EnCAP-IT is pleased to announce that the company’s safeBERM® was mentioned in the national publication, WasteAdvantage Magazine. The article, entitled “The Benefits of an Encapsulated Mechanically Stabilized Earthen (eMSE) Berm”, was published in the October 2019 edition of WasteAdvantage Magazine.
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.
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.
INNOVATIVE ON-SITE USES:
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.
INNOVATIVE OFF-SITE USES:
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.
TRADITIONAL OFF-SITE USE:
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.
Life Beyond: Old Dumping Grounds are Ripe for Adaptive Reuse
Communities with areas in decline have embraced the concept of adaptive reuse to restore historic buildings and reclaim their decaying or abandoned urban landscape. Such projects involve salvaging as much of the existing building material as possible and repurposing it in new ways to make the most of the “good bones” of existing structures. This is a more cost-effective approach than razing entire blocks and rebuilding from scratch.
Adaptive reuse of land is no different. Areas that have served as solid waste landfills or coal ash ponds are not doomed to spend eternity as eyesores on the landscape. In many cases, adaptive reuse can transform that land into better spaces than it was to begin with.
Nowhere stands a more amazing example of this than in Israel. The Dirt described how the Hiriya landfill, commonly known as the “Mountain of Crap,” received 25 million tons of waste over its 60-year life. Flocks of birds drawn to the garbage were causing problems for Tel Aviv’s Ben Gurion Airport, and toxic runoff leached into nearby water supplies.
Hiriya closed in 1999 and began its transformation into the 2,000-acre Ariel Sharon Park, roughly three times larger than New York’s Central Park. Rainwater is now collected and filtered to irrigate plant life on the sprawling mound.
Nearby waste facilities still in operation process 90% of municipal waste, recovering metal and glass for recycling and producing bio-gas to generate electricity. In addition, methane gas recovered from still-decomposing materials within the mound generates enough electricity to run a nearby textile factory.
A man-made lake and redirected water systems created around the area now serve as buffers against flooding in South Tel Aviv and Holon. Hiriya has become a paradise for outdoors lovers, with walking and bike trails, gardens and wildlife habitats. The project’s completion is planned for 2020. TouristIsrael.com describes the site as an “ecological masterpiece.”
But Israel isn’t the only country to master adaptive land reuse. A similarly impressive example in the U.S. is Freshkills Park on Staten Island. At 2,200 acres, it’s the largest park developed in New York City in over 100 years. Amenities will include playgrounds, athletic fields, kayak launches, horseback riding trails, and large-scale art installations. It’s a work in progress, opening in phases through 2036.
Like Hiriya, Freshkills also has submerged gas wells collecting methane still being generated by the decomposing waste. It’s piped it to a power company that in turn uses it to power approximately 25,000 homes on Staten Island, generating $12 million for the city annually.
Predating both of these projects by several decades is Tifft Nature Preserve, three miles from downtown Buffalo, New York. In the 1950s and ‘60s, this 264-acre landfill accumulated nearly 2 million cubic feet of solid waste, which is now encased in clay and covered with soil. The site opened in 1972 as a nature refuge with five miles of trails and boardwalks, ponds and woodlands.
Transforming a blighted area into an oasis for people to enjoy is a wonderful outcome, but another adaptive reuse that’s growing in popularity is solar farming. Once a landfill is capped with an impermeable geomembrane, it becomes a suitable surface for solar panels, a renewable source of electricity for communities.
In North Carolina, the 48-acre Hickory Ridge Landfill had a relatively brief useful life from 1993 to 2006, but after it was capped in 2011 and covered with over 7,000 solar panels, it has essentially become an open-air power plant. Because the land wasn’t replanted, rainwater runs off the panels and down the sides of the mound, to be captured, filtered and reused.
In December 2017, the Orlando Utility Company’s Kenneth P. Ksionek Community Solar Farm brought Orlando one step closer to its goal of running on 100% renewable energy by 2050. The utility installed 20,369 of 37,544 solar panels atop concrete slabs on an 80-acre hill that’s filled with coal ash. The remaining panels sit on nearby flat land. The new $15 million solar plant generates enough electricity to power more than 1,400 homes in the area, costing less per kilowatt hour than fossil fuel, creating a win-win for the environment and the community.
These five examples show how foresight and smart adaptive reuse can ensure that no land goes to waste and that its assets can be put to use to maximize its potential for generations to come. Thrillist.com offers 11 more amazing stories of land reclamation.
The time to face the future is now. Environmental Stewardship requires innovation, forethought and a desire to look beyond immediate problems so you can see the better way of life that lies beyond the horizon and strive to achieve it.
Is a landfill an asset?
The number of landfills in the U.S. is decreasing, resulting in dwindling airspace available to hold our waste. If you own a landfill, you must ask, “Is my landfill an asset or a liability?”
Despite recycling and Zero Waste initiatives across the county, the volume of waste generated hasn’t decreased to the point where we see reduced demand on airspace or an offset in the growing costs of proper disposal.
Compounding the problem is that the U.S. recycling industry shifted from domestic to overseas markets when China and other countries were clamoring for our raw materials. But now, those countries have become glutted, so they focus more closely on quality, and they discover that that much of what we sell them is contaminated, so those loads end up becoming unusable solid waste.
Because it’s prohibitively expensive to ship these rejected loads back to the U.S. for disposition, municipal recycling programs are taking a hard look at what they can continue to accept and sell. Unfortunately, the trend is toward less, not more.
This places the burden for solid waste disposition back on U.S. landfills.
Zero Waste initiatives – where, ideally, 100% of waste is put to beneficial reuse in some form – are noble to strive for, but they require significant compromises to life as we know it. How many of us are willing to go that extra mile and give up our trashcans? How long will it take to achieve zero waste?
It’s a problem that doesn’t have generations of time to solve. It’s growing larger and more pressing every day.
Communities that operate landfills can begin contributing to the solution today with a shift in attitude. Instead of considering their solid waste facilities eyesores that must be closed as soon as possible to appease residents whose mantra is, “Not in my backyard!” (the “NIMBY effect”), they should instead consider those landfills assets to be leveraged and maximized.
This keeps the waste local, reduces transportation costs and doesn’t – literally – kick the cans down the road for disposal in other localities.
Just about any landfill is an asset that can be operationally improved or expanded. At the end of its useful life, the land itself can be reclaimed and reused in a number of ways that benefit the entire community.
Until American innovators can step up and revive domestic recycling by inventing new uses for recyclable materials that other countries no longer want, it’s up to communities to fill the gap.
But let’s not stop at simply creating more landfill airspace. Environmental stewardship goes way beyond just protecting the environment. Localities should consider all stakeholders’ concerns and community needs (farm land, wetlands, lack of open space, beneficial use) and add them to the pot. When all options for landfill maximization are on the table to explore, it can result in winning propositions all the stakeholders can “live with.”
In the final post of this series, we’ll tackle how landfills can be adaptive reused.
Change is Coming – Solutions Must be Ready
These events generate a steady flow of new concerns about the environment. Protection against rising water levels, for example, the threat flooding poses to sites that store hazardous chemicals discussed by Bacon’s Rebellion, should have environmentalists actively seeking answers.
Adding to the already long list, more questions are being raised as to the adequacy and strength of traditional safeguards to manage these threats.
Hurricane Florence in 2018 brought epic rains to North Carolina, eroding earth covering a coal ash landfill at Duke Energy’s now-inactive L.V. Sutton Power Plant near Wilmington. This landfill was constructed according to current regulations. Those traditional construction methods couldn’t contain the coal ash as water reached over the berm. This caused water-laced coal ash to flow beyond containment.
At another coal ash site near the Waccamaw River in response to Florence, an inflatable dam was constructed to stop flooding from breaching the coal ash containment. But any inflatable structure can only be a temporary fix, at best.
These are just a few examples of new complications that current safeguard methodology can’t address. Innovation is needed to facilitate recovery from natural disasters, which are more frequent and catastrophic and reach farther inland as time goes on.
Innovative environmental stewardship is the answer.
Another U.S. environmental disaster 2,193 miles from the mainland is a perfect cautionary tale because it’s not a far-fetch possibility for many communities here. The territory of Puerto Rico is an island where many solid waste landfills already exceed capacity. Hurricane Maria in 2017 exposed a deadly CCR-related public health crisis that began unfolding in 2002, when AES Corporation began contaminating soil and groundwater by dumping over 2 million tons of coal ash without basic safeguards while producing only about 17% of the electrical power. The hurricane churned up the toxins, so the island now needs to find a safe CCR disposition strategy in addition to extending capacity for solid waste disposal. Macroencapsulation could solve both problems.
We must think beyond worst-case. These weather events are so severe that we’ve labeled them “thousand-year storms” on the assumption that such catastrophes typically happen only once every thousand years. But they’re becoming annual rituals in the U.S.
Much more stringent and lasting remediation is needed now by building protective structures that keep waste in and/or water out.
Macroencapsulation is an innovative solution that resolves multiple issues. For example, with long-term CCR disposition, instead of going low – such as digging ditches around coal ash ponds that are susceptible to overflowing, either by coal ash seeping out or encroaching waters seeping in – we need to go high.
We have plenty of CCR just lying around; it can be used as fill in fully lined macroencapsulated berms, bunkers, levees or dikes constructed around coal ash ponds, waste landfills or rivers bordering chemical facilities. This fulfills the dual needs of rendering the ash inert and untouchable by the elements and reclaims the land once occupied by coal ash ponds or solid waste for new uses. In addition, it protects that reclaimed land from any nearby rivers and lakes that may flood.
Instead of grasping for creative, limited or more costly methods of storm preparation, facilities can often implement foolproof macroencapsulated solutions, protecting the land against rising waters.
Some states have started to embrace these challenges, enhancing the importance of sound environmental stewardship in their communities.
It’s a win-win strategy from every perspective .
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).
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.
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.