Coal-fired power plants across the country are continuing to wrestle with the recently promulgated Coal Combustion Residuals (CCR) and Effluent Limitations Guidelines & Standards (ELG) regulations. After all the potential beneficial reuse options have been fully assessed and implemented, your facility will still need prudent and proactive planning to manage CCR and secure availability of CCR geo-environmental containment (landfill) disposal capacity.
Regulations will significantly phase out the long-term use of surface impoundments for CCR management, continuing the shift from wet to dry handling systems. These dry systems are not new to the industry, but can be costly and time-consuming to implement. Generators of dry ash will need to consider permitting and construction timing with respect to new containment needs. States will likely follow existing solid waste management regulations for siting and permitting containment systems, which could take two to several years to confirm a site, prepare a design, receive regulatory approval, construct a facility, and secure an operating permit. This can be further delayed by public processes, which can pose their own challenges.
State-specific requirements and practices will impact project schedules. A containment siting effort will likely include a number of the following tasks relative to determining an approximate timeline. Flexibility in schedule can be achieved by executing some elements simultaneously to reduce the overall time line.
Site Acquisition/Confirmation: (12 – 24 months) Locate a large enough site that meets general set back and separation criteria, balanced with economics of operating and maintaining the facility.
Initial Site Report: (Preparation 2 - 3 months, plus 3 months regulatory review) Prepare an initial site evaluation for specific set back and siting criteria for state agency approval.
Feasibility Report: (Preparation 3 – 6 months, plus 5 months regulatory review) Provide public documents that include detailed design and layout with supporting hydrogeological evaluations and engineering calculations to demonstrate feasibility of the facility to perform while also protecting the environment.
Informational and/or Contested Case Hearings: (2 – 6 months) Move through public processes, engaging advocates and addressing opposition and concerns that may be raised against siting the facility, as needed. This process can take substantially longer depending on opposition to the containment facility.
Plan of Operation Report: (Preparation 3 months, plus 4 months regulatory review) Prepare a detailed phasing plan and operations manual, and closure and long-term care plan for the facility for state agency approval.
Material Borrow Source Investigations and Purchase Agreements: (3 – 6 months) Identify potential sites, evaluate best alternatives, investigate the quantity and quality of the material, and negotiate purchase agreements. Design and permit the borrow site for use and restoration.
Construction Plans and Specifications: (2 months) Develop construction plans and specifications to obtain bids from contractors, clarify scope in the contract, and provide detailed information for construction.
Phase 1 Construction: (2 - 4 months) Construction of infrastructure and ancillary facilities for the containment facility. Document construction in accordance with the approved design. Weather conditions, the size of the facility, and the amount of infrastructure needed will impact construction schedules.
Permit to Operate: (2 months, plus 1-3 months regulatory review) Submit as-built documentation to agency for approval to begin placing CCR.
Construction schedules vary greatly depending on availability of earthen materials (e.g., sand, clay, general fill, and topsoil), manufactured materials (e.g., piping, geomembrane, geotextiles, and geo-composites), and competent contractors. Construction can be greatly impacted by the weather and local construction seasons.
Setback and separation criteria may include specified distances from existing property lines, right-of-ways, potable water wells, wetlands, endangered species habitat, air traffic, depth to bedrock and depth to groundwater, as well as potential line of sight concerns.
Engineering features can address most operational and system structural concerns. Contested case challenges are typically driven by the need for the facility and environmental set back concerns. You will also need to consider the physio-chemical characteristics of your CCR, particularly for surface water control and leachate management systems. Class C (self-cementing) and Class F (pozzolanic) fly ash can generate very different volumes of leachate and chemical profiles.
Like most large capital projects, the most efficient and economical approach includes starting early to obtain the best balance between quality, schedule, and price. The right team can help you plan ahead to not only stay on-schedule and on-budget, but make both work as efficiently as possible.