Corporate Address:
4300 Market Pointe Drive
Suite 200
Minneapolis, MN 55435
Barr
At Barr Engineering Co., we put ourselves in your shoes—understanding what’s at stake and taking on your toughest challenges. Our dedicated employee-owners develop lasting engineering and environmental solutions for clients, communities, and the environment.
Jim Aiken
Vice President
Update on EPA Part A, Part B, and Consent Order Determinations with Applications for CCR Legacy Rule
Jim Aiken – Barr Engineering Co.
The 2015 EPA CCR Rule was originally intended as a ‘self-implementing’ rule that left many critical decisions up to the owner and their designated qualified professional engineer (QPE). Without a permitting program, and without clear guidance on how EPA is interpreting the rule, the default compliance paradigm has been the use of general industry practice as a standard of care. More recently, the EPA’s determinations (Part A, Part B, and Consent Orders) have provided much more insight into what the EPA considers compliant-and in some cases-appears to require a new standard of care. This presentation summarizes the four main categories cited by EPA as deficient, including Site Characterization, Reporting/Certifications, Statistics, and Alternative Source Determinations as well as a tally of EPA’s findings in each category. We will summarize each deficiency type and offer ideas on improving compliance. For example, a common type of deficiency can be described generally as “a lack of rigor” in evaluating data and testing alternative hypotheses. Enhanced data collection and analysis techniques may offer a more defensible basis for conclusions in the event of future EPA or state enforcement actions. The insight offered by this analysis may be used to inform compliance under the anticipated CCR Legacy Rule, which brings in a new type of CCR unit called the CCR Management Unit or CCRMU. Defining and monitoring CCRMUs will require a degree of rigor that we believe can borrow from the insight gained from evaluation of the EPA’s previous determinations.
1-Minute Introductory Video
Jim Aiken
Update on EPA Part A, Part B, and Consent Order Determinations with Applications for CCR Legacy Rule
Information Request
H3
CCR | CCP | Risk Assessment | Rules | Closures
Feb 14 (1 pm – 3 pm)
Jim Aiken
Update on EPA Part A, Part B, and Consent Order Determinations with Applications for CCR Legacy Rule
Update on EPA Part A, Part B, and Consent Order Determinations with Applications for CCR Legacy Rule
Jim Aiken – Barr Engineering Co.
The 2015 EPA CCR Rule was originally intended as a ‘self-implementing’ rule that left many critical decisions up to the owner and their designated qualified professional engineer (QPE). Without a permitting program, and without clear guidance on how EPA is interpreting the rule, the default compliance paradigm has been the use of general industry practice as a standard of care. More recently, the EPA’s determinations (Part A, Part B, and Consent Orders) have provided much more insight into what the EPA considers compliant-and in some cases-appears to require a new standard of care. This presentation summarizes the four main categories cited by EPA as deficient, including Site Characterization, Reporting/Certifications, Statistics, and Alternative Source Determinations as well as a tally of EPA’s findings in each category. We will summarize each deficiency type and offer ideas on improving compliance. For example, a common type of deficiency can be described generally as “a lack of rigor” in evaluating data and testing alternative hypotheses. Enhanced data collection and analysis techniques may offer a more defensible basis for conclusions in the event of future EPA or state enforcement actions. The insight offered by this analysis may be used to inform compliance under the anticipated CCR Legacy Rule, which brings in a new type of CCR unit called the CCR Management Unit or CCRMU. Defining and monitoring CCRMUs will require a degree of rigor that we believe can borrow from the insight gained from evaluation of the EPA’s previous determinations.
Jarrod-Rice
Solids Separation a Novel Approach to CCR Closure
Solids Separation a Novel Approach to CCR Closure
Solids Separation a Novel Approach to CCR Closure
Jarrod Rice – Yukon Technology
USEPA regulations prohibit the use of unlined ponds for ash management at coal-fired powerplants. Each CCR pond is different requiring unique solutions for each location. The concept of wet dredging and a solids separation plant is a novel approach to addressing these new regulations.
There are several benefits to wet dredging and solids separation over the traditional methods. Initially, by avoiding traditional dewatering, we reduce the potential of oxidizing metals in the ash and preventing them from leaching into the water reducing the need for costly water treatment. Additionally, wet dredging allows the movement of ash out of the pond earlier in the closure process. Hydraulic dredging and the use of a solids separation plant also allows for the processing of wet ash into a dry easily transportable product reducing the time required for ash management. Finally, removing ash through dredging preserves the stability of the ash in place reducing the dangers of ash slides providing a safe and secure field from which to work.
Water generated during this process can be returned to the pond for further sluicing of ash or treated further to allow for permitted release. Water can also be reused onsite for operational needs such as a truck wash or dust control. Using this approach to ash management, a significant amount of time and costs can be saved.
This presentation will discuss in detail the use of dredging and mechanical solids separation to reduce the time and costs associated with CCR pond closure.
Alejandra Cabrera
Multi-gas FTIR Monitoring in Carbon Capture Processes
B1.3 Multi-gas FTIR Monitoring in Carbon Capture Processes
Alejandra Cabrera – Gasmet
Carbon capture plants deploy several methods ranging from membranes, to amine-based technologies that involve components which degrade into ammonia, formamide, aldehydes, organic acids, nitrosamines and other toxic gaseous species. Gas products pose challenges for sampling and analysis given the presence of water vapor and high concentrations of carbon dioxide as well as certain water-soluble compounds.
There are currently stationary and semi-portable hot-wet FTIR (Fourier Transform Infrared Spectroscopy) instruments for online analysis and gas emissions monitoring from such plants. These units scan a wide wavenumber spectrum where several species absorb infrared light, allowing to simultaneously measure more than 25 gases. FTIR analytes include standard criteria pollutants such as CH4, CO2, NOx, SO2, acid gases, NH3, aldehydes, and other VOCs, and extend to amines and amine by-products observed in CO2 absorber and amine stripping towers. Some of these substances are ecotoxic, have low biodegradability, and are known to cause cancer.
This presentation reviews FTIR principles, sampling solutions, and available configurations for online gas analysis at carbon capture and storage plants. It highlights industrial and laboratory scale case studies using semi-portable and CEM systems, and advantages as related to analytical performance, component flexibility, and maintenance requirements.
Co-Author: Jim Cornish, Gasmet Technologies
QUESTIONS
1. How are different gas matrices and concentrations analyzed?
2. What gas components cannot be monitored with FTIR?
3. Can I measure from multiple sampling points within a plant?