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June 23, 2020

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Allison Kreinberg and Lane Dorman Presented at the Utility Solid Waste Activities Group Coal Combustion Residual Workshop Session

Allison Kreinberg (Ohio) presented "Approval of an Alternate Source Demonstration Under Oklahoma's State CCR Program" and Lane Dorman, P.G. (Florida) Presented "Case Study: High Resolution Site Characterization (HRSC) to Inform CCR Groundwater Remedial Design and Implementation" at the Utility Solid Waste Activities Group (USWAG) Coal Combustion Residual (CCR) Workshop's Session 1 on June 18, 2020.

Allison's co-presenter was Jill Parker-Witt, American Electric Power. Lane's co-presenter was Lauren Petty, Southern Company Services.

Allison is a Project Scientist based in Ohio with experience in the assessment and remediation of sites impacted by chlorinated solvents and metals, coal combustion residual (CCR) management, and contaminant fate and transport. She also has extensive experience performing vapor intrusion sampling and mitigation.

Lane is a Senior Hydrogeologist based in Florida with more than 12 years of professional experience focused on the assessment and remediation of arsenic, coal combustion residuals (CCR), and chlorinated solvent groundwater plumes.

The Coal Combustion Residuals Workshop was designed to provide attendees with an understanding of the CCR Rule, a key regulatory compliance.

USWAG is responsible for addressing waste, byproduct and chemical management, and transportation issues on behalf of the utility industry. USWAG members include more than 130 utility operating companies, power producers, energy companies, and industry associations. USWAG's core mission is to support the industry's efforts to comply with federal environmental regulations, protect the environment, and serve its customers. As part of that effort, USWAG engages in regulatory advocacy, regulatory analysis and compliance assistance, and information exchange.

Geosyntec Participation

Title: Approval of an Alternate Source Demonstration Under Oklahoma's State CCR Program
Presenter: Allison Kreinberg, Geosyntec; Jill Parker-Witt, American Electric Power
Description: Oklahoma Department of Environmental Quality (ODEQ) prepared a state CCR program which was approved by EPA and became effective on September 15, 2018. Although the ODEQ program generally mirrors the Federal CCR Rule (40 CFR 257.95 Subpart D), the state rules have been subject to a lawsuit alleging they were unlawfully approved.

While the lawsuit proceeds, ODEQ has begun regulating the Bottom Ash Pond (BAP) at AEP's Northeastern Plant in Oologah, Oklahoma. During assessment monitoring, lithium was detected at statistically significant levels (SSLs) above the groundwater protection standard (GWPS) and an ASD was conducted.

The ASD provided multiple lines of evidence indicating that lithium was naturally occurring and not indicative of a release from the BAP. A hydrogeological investigation helped rule out the possibility that lithium was being sourced from the BAP. A geochemical evaluation suggested there were multiple different groundwater chemistries within the limestone bedrock at the site. Furthermore, the geology of the Site, originally thought to consist of limestone underlain by shale, was determined to consist of a thicker unit of limestone with intermittent shale/clay interbeds. Mineralogical analysis of the shale/clay interbeds identified lithium present in these layers. The presence of lithium and different chemistries in certain monitoring wells appears to generally correlate with the presence of shale interbeds present at and near the screen intervals. These lines of evidence allowed AEP to conclude that an alternate source for lithium at the BAP was naturally occurring lithium dissolved from shale/clay interbeds.

ODEQ did not accept the ASD and requested an assessment of corrective measures. After additional analysis confirmed low concentrations of lithium in the bottom ash pond water and solids, AEP secured approval of the ASD. AEP's experience with the approval process can provide insights to others as more sites become regulated under state programs.

Title: Case Study: High Resolution Site Characterization (HRSC) to Inform CCR Groundwater Remedial Design and Implementation
Presenter: Lane Dorman, P.G., Geosyntec; Lauren Petty, Southern Company Services
Description: A suspected CCR impoundment release resulted in increasing concentration trends of select CCR-related constituents (e.g., calcium, sulfate, chloride, arsenic, mercury) in multiple downgradient monitoring wells. High resolution site characterization (HRSC) of groundwater downgradient of the CCR impoundment was performed using multiple tools to evaluate CCR groundwater impacts and serve as the basis for selecting and designing a groundwater remedy. HRSC at this CCR facility included: 1) surface geophysical surveys using electrical resistivity imaging (ERI) around CCR impoundments to evaluate zones of elevated specific conductivity as an indicator of CCR groundwater impacts; and 2) direct push technology (DPT) investigations for collection of relative hydraulic conductivity, real-time vertical profiles of electrical conductivity (EC), and depth-discreet groundwater samples. The DPT investigation evaluated preferential contaminant flow paths and confirmed CCR groundwater impacts with depth during a single mobilization. Cross-sections were used to display the ERI, EC, and DPT data with existing lithologic and groundwater monitoring well data to inform the development of a conceptual site model (CSM). Once the CSM was developed, a groundwater extraction system was designed, constructed, and brought online under an aggressive schedule to address identified CCR impacts. The remedial system included the installation of nine extraction wells with a total flow rate up to 250 gallons per minute (gpm). Extracted groundwater is treated by a groundwater treatment system before disposal. Due to the concentrations of groundwater constituents, corrosion/scaling issues were predicted by geochemical modeling and subsequently observed during system operation. The potential for scaling was addressed through system design and as part of routine system operation/maintenance. Since system startup, routine groundwater monitoring indicates substantial declines in groundwater concentrations.

More Information

About the event: https://bit.ly/2YKTIsE
About the Utility Solid Waste Activities Group: https://www.uswag.org/
For consultation regarding CCR remediation, contact Allison at This email address is being protected from spambots. You need JavaScript enabled to view it. or Lane at This email address is being protected from spambots. You need JavaScript enabled to view it.
Learn more about Allison: https://www.geosyntec.com/people/allison-kreinberg
Learn more about Lane: https://www.geosyntec.com/people/lane-dorman