CCR, ELG Compliance Is Evolving, But Planning Is Key for Utilities
The past few years have been a challenge for coal-fired power plants trying to prepare for and comply with U.S. Environmental Protection Agency (EPA) regulations covering plant wastewater management, treatment and discharge. Federal Coal Combustion Residual management (CCR) and Effluent Limitations Guidelines (ELG) make up an intertwined set of rules that continue to be in flux.
While portions of the ELG compliance rules are on hold, some CCR compliance dates have passed and some are still looming. Several CCR changes are being remanded and reconsidered; however, plants must continue to meet compliance dates that are rolling in. Regardless of policy outcomes and timing, utility plant operators know that a variety of water impacts are coming, but have they connected all of the dots?
The CCR management rules are already affecting power plants in a variety of ways. Compliance dates have driven many plants to cease wet ash handling operations and start ash pond closures. With compliance dates in the rule coming into effect through the end of 2018, however, more decisions are ahead. So what are the primary drivers today?
By January of this year, utilities had to analyze all background water sampling and produce the plant’s first annual groundwater report. At this stage, plants have confirmed, or have a good indication of, what groundwater impacts exist on-site.
Utilities should also be preparing to prove later this year that CCR impoundments meet aquifer separation criteria. If these standards are not met, plants must move toward closure of CCR impoundments. Both pond closure and remediation requirements mean facilities need to take a hard look at their overall water balance and develop plans for the discharge or use of both CCR impoundment water and potentially treated groundwater.
While it may not seem evident that impacted groundwater could become an overall plant water balance issue, when you consider all of the outcomes of the finalized ELG and CCR challenges, don’t dismiss this key issue in planning.
Simplify with Strategy
For plants not prepared to date, a lot of changes are ahead. Utilities should start thinking about the strategic approach needed to comply with the CCR and ELG rules, and how plant changes can be impacted by this year’s groundwater timeline. The more discharges that can be minimized at a plant, the better off utilities will be in the long term.
Utilities forced into an aggressive pump-and-treat type of remediation approach will only add another water stream to an already complex process water balance. ELG compliance should be top-of-mind when planning for these impacts. Strategic evaluation and planning should cover all aspects to achieve long-term operational benefits and compliance, including:
- Will adding another permanent water treatment system add to future capacity?
- Can using treated groundwater as source water minimize other water source needs?
- What permitting, treatment equipment and operational improvements will be needed to dispose of treated groundwater and comply with rules?
State regulators are expected to play a big role in the actions necessary for plants needing to discharge streams where this requirement did not exist before. Unlike the original intent of the CCR rule, federal regulators now appear to be leaning toward giving states more power to regulate.
Currently, states have the power to develop and implement an EPA-approved CCR program, including making requirements more stringent than the federal rule (if allowed by that state’s regulations). State programs also issue National Pollutant Discharge Elimination System (NPDES) permits for coal-fired power plants and may alter water discharge requirements to deal with location-specific issues unique to their areas.
Given the control of state regulators regarding water discharges and specific CCR programs, it’s important utilities engage and understand the drivers of regulators and local groups that may influence the direction of programs.
Time is of the essence for power utility operators to understand their current wastewater operations, evaluate potential impacts of national standards, and develop short- and long-term treatment and management compliance plans.