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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