1. 2015 Coal Handling and Storage Conference
CCR & ELG Compliance Strategies for Utilities – Managing Risk
Michael Roush, PE
Patricia M. Scroggin, PE
October 7, 2015

2. Coal Combustion Residuals (CCR)

3. CCR Rule Overview
Fly ash
Bottom Ash
Boiler Slag
FGD byproducts
Federal Register published version on Friday, April 17th
Compliance dates triggered by published date (effective October 19th, 2015)
Federal Minimum Standard – States can be more restrictive
CCR is defined as fly and bottom ash, boiler slag or FGD materials
Beneficial uses defined/unencapsulated uses discouraged

4. CCR Rule Overview Publish Documents on CCR website
Citizen Suit Authority
Rule does not apply to:
Landfills no longer receiving CCR by October 19, 2015
“Closed” CCR impoundments
Inactive ponds that are closed by April 17, 2018
CCR units at facilities no longer generating electricity by October 19, 2015
Non-utility operations (manufacturing, universities, hospitals, etc.)
CCR beneficially used, placed in mines, or disposed in municipal landfills

5. CCR Rule – Key Differences from Proposed Version
Aquifer location restriction (5’ above)
Groundwater schedule extended (1 year to 30 months)
No liner retrofit requirements for existing impoundments
Alternative liners allowed for new facilities/closures
Failure to meet location restrictions or groundwater protection standards requires closure (or retrofit)
Timeframes for closure:
Standard five year closure
Impoundments < 40 acres – up to 7 years
Impoundments > 40 acres – up to 15 years
Inactive ponds – no CCR after effective date/closed before April 2018
Fugitive dust controls required

6. Required Demonstrations & Recordkeeping
Requirement
New CCR Landfills
Existing CCR Landfills
New CCR Ponds
Existing CCR Ponds
Inactive CCR Ponds
Initial Date Required for Facilities1
Locational Restrictions2
Placement Above the Uppermost Aquifer
OCT 2018
Wetlands
Seismic Impact Zones
Fault Areas
Unstable Areas
Design Requirements
Composite Liner
OCT 2016
Leachate Collection & Removal System
Prior to Initial Receipt
Groundwater Monitoring
OCT 2017
1 Date for new facilities generally required before initial receipt of CCR materials or within 6 months of sampling initiation.
2 If location, groundwater or safety criteria not satisfied, ponds must cease receiving CCR within 6 months & begin closure process.

7. Required Demonstrations & Recordkeeping
Requirement
New CCR Landfills
Existing CCR Landfills
New CCR Ponds
Existing CCR Ponds
Inactive CCR Ponds
Initial Date Required for Facilities1
Structural Integrity Criteria
Marker
DEC. 2015
Hazard Potential Classification Assessments
OCT 2016
Emergency Action Plan
APR. 2017
History of construction3
OCT. 2016
Construction Plan3
Prior to Initial Receipt
Structural Stability Assessments3
Safety Factor Assessments2,3
Weekly Inspections
OCT. 2015
Annual Inspections 3
JAN. 2016
1 Date for new facilities generally required before initial receipt of CCR materials or within 6 months of sampling initiation.
2 If location, groundwater or safety criteria not satisfied, ponds must cease receiving CCR within 6 months & begin closure process.
3 Only required for ponds with height of 20 ft. or more: or with height of 5 ft. or more and volume > 20 acre-ft.

8. Required Demonstrations & Recordkeeping
Requirement
New CCR Landfills
Existing CCR Landfills
New CCR Ponds
Existing CCR Ponds
Inactive CCR Ponds1
Initial Date Required for Facilities2
Other
Fugitive Dust Controls
OCT. 2015
Run on, Run off Controls
OCT. 2016
Hydrologic & Hydraulic Capacity Requirements
Closure Requirements
Post Closure Care3
1 Inactive CCR ponds do not receive CCR after Oct. 2015, still contain water/CCR after Oct must complete closure by Apr Intent to close and closure plan must be submitted by Dec
2 Date for new facilities generally required before initial receipt of CCR materials or within 6 months of sampling initiation.
3 Does not apply to CCR ponds that have closed by removing all CCR materials and have verified groundwater not contaminated.

9. Immediate Reporting Efforts
October
Initiate Weekly Inspections
Dust Control Plans
“Containerize” CCR Piles
December
Closure Plans for Inactive Ponds
Install markers at impoundment sites
January 2016
Initiate Annual Inspections
Other
Develop Overall Compliance Strategy
Design Groundwater Monitoring
– 8 samples by October 2017
Site Surveys
Items for overall strategy:
Closure Plans for all CCR Facilities – Begin conceptual studies to identify preferred overall site compliance plan/schedule
Clean closure vs Cap in place - cost estimates/selection
Ash Handling Conversions – review options, costs, etc
Alternative CCR disposal – preliminary siting and design for landfills and/or ponds
Survey for Run-on/Runoff Control and Hydraulic Capacity Assessments – Fall 2015, modifications designed and in place by Aug 2016

10. Critical CCR Concepts
What triggers a pond closure?

11. CCR Rule – Triggers for Pond Closure
Three triggers, closure begins within 6 months after
Structural Integrity Criteria/Safety Factor Assessments
18 months/October 2016
Groundwater contamination from unlined ponds
30 months/October 2017 with first annual report due January 2018
Ponds with one of the following liners would not be subject to closure at this date:
2 feet of compacted soil with a hydraulic conductivity < 1 x 10-7 cm/sec
A composite liner (60-mil HDPE on top of specified soil layer)
An alternative composite liner that meets this criteria
Liner Retrofit is also an option
Failure to meet location restrictions
42 months/October 2018

12. Implementing a Holistic Approach
CCR burden is bigger than it may appear
Ponds are typically key to overall plant water balance
Overlap between ELG/CCR & State Water Quality Criteria
Potential Projects Involved:
Water Balance Optimization
Groundwater Monitoring/Remediation
Ash Handling Conversions
Wastewater Treatment Systems
New Process Ponds
New Landfills
Pond Closures

13. Effluent Limitations Guidelines (ELG)

14. Basics of the ELG Rule Legacy Wastewater – not applicable
Issued September 30th, 2015
Rule in effect 60 days after entered into Federal Register
50 MW and larger coal units – all electric utilities
“An establishment whose generation of electricity is the predominant source of revenue or principal reason for operation”
Legacy Wastewater – not applicable
First permit applicable November 1st, 2018
“as soon as possible”
Absolute last date for compliance December 31st, 2023
Regardless of administratively renewed permits
Rolls out in NPDES permit

15. Rule Definitions Bottom Ash: FGD Wastewater: Ash and slag Under boiler
Blowdown/filtrate/FGD gypsum wash water etc.
Not: Drains/washdown sumps, scrubber/equipment washdown/cleaning

16. Options Considered by EPA

17. Numeric Limits Set by Stream in Rule

18. FGD Wastewater Treatment Sample Flow Diagram
Text

19. Rule Concerns Anti-circumvention in final rule
Zero discharge and applicability
Exception:
Bottom and fly ash transport water used as Scrubber makeup
Internal Monitoring Points on FGD wastewater vs. Common Outfall with reduced concentrations of regulated constituents
Existing installed BAT technologies may need to be upgraded
Trucking FGD wastewater offsite
Compliance still required

20. Volunteer Clause Applies to FGD wastewater only
Thermal evaporation
Distillate can be discharged through NPDES permit
Compliance can be delayed to December 31st, 2023
Must indicate in writing to permitting authority PRIOR to next permit issuance

21. Tips on Risk Management under CCR and ELG
Holistic approach towards all regulations
Get started early
Market conditions
Define flows and quality
Reduce flows if possible
Legal should be involved to address interpretations where rule unclear
Groundwater Monitoring

22. QUESTIONS?
Patricia Scroggin, P.E. Sr. Water/Wastewater Consultant Burns & McDonnell
Michael Roush, P.E. CCR Handling Specialist Burns & McDonnell