Webinar on June 26 Will Aid in Your CCR and Effluents Decisions
A high level discussion on coal combustion wastes and liquid effluents will be
based on data published on a new website CCR and Effluents – Continuous
analysis. The purpose is to help coal-fired power plant operators make
decisions about how to meet the proposed CCR and Effluent standards. The
challenge is interdependency. A decision on one aspect changes the options for
another. It is the equivalent to a trip where you have to keep backtracking and
changing course based on what you find at each stop. The equivalent of a GPS
tool would be helpful. This is what has been created with the CCR and
Effluent Global Decisions Positioning System™ (GDPS)
CCR and Effluent Standards GDPS
The proposed effluent guideline rule and the proposed CCR rule have to be viewed
together. Douglas J. Dahlberg PE, Project Associate II at Sargent &
Lundy LLC, in a recent McIlvaine webinar, anticipates a final rule to
classify CCRs under Subtitle D, Resource Conservation and Recovery Act (RCRA),
similar to Municipal Waste. The June 7, 2013 Code of Federal Regulations,
Effluent Limitations Guidelines (ELG) and Standards for the Steam Electric Power
Generating Point Source Category Proposed Rule stated, “reliance on (current)
data… coupled with the ELG proposed requirements could provide strong support
for a conclusion that regulation of CCR disposal under Subtitle D would be
adequate.” Speculation on final regulation publishing timing ranges from
October 2013 to the end of 2014.
Whether your current disposal operation is wet or dry bottom/flyash/FGD
byproducts, above or below grade, permanent disposal or transfer, your basic
choices include:
·
Close and cap your current disposal operation.
·
Transition the existing site to comply with new requirements.
·
Develop a separate new compliant disposal facility.
·
Regardless of whether your existing disposal site is lined, monitored or impacts
groundwater, the best option may be to combine the disposal options.
Doug made a convincing argument that you can maximize the use of your existing
site by depositing the new waste over the one which has already been covered and
capped.
Decision Trees in ELG-CCR GDPS Route Map
ELG
Regulations
CCR
Regulations
Wet
Air Pollution Control
Bottom
Ash Handling
Wastewater
Treatment
Flyash
Handling
The ELG regulations will be issued first and will shape the CCR decisions, so
this is a starting point. However, it may be necessary to review the ELG
regulations in light of any CCR regulatory insights.
1st
Decision Tree Stop: ELG Regulations
With respect to ELG requirements for surface impoundments that are used to
manage CCRs, EPA is considering establishing best management practices (BMPs)
that address impoundment construction, operation and maintenance to prevent
uncontrolled discharges Id. at 34,458. The BMPs that EPA is
considering would require plant operators to conduct periodic inspections of
active and inactive surface impoundments and to take corrective actions where
warranted. Inspections would be conducted every seven days by a person qualified
to recognize specific signs of structural instability and other hazardous
conditions by visual observation and, if applicable, to monitor instrumentation.
Dennis Fink, CH2M HILL outlined the challenges in a previous
McIlvaine hot topic discussion.
Click here for Dennis' presentation at a McIlvaine Hot Topic Hour in 2012.
2nd
Decision Tree Stop: CCR Regulations
Since the close of the comment period on the CCR rule, EPA has received new data
through a 2010 Information Collection Request. EPA now has
facility-specific data from the 495 coal-fired power plants in the U.S. that the
Agency says have the potential to affect its final risk assessment. The
new data reveals that the impoundments and landfills are generally smaller than
the impoundments and landfills included in the assessment to support the
proposed CCR rule. According to EPA, the new data and analyses “may have the
potential to lower the CCR rule risk assessment results by as much as an
order of magnitude.” EPA continues: “If this proves to be the case,
EPA’s current thinking is that, the revised risks, coupled with the ELG
requirements that the Agency may promulgate, and the increased Federal oversight
such requirements could achieve, could provide strong support for a conclusion
that regulation of CCR disposal under RCRA Subtitle D would be adequate.”
So we will be keeping abreast of the latest on these regulations
3rd
Decision Tree Stop: Wet Air Pollution Control
One of the options is utilize natural oxidation instead of forced oxidation FGD.
The soupy sludge encapsulates the heavy metals. When you add lime to this mix
you create a chemically fixed product which is less leachable than gypsum.
So you have to consider the FGD options.
4th
Decision Tree Stop: Bottom Ash Handling
There are various technology solutions to the bottom ash problem Ron Grabowski,
Vice-president Business Development at Clyde Bergemann Power Group
Americas, Inc., Materials Handling Product Division, discussed the
handling of bottom ash in a recent McIlvaine webinar.
He explained all the options including one which eliminates the use of any
water.
1.
Divert the flow of the existing bottom ash slurry piping to new dewatering bins.
2.
Divert the flow of the existing bottom ash slurry piping to a remote submerged
scraper conveyor (RSSC) system (ASHCON™).
3.
Replace the bottom ash hopper system with a submerged scraper conveyor (SSC).
4.
Replace the bottom ash hopper system with a dry ash conveyor (DRYCON™).
One more option is to make a unique by product Dale Timmons, R.G., Business
Development Program Manager at NAES Corporation, discussed the
Circumix Dense Slurry System (DSS) technology in a recent McIlvaine webinar.
NAES Corporation and GEA EGI have teamed to deploy DSS technology
in North America. DSS is a proven and commercially deployed technology that uses
wastewater (including FGD water) to stabilize ash products.
5th
Decision Tree Stop: Wastewater Treatment
There are a number of sources creating to wastewater contamination in a coal
fired power plant. The options include zero liquid water discharge.
Water is purified for re-use and evaporators convert the slurry into a solid
waste.
6th
Decision Tree Stop: Flyash Handling
Sale of flyash is one of the best options, but this is contingent on the coal
type and access to markets. If the solution to the MATS is to add dry
scrubbers or DSI followed by a baghouse, then the flyash is going to be mixed
with calcium sulfate and will not be salable. One option is to mix the flyash,
calcium sufate sludge with about 2 percent of extra lime and create a chemically
fixed disposable product. Gordon Maller of U.R.S. discussed this option in a
recent McIlvaine webinar. His power points are included on the site.
Flyash needs to be transported from the precipitator or baghouse by pneumatic or
mechanical conveying. There are options among the various types of
pneumatic systems as well.
