At the upcoming USWAG CCR Workshop Feb 22-23 in Arlington, VA, Steve Lamb and Floyd Cotter of SCS Engineers will present a session about the advantages and disadvantages of emerging alternative capping options, and how different regulatory agencies are viewing these options.
About this Session: Traditional final cover and capping design for coal combustion residual (CCR) surface impoundments and landfills have included compacted soil liner, geomembrane liner, drainage layer, and a vegetative soil cover. But coal-fired plants oftentimes don’t have the large volumes of soil that it takes to implement these options.
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 advantages include faster installation times, minimal need for soil, improved storm water quality, and reduced maintenance and post-closure costs. For surface impoundments, alternative capping designs can also greatly reduce the amount of disturbance of the existing CCR material within the impoundment.
About Steve Lamb: Steve Lamb, PE provides SCS with over 27 years of experience in solid and hazardous waste management, environmental engineering, civil engineering, hydrology and hydraulics, landfill engineering, remedial design, and regulatory compliance. Mr. Lamb is a Vice President and director of SCS’s Charlotte, NC office.
About Floyd Cotter: Floyd Cotter specializes in solid waste management projects. His project work involves all areas of solid waste management including planning, permitting, transportation, landfill design, construction, and monitoring. Mr. Cotter is also experienced in general civil engineering, construction oversight, environmental site assessments, closure and post-closure plans, and permit and contract document preparation.
The complexity of regulations that govern the disposal of coal combustion residuals (CCR) is growing. We expect the pace of change will also increase based on recent headlines. To help you successfully address these ever-changing regulations and stay focused on serving your customers, SCS Engineers uses our Advice From the Field blog and Technical Bulletins.
Using the SCS Advice blog we recently posted a short overview of the WIIN Act and highlights of how the Act is being received. This is just the start. In the coming weeks and months, SCS Engineers’ staff will bring you timely, relevant updates and interpretations of the WIIN Act and other changing regulations. Most importantly, we’ll recommend what to do next, steps you should consider taking and when to take them so that you’re ready for whatever changes come.
Follow the SCS blog on LinkedIn or Facebook for the latest information about coal combustion residuals regulations, and to participate in the conversation that’s shaping our industry. Or contact us at if you have questions.
SCS periodically prepares Technical Bulletins to highlight items of interest to our clients and friends. These are published on our website. For example, this SCS Technical Bulletin addresses Inactive Surface Impoundments and EPA Direct Final Rules for Disposal of Coal Combustion Residuals from Electric Utilities.
About Eric Nelson, SCS Engineers CCR National Expert
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:
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.”
“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.”
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.
EPA Final Rules for Disposal of Coal Combustion Residuals from Electric Utilities
SCS updated information describing the rules regulating CCR from electric utilities. This bulletin includes compliance details about location, design, operation, closure and post-closure care requirements to avoid a facility considered as an “open dump” subject to citizens’ suit enforcement under RCRA.
by Mike McLaughlin, P.E.
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.
