash

Disposal

Catastrophi

c Loss

Public

Acceptabilit

y

Environment

al Score

Transmissio

n Congestion

Risk

Water

Availability

Fuel

Flexibility

Engineering

Score

Total Score Ranking

Weight 10 17 5 8 15 8 15 22

Site 10 0 100 100 0 13.0 25 0 40 10.8 23.8 5

Site 250 70 0 100 50 32.4 50 0 100 26.0 58.4 3

Site 375 30 75 0 100 31.4 100 100 85 41.7 73.1 1

Site 40 70 0 100 0 19.9 0 0 0 0.0 19.9 6

Site 550 30 75 100 50 29.4 75 33 0 11.0 40.3 4

Site 6100 100 0 100 100 50.0 100 66 0 17.9 67.9 2

Category Weight 55 45

EngineeringEnvironmental

Criterion

Site Name


• CCP management during this

time of unknown change

– Be proactive

– Plan and prepare

– Be thorough

– Remain informed

– Get involved

By: Mark D. Rokoff, PE

National Practice Leader – CCP Management

URS Corporation, Cleveland Ohio

[email protected]

Coal Combustion Product (CCP) Management –

Weathering the Storm of Change

Important Changes in CCP Management Certain to Impact

the Power Industry

QUESTIONS ???

coal combustion product (ccp) management …...by: mark d. rokoff, pe national practice leader...

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