Elementary Secondary Tertiary / Higher Education Issues Differences.
are Utilities CCR Impacts · design did not intend for it to be a CCR impoundment by definition,...
Transcript of are Utilities CCR Impacts · design did not intend for it to be a CCR impoundment by definition,...
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Impacts o
f CCR
Managem
ent
Audits and
How
Utilities are
Respon
ding
Jason Po
korny, PE
Steve Pu
trich, PE
2015
Wo
rld
of
Co
al A
sh (
WO
CA
) C
on
fere
nce
in N
asvh
ille,
TN
- M
ay 5
-7, 2
015
htt
p:/
/ww
w.f
lyas
h.in
fo/
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2
1Final Rule Highlights
2Ho
w Utilities Have Prep
ared
3Au
dit O
verview & Lessons Learned
4What U
tilities are Doing
Key Po
ints
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Final Rule Highlights
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Final CCR
Rule
•For purpo
ses of th
is presentatio
n, we assume the grou
p has a
gen
eral to
de
tailed un
derstand
ing of th
e Final Rule
•The
Rule is complex and
has layers of interpretation
•Definition
s are key
•The
re are not definitive answers to all site
‐spe
cific sc
enarios
–Legal team sh
ould be integral to
process
–Falls back on
“recognize
d and gene
rally accep
ted good
engineerin
g practice” to
meet the
specified
requ
irements or top
ics that a
re m
ore vague
4
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Site‐Spe
cific Nature of App
licability
•The
truth is, th
ere is no
t one
size fits all or one
right a
nswer –de
pend
s on
utility
risk to
lerance, m
anagem
ent strategies, and
managem
ent/bu
dget
•Spe
cific app
lications to
Rule requ
ire site‐spe
cific inform
ation, so
illustrations/examples, com
men
ts are not app
licable fo
r every site
•For an inform
ed answer, have to look
at site
‐spe
cific inform
ation that will
includ
e site cond
ition
s/siting issue
s:•History
•Geo
technical &
hydrogeology/GW con
ditio
ns,
•Surface water m
anagem
ent con
ditio
ns;
•Interrelationship with
other CCR
units on site;
•Plant o
peratio
nal plans; and
•Interplay/coordinatio
n with
other com
pliance standards
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6
New
CCR Im
poun
dmen
ts, landfills/
land
fill lateral expansio
ns m
ust
demon
strate com
pliance prior to
placing CC
R materials.
Apr 2015
Oct 2015
Oct 2016
Oct 2017
Apr 2018
Oct 2018
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What to Focus o
n Now
•Recon
figuring “Status D
esignatio
ns” of units/site
s
•Potentia
l Causal Trig
gers
–Stability
–Groun
dwater
–Sitin
g
•Internal Team and
Managem
ent
•Ultimately –Ke
eping Your Plant Ope
ratin
g
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How Utilities Have Prep
ared
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Wha
t is the
Spe
ctrum of U
tility
Activity
?
9
•Proa
ctive versus Reactiona
ry•Whe
re do I stand
? How
do I
compa
re to
the indu
stry?
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Level of A
ctivity
Silos
•Tho
se th
at have be
en re
stricted (regulated
vs. de‐regulated)
•Tho
se th
at have moved
slow
–Available Bu
dget
–Limite
d Staff
–Managem
ent h
urdles
–Other Focuses (A
ir, etc)
•Tho
se th
at are aggressive
–De
veloping
internal m
anagem
ent p
rotocols
–Bu
y‐in from
Managem
ent
10
Restricted
Aggressive
Slow
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What R
oadb
locks/Hurdles
are We Seeing?
•Internal Sched
ule, $$ Allocatio
n Und
er‐Bud
geted (fo
r 201
5/16
/17)
•Lack of utility
staff/resources
•Con
flicts w
ith State Permits/Program
s (e.g. we want to close no
w und
er
fede
ral, bu
t state has 12 to 18 mon
th lead
time to app
rove und
er its
perm
itting programs)
•Status D
esignatio
ns of Inactive and Second
ary/Tertiary Pon
ds
•Historic Im
poun
dments –Closed
, Idled
, Inactive
•Misc
onception that entire
state pe
rmitted
land
fill (with
portio
ns not
“existing”) m
eans th
e remaining
footprint n
ot im
pacted
by Ru
le
•Staging
Area Managem
ent –
being “con
tainerize
d”
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Audits Overview and
Lessons Learned
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Type
s of A
udits and
Purpo
se
13Programmatic Aud
its
•Outcome = De
term
ine whe
re to
focus
resources
Detailed Multim
edia Aud
its
•Outcome = Thorou
gh Preparatio
n, Strategy,
and Ab
ility to
Act
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Compliance by
“Definition
”….from
the Bo
ttom
Up or Top
Dow
n, W
hat D
oes that M
ean or Loo
k Like?
3 STEP
S
•1st–Und
erstan
d the Ru
le: What d
oes it say, digest it, apply it
•2nd–Ap
ply the Ru
le:Iden
tify & aud
it for com
pliance ‐Every
know
n or poten
tially kno
wn CC
R un
it [In
ventory/Status
Desig
natio
ns, A
pplicability]
14
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Compliance by
“Definition
”….from
the Bo
ttom
Up or Top
Dow
n, W
hat D
oes that M
ean or Loo
k Like?
•3rd–Strategic Plan
ning
and
Action
Yes–
Status Quo
may be fin
e
No–What d
o we have to
do “To Co
mply”
Maybe
/Never
‐the
answer to
“what if w
e can’t com
ply”, or “if the
cost is to
o high”, or “we do
n’t h
ave en
ough
time”, or “it do
esn’t
mesh with
the rest of o
ur overall CC
R plan”, or if we did “w
e’d
have to
make a dracon
ian change/shu
t‐do
wn”
Alternate and/or Sup
porting Co
mpliance Strategies?
15
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What can
you
do by th
e Effective Da
te?
•De
term
ine what u
nits are exempt/regulated
•An
y po
tential closure triggers you
can
add
ress?
•“Lined
” vs. U
nlined
Impo
undm
ent?
•CC
R Piles v
s. CCR
“Staging Areas”
•Proactive constructio
n or closure activities
•Groun
dwater M
onito
ring Program –Prelim
inary Und
erstanding
•Do
cumen
tatio
n de
velopm
ent / PE certificatio
ns–Web
site and protocols
16
Stability?
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Compliance De
mon
stratio
ns•W
hat to focus o
n:
–First, Du
st Con
trol Plan
•Need to find
metho
d to “e
mplace CC
R as con
ditio
ns” or che
mical dust sup
pressio
n agents?
•May re
quire
time to im
plem
ent o
peratio
nal changes prio
r to Effective Da
te
–Po
tential causal trig
gers
•Structural Integrity
Assessm
ents
–Ab
ility to
Retrofit to
meet FS?
–Otherwise
, a definitive answer to
und
erstand ne
ed fo
r alte
rnative managem
ent (dry conversio
n, new
unit)
•Sitin
g–Need tim
e to develop
alte
rnative path?
–Need tim
e to determine if you can resolve?
17
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Compliance De
mon
stratio
ns•W
hy Early?
–De
velop process for:
•Internal re
view
–Give tim
e for layers o
f internal review/com
ment
–Legal
–Branding
of u
nits
–Nam
ing conventio
ns•External re
view
–Gives te
am buy‐in
that re
sults are correct
–Co
nsisten
cy–Manage level of aggression or con
servatism
–Alternate compliance standards
18
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Internal Ju
stificatio
ns fo
r Exempting Units
•Since Rule is self‐im
plem
entin
g, develop
a basis for w
hy you
are
exem
pting a un
it–“Closed” im
poun
dment
–Inactive Im
poun
dments
–Staging Areas instead
of C
CR Piles
•Don
’t wait for outsid
e EN
GO to
inqu
ire
•Develop
s a com
mon
und
erstanding
internally
–Co
mmon
talking po
ints and
und
erstanding
for a
ll layers of o
rganiza
tion
•Not intend
ed to
be placed
on pu
blic web
site (in
back po
cket)
19
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So W
hat A
re Utilities Doing?
‐Status Designatio
ns‐
Land
fill Expansio
ns‐
Staging Areas
‐Groun
dwater
‐Da
ta M
anagem
ent
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Defin
ing An
Impo
undm
ent’s “Status Designatio
n”•Ha
s it a
lready be
en closed?
•Was it designe
d to re
ceive CC
Rs?
–De
term
ines: C
CR or N
on‐CCR
Impo
undm
ent
•If CC
R Im
poun
dment, do
es it and
/or w
ill it con
tinue
to re
ceive CC
Rs after Effe
ctive Da
te?
–De
term
ines: A
ctive or Inactive CC
R Im
poun
dment
•If Active, is it idled with
capacity
remaining
or p
lans fo
r ben
eficial use?
–De
term
ines: W
hen closure may be triggered
•If Active, doe
s it m
eet the
definition
of an existing lined
impo
undm
ent?
–De
term
ines: Lined
or U
nlined
Existing Im
poun
dment
•If Inactive, do you plan
on closing in 36 mon
ths?
–De
term
ines: W
hich criteria app
ly21
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Second
ary/Tertiary
Pond
s ‐De
signatio
n•A
ssum
e the scen
ario sh
own
•Key Que
stions to
Ask:
–Was th
is po
nd orig
inally designe
d to hold an
accum
ulation of CCR
s?–Do
es it treat, store, or d
ispose of
CCR?
–Do
es it re
ceive sig
nificant
amou
nts o
f CCR
?–Even
if orig
inal design did no
t intend
for it to be
a CCR
im
poun
dment b
y defin
ition
, has it
ever acted
as o
ne?
22
Prim
ary
(Dire
ct Sluice)
Second
ary
Tertiary
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Second
ary/Tertiary Im
poun
dments ‐
Limiting
CCR
Material D
ischarge
•Lon
gest Flow Path for S
ettling
•Hanging
Baffle
s
•Decant S
tructures
23
INTENT?
MODIFY DOWNSTRE
AM
IMPO
UNDMEN
T STATU
S
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Opp
ortunistic Con
struction Activ
ities –
Pond
Recon
figuration
24
ACTIVE
24
ACTIVE
ACTIVE
ACTIVE
ACTIVE
HISTORIC
HISTORIC
ACTIVE
PROPO
SED
INAC
TIVE
INAC
TIVE
PROPO
SED
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Historic “Closed
” vs. Inactive Im
poun
dments
•Need to m
ake de
term
ination if un
it is “closed” or sim
ply “inactive” (m
eaning
it
no longer re
ceives CCR
after Effe
ctive Da
te but still con
tains C
CRs a
nd liqu
ids)
–Is it “breached
and
dew
atered
”? Can
it im
poun
d water (closest definition
to “c
losed”?
Prea
mble Pa
ge 21409
Prea
mble Pa
ge 21343
–If it still has liqu
ids and/or th
e ability to
impo
und liquids, m
ay be considered
“inactive”
instead of “c
losed” and
therefore subject to the regulatio
n
25
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“Strategic” Ve
rtical or H
orizo
ntal Expansio
n?
26
Amen
ded Pe
rmit Expa
nsion
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Entire Perm
itted
Landfill vs. “Existing Land
fill”
27
250 A
cre P
erm
itted
La
ndfil
l10
Pha
ses
Over
60 Y
ears
of
Tota
l Life
Existin
g Footprint
is 25
acres as
of to
day
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Strategic CC
R Land
fill
Horizon
tal Expansio
n
28
Existing
Proposed
Existin
g
Prop
osed
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Tempo
rary Stockpiling
•A tempo
rary stockpile of C
CRs p
laced
on land
at the
plant site in
an
“unp
rotected
manne
r” is con
sidered
to
be a “CC
R Pile”
•The de
finition
of a
“CC
R Pile” is:
–any no
n‐containe
rized
accum
ulation
of so
lid, non
‐flow
ing CC
R that is
placed
on land
. CC
R that is
beneficially used off‐site
is not a CCR
pile.
•“CCR
Pile” = CC
R Land
fill
29
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CCR Piles
•To clarify
the de
finition
, the
EPA
disc
usses its intent of the
term
non
‐containe
rized
on page 21356 of th
e Preamble:
–The use of th
e ph
rase “no
n‐containe
rized
” is no
t inten
ded to re
quire
that all activ
ities occur with
in ta
nks or con
tainment structures, but
merely that sp
ecific measures h
ave be
en ado
pted
to con
trol exposures
to hum
an health
and
the environm
ent.
–This could includ
e placem
ent o
f the
CCR
on an
impe
rvious base such
as asphalt, con
crete, or a
geo
mem
brane; leachate and
run‐off
collection; and
walls or wind barriers.
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“Con
tainerize
d” Staging
Areas
31
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Bene
ficial U
ses
•Coal M
ine Re
clam
ation
•Roadw
ay Activities/Agricultural
•Mining ou
t historic disp
osal activities
32
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Groun
dwater
Mon
itorin
g
33
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Gen
eral Tim
eline –Groun
dwater M
onito
ring
30 M
onths –
Whe
re did th
e tim
e go?
34
Publish Date
Minim
um Recom
men
ded
Sampling Period = 12
Mon
ths
30 months
Effective Date
18 months
CERTIFY
Can you pu
ll some of th
ese activ
ities fo
rward to allow m
ore tim
e for sam
pling and analyses?
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Early
Groun
dwater Analyses
•Groun
dwater Flow Dire
ction and Elevations
•Site
Con
ceptual M
odels
35
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Inform
ation Managem
ent
36
Step
3: R
eview Develop
ed Con
tent & Post M
aterial to Pu
blic Site
Professio
nal Third Party Review
Post to
Pub
lic Portal “Go Live”
Prep
are respon
ses for potentia
l qu
estio
ns
Step
2: C
CR W
ebsite Logistics, Design, Con
tent, Review Criteria
Develop web
site strategy,
implem
entatio
n sc
hedu
le w/ a
ction
items &
respon
sibilitie
s
Review
existing material, identify
othe
r related
pub
lic inform
ation,
Develop requ
ired content p
er plan
for C
CR Com
pliance, PE requ
ired
sign offs
Step
1: D
evelop
CCR
Pub
lic W
ebsite Im
plem
entatio
n & Action Plan
Develop CC
R Strategy & Im
plem
entatio
n Plan
for e
ach
CCR Unit
Determ
ine Ope
ratin
g Re
cord Req
. for each compliance
compo
nent for each affected
unit &
minim
um level of
content req
uired for w
ebsite
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Conclusio
n•P
ublishing
of R
ule has forced utilitie
s to act
•The
re is still time to m
anage risk and fin
d op
portun
ities to
actively
manage assets and
plan
•Gettin
g all critical personn
el (e
ng/enviro
/legal/p
lant/m
anagem
ent) in
the
same room
and
on same path fo
rward is of utm
ost impo
rtance
37
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Impacts o
f CCR
Managem
ent A
udits and
Ho
w Utilities are Respo
nding
JASO
N POKO
RNY, PE
STEV
E PU
TRICH PE
QUESTIONS??
Than
k you