ccr rule: consultant’s perspective 2015 air & waste management association meeting callaway...
TRANSCRIPT
CCR Rule: Consultant’s Perspective2015 Air & Waste Management Association Meeting Callaway Gardens, GAPresented by: Randy Sullivan, Principal & Senior Practice Leader Golder Associates Inc.
Outline
Varied Client Responses State Rules Technologies & Tools
Well established Emerging
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The Path to CCR Compliance- Varied Client Responses
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New and Existing Surface Impoundments
and Lateral Expansions
New and Existing CCR Landfills
and Lateral Expansions
Inactive Surface Impoundments
State requirements may be more stringent.!
State Rules
North Carolina 2014 law
Mandated ash removal at High & Intermediate risk sites
Decision by Commission based on data supplied by utility in 2015
Legality of Commission challenged Ruled unconstitutional by lower
court Appeal to NC Supreme Court
pending Commission currently inactive
DNER preparing for plan reviews Others: funding & staffing limited so
impoundments rules uncertain
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Active CCR Surface ImpoundmentSchedule Considerations
Failure to meet structural integrity
requirements
Failure to meet location restrictions
Groundwater contamination
Triggers to SI Closure
**Closure timeframes vary:< 40 acres – up to 7 years> 40 acres – up to 15 years
Once triggered SIs must cease receiving CCR and initiate closure (file permit application) within 6 months
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SI ClosuresSchedule Considerations
Design/Permit/Build New Lined SI Typical schedule, 2 ½ to 3+ years
Wet to Dry Conversion Requires regulated dry disposal Typical schedule, 2 ½ to 3+ years
Closure Cap in place, excavate and landfill
on/off-site, beneficial re-use Typical schedule, 2+ years
Water Balance Impacts Combined impacts of ELG Rule
Treatment and reuse Treatment and discharge Zero liquid discharge
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Example Closure Planning Schedule
Client Responses
Key drivers Generation plans CCR portfolios State Rules or expectations for them Risk management Public perceptions
Current focuses Groundwater monitoring Structural assessments Closures: alternatives analysis, cost
estimating, implementation
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Well-Established Technologies & Tools
Technologies Dams & impoundments Landfills Groundwater monitoring
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Well-Established Technologies & Tools
Tools: Feasibility studies Work Breakdown Structures(WBS)
for cost estimating Scheduling Qualitative risk ratings
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Quantity UnitEstimatedUnit Price
EstimatedPrice
Design and PermittingEngineering, Design and Bidding 1 LS $1,850,000 $1,850,000Permitting 1 LS $370,000 $370,000Mobilization and Site PreparationMobilization and Temporary Works 1 LS $2,440,000 $2,440,000Erosion and Sediment Control 1 LS $1,470,000 $1,470,000Clearing and Grubbing (Pond Areas) 44 AC $13,300 $585,200Haul Off Ash Contaminated Organics 350,000 CY $38.00 $13,300,000Clearing and Grubbing (Borrow Areas) 40 AC $7,700 $308,000Pond Free Water Removal/Water Mgmnt 1 LS $2,750,000 $2,750,000Ash Regrading, Drying and HaulingPond 1 - Excavate and Haul Ash to Pond 2 450,000 CY $8.00 $3,600,000Pond E - Regrade Ash 1,750,000 CY $7.00 $12,250,000EarthworkPond 1 - Regrade and Partially Breach Dam 60,000 CY $4.00 $240,000Pond 2 - Buttresses at Perimeter 100,000 CY $6.00 $600,000Subtitle D Cap ConstructionPond 2 - Buttresses at Perimeter 120 AC $115,000 $13,800,000Site RestorationGrassing of Pond 1 Area and Borrow Area 14 AC $2,500 $35,000Pond Lift Stations and Piping at Pond 2 4 EA $250,000 $1,000,000Outlet Structures for Sediment Ponds 1 EA $15,000 $15,000Decommissioning and Demolition 1 LS $300,000 $300,000
TOTAL ESTIMATED PRICE $55,000,00030% CONTINGENCY $16,500,000
TOTAL WITH CONTINGENCY $71,500,000ASH VOLUME VARIATION CONTINGENCY 1,000,000 CY $8.00 $8,000,000
TOTAL WITH BOTH CONTINGENCIES $79,500,000
Emerging Technologies & Tools
Technologies: Ash excavation & dewatering Rim ditches & sumps, stockpiling Well points & deep wells
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Emerging Technologies & Tools
Technologies: Seepage water/leachate handling Onsite treatment: plant/wetlands Storage, hauling & offsite treatment
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Emerging Technologies & Tools
Technologies: Remediation Cutoff walls Permeable reactive barrier (PRB) walls Recovery wells and trenches Risk assessment & monitored natural attenuation
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Emerging Technologies & Tools
Technologies: Beneficial re-use Concrete Structural fills Mine reclamation exclusion Thermal beneficiation
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Emerging Technologies & Tools
Technologies: Ash conveyance
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Emerging Technologies & Tools
Emerging Tools: GoldSET – tool for multi-criteria analysis
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Project Description
Project Description
Evaluation of Options
Interpretation & Decision
Making
Option Development
Option Development
Indicator Selection
A 5-Step Evaluation Process
A 5-Step Evaluation Process
ResultsResults
Emerging Technologies & Tools
Emerging Tools: Probabilistic cost & schedule risk analysis
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Questions and Answers
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