“Not everything that can be counted counts, and not everything that counts can be counted.”—William Bruce Cameron
“Better three hours too soon than a minute too late.”—William Shakespeare
Their sentiments couldn’t be more apt in 2020, as the Coal Combustion Residual Management marketplace faces a tremendous increase in activity. The 2015 Disposal of Coal Combustion Residuals (CCR) rule established a comprehensive set of requirements for the safe disposal of coal ash from coal-fired power plants. This year, up to 60% of the CCR ponds targeted for closure must initiate the process, compared to the last four years in which only 25% of ponds initiated multi-year closures.
How will the industry handle this change? What perspective should a consultant possess to advise stakeholders and plan the work? Access to CCR data for planning and benchmarking can shape response behaviors and is a critical component of the informed decisionmaking and risk management process. Indeed, there is an immediate need for the right information and analysis to help utilities discern the best closure tactics and attain facts that support technical and legal positions.
As discussed in Part 1 of this blog, business intelligence (BI) applications can cut through these market complexities in extraordinary ways. Here, we illustrate how using an award-winning BI tool has brought facts into focus and helped stakeholders optimize decisionmaking related to CCR management at the market and plant levels.
The Need for Facts and Data
The CCR management market is wildly dynamic. The 2015 CCR rule impacted 100+ organizations who operate 300+ regulated plants with a total of 700+ CCR units. Some closures will cost in the billions, making benchmarking even more important. Yet, each utility publishes required CCR data on their own sites, which makes easy access to available data difficult and data evaluation challenging.
Meanwhile, legal and public response has shifted the regulatory course and resulted in modifications at the federal level, and states have intervened with their own requirements. Environmental nongovernmental organizations (ENGOs) are applying the available data to shape government policy and public perception.
The award-winning Ash Mart, an industry-leading data analytics tool, not only quickly collects real-time data, but also employs robust filters to help CCR stakeholders understand critical information and make well-informed decisions. In fact, in creating a typical summary of data points for the entire market, it would take thousands of hours to pull data from utility sites and implement interpretations that capture the meaning of the larger data set. But BI applications like Ash Mart can compile data from multiple disconnected data sources, making that data much easier and faster to analyze.
The Data as It Relates to Closure Triggers
Understanding the closure triggers for surface impoundments within two CCR rule areas is important: (1) location restrictions (LRs) such as wetlands, fault areas, unstable areas and seismic zones, and aquifer separation areas; and (2) groundwater exceedances (GEs).
Using Ash Mart, we investigated and analyzed data points garnered from approximately 400 surface impoundments and discovered:
- A small number of sites failed to meet unstable area, wetland, and fault area LR requirements, and no sites were triggered due to seismic zones. Of these, nearly all impoundments are either already closed or are in the process of being closed.
- A significant number of sites—around 45%—do not meet the aquifer separation requirement, and, as in the case of the other LR requirements, most of these CCR units are currently in various stages of closure.
- Sites that fail to meet the aquifer separation requirement are currently required to cease accepting flows by October 31, 2020, and initiate closure. There is regulation pending to move up this date. The operations and budgets of the 100+ power plants are impacted by the closure that the LR requirement triggers—the owner/operators of the coal-fired power plants and their customers will be affected as well.
Groundwater Exceedances & Analytes
The CCR rule addresses groundwater protection by requiring corrective action for units that exceed defined levels. ENGOs have created scenarios based on available data that asserts that more than 90% of coal plants with regulated CCR units that have triggered closure are contaminating groundwater with unsafe levels of one or more CCR constituents. Using Ash Mart, we found that less than one-half of all coal plants are impacted by GEs.
The most-common constituents exceeding groundwater standards are lithium, cobalt, and arsenic, the occurrence of which varies by region and affects 100+ CCR units. Because these constituents are very different analytes from those that have historically been observed commonly in remediation projects, different implementation responses and technologies must be explored. All these points are significant to the closure itself and are of interest to purveyors of groundwater remediation technologies and services.
Because we’re able to see the data, we’re able to offer this figure, which indicates the top-three constituents (exceedances by state) in the top-five states-of-occurrence.
Looking Ahead Into 2020
In our daily practice, we continue to successfully address the unique conditions and challenges of each CCR unit closure. In 2020, the market faces enormous demands because of the tremendous increase in the amount of triggered pond closures. Ash Mart has increased the accuracy of our industry understanding and benchmarking, as well as our efficiency in delivering critical information for decisionmaking.
Especially now, as we enter this extraordinarily demanding period, we recommend that all stakeholders consider the use of a BI tool that provides real-time access to relevant data that can be effectively filtered to yield quality interpretation. The resulting increase in productivity will allow consultancies to meet stakeholder demands for fact-based information and risk reduction.