Category Archives: safeSTORAGE

From the Desk of the Utility CEO

The CEO in the corner office of any large organization has a lonely existence.

CEOs of utilities may feel even more isolated – but it’s not mandatory.

The energy industry is steadily evolving beyond fossil fuels and shifting to more renewable and sustainable sources. This is fantastic news for the planet, but before this transformation can be complete, we must address the fossil fuel legacy of nearly 2 billion tons of coal ash stored in inefficient and environmentally perilous ways all over the United States.

The buck for this state of affairs sits squarely on the desk of the utility CEO, while the pressure to provide answers pours in from all directions: political forces, environmental groups, ratepayers, internal managers, the board of directors and major investors.

Large companies usually establish methods and infrastructure with adequate manpower and resources to handle legacy CCR issues. But as new methods come to the market to deal with CCR more efficiently — yes, it happens — existing infrastructure may find itself calcified, too set in its ways. (“This is how we’ve always done it.”) Instead of being able to nimbly change course and adapt, it fractures or even collapses under the pressure.

Early CCR deposition strategies have relied on the “Cap-In-Place” method. However the science behind it, which CEOs and their teams have traditionally believed to be “the safest” is, in fact, unable to support the environmental and business risks that approach entails.

With that option now off the table, the buck flies back to the CEO whose job is to lead the way by forging a middle path that will satisfy all stakeholders going forward.

The first — and easiest — question a CEO might ask is, “Is there another one solution to fit all?”

The answer to that is easy. It’s no. (That was destroyed in the last Avengers movie.)

Without another simple strategy like good old out-of-sight-out-of-mind cap in place, the next logical area to explore is hybrid approaches.

It’s the way of today and the future to pursue multiple solutions that all contribute to the goal of proper CCR deposition.

The good news is that CEOs who can present multiple solutions to their boards, internal managers and external stakeholders dramatically increase their negotiating power and chances of success by having more than one card to play.

It seems hard to believe that groups around the country have been wrestling with this issue of what to do with legacy CCR for almost 11 years. The nation is making progress. We’ve realized that cap in place is virtually never the answer, and we’re developing alternatives. However, most of the work is yet to be done, and dealing with 2 billion tons of anything can take decades, but we have to start somewhere.

CEOs have the resources, tools and stature to jump-start any CCR deposition project by considering all their options so they can guide stakeholders toward wise decisions and action.

Next, we’ll step away from the corner office and consider the perspective of stakeholders who have been locked in CCR trench warfare for over a decade.

CCR Innovation Series: Part 3 of 3

It takes a village to solve the looming CCR storage issue.

In all discussions of coal ash disposition — either through beneficial reuse or keeping it intact but contained — the overriding concern is safety.

The cap-in-place solution has been solidly debunked from a safety standpoint. The market for beneficial use of coal ash in building products still lags far behind the over-abundance of legacy CCR. Yes, the market may eventually catch up, but leaving toxic CCR in the ground indefinitely while it waits for a new home isn’t an option.

Government regulations have necessitated more rapid and safe disposition, raising these questions for stakeholders:

  • What method to use?
  • How long will it take to implement?
  • What will it cost?

New regulations in Virginia and North Carolina, and pending legislation in Illinois, are harbingers of what’s to come as utilities find themselves compelled by law to find innovative ways to dispose of their legacy CCR. Drying and excavation is a monumental challenge, but the challenge doesn’t stop there. Excavation results in large stockpiles that need to be properly stored. Indecision over how to proceed, or an inability to pick a middle path for all stakeholders, only compounds the problem.

When engineers in ancient Egypt cut and laid the first limestone block, they probably wondered if and when their project would ever end. But that didn’t stop them from marshalling their forces to stack block upon block for years until they finally had a pyramid.

Similarly, it’s the duty of all stakeholders in the CCR dilemma to rise up and conquer the challenges they face today, one site at a time, until no CCR is left behind.

If we take inspiration from the famous Nike slogan, “JUST DO IT,” resolutions to the most vexing problems become fairly straightforward:

“The impounded coal ash is too close to a waterway.” — MOVE IT.

“We don’t have enough land to store the impounded coal ash.” — FIND WAYS TO MAXIMIZE IT.

“We can’t beneficiate all the ash within the 15-year deadline.” — SAFELY STORE IT.

“Our on-site landfill is susceptible to hurricanes and flooding.” — SHORE IT UP.

“There’s no one solution that fits all.” — SO TACKLE IT WITH MULTIPLE SOLUTIONS.

“We don’t want to burden our ratepayers.” — FIND WAYS TO FIX IT THAT PROVIDE THE MOST BANG FOR THE BUCK.

“It costs too much to safely store this much coal ash.” — SHOW US WHY IT DOES.

Utilities have typically been less than transparent in divulging their methods and costs. Ironically, this has forced environmentalists and affected citizens to become much better educated and organized, making them potent potential allies equipped to bring new ideas to the table.

Now’s the time for everyone to come together, think together, and determine best practices for dealing with CCR in their communities. Whether it’s safe storage now to become inventory for future beneficial use, permanent on-site disposition or relocation, the answers are out there. It takes a village to find them.

CCR Innovation Series: Part 2 of 3

Maximize Innovation Before Resorting to Traditional Methods

In 2008, the Tennessee Valley Authority’s dike containing its coal ash failed, allowing approximately 5.4 million cubic yards of coal ash to spread over 300 acres and into the Emory River. Since then, the problem that coal ash represents for the U.S. has only gotten worse. Constant battles between federal and state governments, regulatory agencies, environmental groups, courts, vendors and the general public represent the inability of these stakeholders to understand how monumental this situation has become.

Since that devastating TVA spill brought the situation to front pages everywhere and other localities have dealt with their own coal ash disasters, several facts have been proven:

  • CCR is a waste containing arsenic, mercury, lead and other toxic substances. It may not be officially classified as hazardous waste, but it is hazardous to the environment. That’s not something Washington, D.C., can change through legislation.
  • Liquifying and pumping wet coal ash into unlined containment ponds may not pollute the air, but the moisture facilitates toxins leaching into surrounding soil and groundwater.
  • Capping ponds in place is not an option if the coal ash will remain in contact with soil, which is usually the case.
  • Drying and excavating coal ash ponds generates tremendous volumes of coal ash requiring proper deposition.
  • Any disposition strategy must address these questions: how to dispose, where to dispose, and for how long?
  • The longer the distance coal ash must be transported by road, rail or barge for off-site disposition, the greater the likelihood that it will disrupt and impede regular traffic or have a spill that creates another environmental mess to clean up.

We’re already developed various methods to tackle this challenge.


Microencapsulation involves recycling coal ash into other products, such as brick, block and cement. When coal ash becomes physically bonded to other ingredients, it’s rendered inert and harmless. This solution is limited only by market demand for building materials. Developing other uses for coal ash in other industries could only help to use up the existing stockpile.

Macroencapsulation offers several approaches and solutions. When coal ash is transferred on-site to a fully lined landfill, that land can be reclaimed for solar farms or sports parks that entire communities can enjoy. Another on-site option is using the coal ash as fill to create new solid waste landfills, helping communities achieve more capacity for household waste disposal by re-purposing land that’s already otherwise unusable.


Macroencapsulation becomes a highly versatile solution when coal ash can be transported off-site to be used as fully encapsulated fill for solar farms, berms or other structures. Also, it can become fill around existing solid waste landfills to increase their airspace and extend their useful lives. However, the coal ash must be transported with the same risks as mentioned above, not to mention the added expense.


Disposal is the last resort if all these other methods don’t pan out, with the coal ash ending up in a subtitle D compliant landfill.

Until the country weans itself completely from fossil fuel energy, coal ash will continue to be generated and legacy coal ash needs to be beneficially reused or stored properly. Now is the time to figure out the best ways to dig ourselves out from under the 500 to 600 million tons of legacy coal ash we’ve already created while building up capacity and infrastructure to implement innovative solutions for the future.

Our ultimate goal should be no coal ash left behind. Every existing pond needs to have a plan in place for its productive disposition.

CCR Innovation Series: Part 1 of 3

K.I.S.S. Applies to Coal Ash Solutions

Imagine a community facing the dual crisis of severely dwindling solid waste disposal capacity at the same time its electric utility has been ordered by a federal judge to excavate and move a hazardous legacy coal ash pond to a lined landfill.

Unfortunately, this isn’t fantasy. Nashville, Tennessee, is one such example of a community wrestling with these issues today. The two problems may seem unrelated, but technology exists to make them part of each other’s solution if you look at the big picture and think creatively.

On the solid waste side, Tennessee’s largest landfill, Middle Point, which serves Nashville and many other localities, will run out of capacity in eight to nine years based on current daily volume, according to its owner. Outside observers believe any number of unforeseen events could increase volumes and force closure in as few as five years. Reasons include a recycling rate well below the national average and a building boom from the economic recovery that’s generating an over-abundance of waste.

One solution proposed for when the landfill closes is to truck the waste to other landfills in Kentucky and Tennessee, incurring the expense of long-distance hauling.

As for the coal ash, about 14 million cubic yards of it sit in an unlined pond at Gallatin, with potential to leach arsenic, mercury and lead into the Cumberland River. A federal judge has ordered the Tennessee Valley Authority (TVA) to excavate the coal ash and move it to a lined landfill. Because there’s little evidence that the river has been affected so far, although groundwater issues do exist near the pond, opponents of the ruling say the excavation order is disproportionately harsh and to cap in place would be sufficient.

One innovative solution to help alleviate both problems is to move some of the coal ash to Middle Point for use as fill in macroencapsulated berms around the landfill. This would extend the landfill’s life by years and render the coal ash completely inert and harmless.

Murfreesboro and Gallatin are about 45 miles apart, so that’s how far the coal would have to travel. Solid waste would continue to go exactly where it’s always been, with no interstate hauling required.

Cost-effective remedies for TVA Gallatin’s problems are close at hand with innovative thinking. Cap in place isn’t an option; proper CCR deposition is required. So why not keep it “local” and put it to beneficial use wherever possible?

Macroencapsulation fills the judge’s requirement for a lined repository, and innovation, when applied, can solve multiple problems for all stakeholders. When the private sector works with public entities to find mutually beneficial solutions that can be implemented in the simplest and most direct ways, everybody comes out ahead.

Legacy CCR Series: Part 6 of 6

Hey, Power Industry, Welcome to the Waste Industry!

The unbreakable thread running through all arguments about CCR over the years is this: CCR is waste. Like any waste, it should adhere to a certain methodology that has been developed by the waste industry.

The U.S. waste industry has structured its business model around the EPA’s nonhazardous waste management hierarchy for years. The hierarchy dictates reducing, reusing and recycling most wastes – all key components of the EPA’s Sustainable Materials Management Program (SMM).

Source: EPA

To quote the EPA, the SMM “is an effort to protect the environment and conserve resources for future generations through a systems approach that seeks to reduce materials use and their associated environmental impacts over their entire life cycles, starting with extraction of natural resources and product design and ending with decisions on recycling or final disposal.”

Coal ash is a natural fit in the waste management hierarchy, and the EPA expects utilities to play by its rules for CCR disposition. Recycling CCRs into building materials is currently the preferred method, but we’ve discussed its inherent limitations in previous posts.

Many utilities consider disposal, the last resort environmentally, the most expedient solution because it’s relatively easy to accomplish compared to all other accepted methods. However, public perception has evolved to realize that this is the most impractical solution, and it’s rightly the least preferred method in the EPA hierarchy. Airspace in the United States is dwindling, and the fastest way to put landfilling in crisis mode is to add this waste stream to it.

This impasse could be overcome if CCR producers would only partner more with the waste industry, which has the expertise in formulating creative disposition methods. For example, CCR contamination hazards could be negated through macroencapsulation in berms and bunkers constructed for land reclamation projects.

Taking this single approach could eliminate the need to find outlets for recycling, remove the necessity of dangerously transporting CCR long distances on public thruways, give the CCR a safe, final resting place AND make it a beneficial contribution to land reclaimed for new, productive use.

No matter how you parse it, CCR is a hazardous waste. Instead of minimizing the risks it poses, utilities would do better to take a page from the waste industry’s playbook on landfill management and cooperate on ways to put CCR to constructive uses that have long-term benefits.

This is the last post of our Legacy CCR Series. Our goal was to share some of our experiences with this multifaceted issue confronting all stakeholders today. The simplified approach in writing these messages was not to diminish the complexities of dealing with every coal ash pond, each of which poses its own unique challenges, but to provide a starting point for such discussions, which are taking place across the nation.

Legacy CCR Series: Part 5 of 6

The Only Problem with the Unencapsulated Beneficial Use Definition is the Word “Unencapsulated”

In public debate over the best disposition of legacy coal ash (CCR), the phrase “uncapsulated beneficial use” is used. However, “uncapsulated” solutions, such as mixing loose CCR into soil or spreading large quantities as fill on construction sites without environmental safeguards, are no longer considered viable options for beneficial use.

The method called “macroencapsulation” is considered by the EPA to be an “unencapsulated beneficial use.” This term, at least on the surface limits encapsulation beneficial use to a micro level (the CCR is fused or, in EPA terms, “encapsulated”) through recycling into another product like concrete or wall board. But if you look at macroencapsulation on a macro level, the CCR is FULLY encapsulated and rendered inert within a structure. Confusing? We know, since we understand the safeguards put in place for all beneficial use, But a simple label certainly has a negative impact.

EPA regulations on beneficial use finalized in April 2015 have safeguards in place to exclude earlier methods of unencapsulated beneficial use that have proven dangerous.

40 CFR § 257.53 Definitions “Beneficial Use”

Beneficial use of CCR means the CCR meets all the following conditions:

(1)      The CCR must provide a functional benefit;

(2)      The CCR must substitute for the use of a virgin material, conserving natural resources that would otherwise need to be obtained through practices, such as extraction;

(3)      The use of the CCR must meet relevant product specifications, regulatory standards or design standards when available, and when such standards are not available, the CCR is not used in excess quantities; and

(4)      When unencapsulated, use of CCR involving placement on the land of 12,400 tons or more in non-roadway applications, the user must demonstrate and keep records, and provide such documentation upon request, that environmental releases to groundwater, surface water, soil and air are comparable to or lower than those from analogous products made without CCR, or that environmental releases to groundwater, surface water, soil and air will be at or below relevant regulatory and health-based benchmarks for human and ecological receptors during use.

Macroencapsulation meets all four of these EPA requirements, winning another argument against calling it an “unencapsulated” approach.

In 2009, and again in 2012, well before the EPA issued its 2015 regulations, the Commonwealth of Virginia’s Department of Environmental Quality approved macroencapsulation as a tested, proven and environmentally protective beneficial use, positioning Virginia as a visionary leader in the safe disposition of CCR.

The snag continues to lie in the semantics. The public continues to mistakenly view macroencapsulation – where coal ash is completely encased in an impervious barrier, in no contact with air, soil or groundwater whatsoever – an unencapsulated use. Although the EPA supports responsible beneficial use, the EPA’s definition of “unencapsulated” injects confusion into any discussion of the advantages of macroencapsulation and causes it to be discounted without considering the sound science behind it.

The last-ditch solution of disposing of coal ash by moving it to lined landfills is also considered a viable option. But a landfill’s geomembranes are no different from the geomembranes used in a macroencapsulated structure. The only difference is that the landfill continues to be a landfill (full of coal ash), whereas a macroencapsulation project uses the CCR to reconfigure the land for productive reuse, such as creating an area where solar panels can generate renewable energy.

What’s more, macroencapsulation done on-site or near the existing legacy coal ash pond is usually the least disruptive and most cost-effective solution.

The bottom line is that macroencapsulation IS a method of encapsulation, and it has more potential for safe disposition of CCR and land reclamation than recycling the CCR into other products, because recycling will always be limited by the market’s demand for those products.

Legacy CCR Series: Part 4 of 6

Slow Death of Cap-In-Place

Over the years, methods to properly close legacy coal ash ponds (referred to “CCR units” by the EPA) have become a source of great debate. Most utilities have publicly stated that closure in place, commonly referred to “cap-in-place,” is a “safe and effective option” and it is being considered at a great number of coal ash ponds across the U.S.

However, that strategy has been slowly dying as a solution. The science behind the choice has revealed, according to the EPA, that coal ash in direct contact with soil leaches contaminants such as selenium, mercury, cadmium and arsenic into surrounding groundwater. These substances have been clearly associated with cancer and other serious illnesses.

(40 CFR § 257.102(d)(i))

“Control, minimize or eliminate, to the maximum extent feasible, post-closure infiltration of liquids into the waste and releases of CCR, leachate, or contaminated run-off to the ground or surface waters or to the atmosphere…”

As we’ve previously posted, the EPA regulations stipulate that capping in-place is safe only under certain conditions.

While this does not stipulate that this performance standard specifically applies to the entire CCR unit, acceptable waste management practice indicates that it does apply to the entire CCR unit storage system. To interpret the regulation any other way would mean that concern for environmental impact is restricted to surface water infiltration, and does not include any subsurface interactions of the CCR with the environment.

To paraphrase Hamlet, therein lies the rub – a judgement call must be made as to whether cap-in-place of a pond has alleviated environmental impact to the “maximum extent feasible” if the pond still has the potential to leak underground into the environment in the future.

Like placing a bet in Las Vegas, the odds can change based on various factors such as, for example:

Factor No. 1 equals 100% need for clean-up, not cap-in-place. Once stakeholders have determined that cap-in-place is not an option, the challenge of finding effective ways to properly dispose of tens of millions of tons of legacy coal ash becomes an imperative.

Legacy CCR Series: Part 3 of 6

The 5 C’s of Legacy Coal Ash Beneficial Reuse

When utilities are determining how to eliminate environmental hazards posed by legacy coal ash, the paramount goal should be to beneficially reuse much or all of it, if possible, with disposal being the last resort. We discussed methods of accomplishing this in Post 1: microencapsulation and macroencapsulation.

Now we’ll cover what these two methods’ frameworks have in common, or the “5 C’s” of beneficial reuse.

Beneficially reusing coal ash in productive ways yields many more benefits than simply disposing of this material. Coal ash may be used in place of some virgin materials in building products like concrete, brick, block and wall board, which helps to preserve virgin resources. Creating products through recycling typically requires less energy consumption in manufacturing, so fewer greenhouse gases are generated. Using coal ash as a construction fill in a macroencapsulated environment also yields similar benefits.

The 5 C’s Role in Coal Ash Beneficial Reuse

  1. Commitment to the process. In determining the best strategy for beneficial reuse, it’s vital for all parties involved to commit to carrying out the agreed-upon process, whose components include technology, cost and constructability.
  • Clean closure, the preferred environmental method. Now that environmentalists and energy end users have become educated on the inherent dangers of leaving coal ash in the environment, they aren’t satisfied with a cap-in-place solution that leaves coal ash in unlined ponds where it can continue to leach toxins into the surrounding land and groundwater.
  • Creation of proper, adequate storage. As already stated, dumping coal ash into unlined areas, or using it as unencapsulated fill material without environmental safeguards on construction sites are no longer considered viable options. Macroencapsulation uses the same landfill safeguards, rendering the storage proper and adequate.
  • Consolidation into the smallest footprint. This has always been the mantra of the solid waste industry. In coal ash disposition, once as much volume is microencapsulated into other products as possible, remaining ash may be macroencapsulated as construction fill for berms or bunkers and rendered inert.

Macroencapsulation can also reduce the footprint, which saves valuable acreage and can safely position the ash farther away from flood plains and groundwater. The bonus is that the surface created on the smaller footprint can be repurposed for solar energy generation or park land, to name a few uses.

One notable example of land reuse is the famous Mount Trashmore in Virginia Beach. This 165-acre family-friendly park with many amenities was once a solid waste eyesore.

  • Compliance with environmental regulations. Since coal ash has lost its classification as a benign byproduct of energy production, the EPA has issued guidelines for encapsulated and un-encapsulated beneficial reuse. Complying with or exceeding these regulations prohibits even the suggestion of implementing any legacy non-protective solutions.

Positive Outcomes Resulting from This Framework

  • Correct the problem
  • Beneficially reuse as much legacy coal ash as possible
  • Re-purpose the land, if possible
  • Safely remove all coal ash from the environment