2017 World of Coal Ash (WOCA) Conference in Lexington, KY - May 9-11, 2017

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CCR Pond Dewatering – Critical Planning and

Characterization Tasks
Jeffery B. Heyman, P.E., R.G.1, G. Richard Bird, P.E.2, Stephen
Couture, P.E., DEE, BCEE3
1
AECOM, 7720 N 16th Street, Suite 100, Phoenix, AZ 85020; 2AECOM, 1001 Highlands
Plaza Drive West, St. Louis, MO 63110; 3AECOM, 1600 Perimeter Park Drive, Suite
400, Morrisville, NC 27560

CONFERENCE: 2017 World of Coal Ash – (www.worldofcoalash.org)

KEYWORDS: CCR (coal combustion residuals), Dewatering, CCR Impoundment

(Pond) Closure, Wellpoints, Water Characterization, Water Treatment

ABSTRACT

Dewatering is a critical task, with regard to safety, schedule, and cost, for the closure of
a Coal Combustion Residual (CCR) Impoundment (Pond). Dewatering of CCR ponds
consists of the decanting of free (ponded) water and the dewatering of pore water to
lower the phreatic surface. Decanting of ponded water may potentially lower the
phreatic surface within the impounded CCR, which may help to reduce schedule and
cost of dewatering pore water. It is important to remember during planning and
characterization for CCR pond dewatering that no two ponds are alike. Planning for
dewatering should include evaluation of the different methods for decanting of the
ponded water, and dewatering of the pore water. This paper provides overview of the
passive and active methods/systems available for dewatering pore water within CCR
Ponds: gravity outlets, siphons, sumps, well points, deep wells, eductor wells, horizontal
wells, etc. A brief discussion of the applicability of each method to CCR dewatering and
the limitations of these methods and the characterization of a CCR pond for evaluation
of applicability of methods is also provided in the paper. The paper also includes an
overview of dewatering discharge limitations, which in the authors’ opinion may possibly
be the most limiting factor in implementation of pond dewatering. Finally, a discussion of
the planning and characterization of the waste water discharges and water treatment for
the dewatering discharge is presented.

INTRODUCTION

The advent and promulgation, by the Environmental Protection Agency (EPA), of new
rules governing Coal Combustion Residual (CCR) disposal and discharge of CCR
waste water has fostered a heightened planning and implementation for closure of CCR
ponds. A critical part of the planning and implementation of closure of a CCR
impoundment (pond) is the decanting and dewatering of the pond. For the purpose of
this paper, the term dewatering includes both the decanting of ponded water (free
water) within the pond and the lowering of the phreatic surface within the impounded
ash. Both of these water removal activities are necessary to facilitate either closure by
re-grading and covering or capping of the pond – Closure In Place (CIP) – or closure by
excavating all of the CCR – Closure by Removal (CR). A critical and often limiting part
of the implementation of CCR pond dewatering is the quality and/or quantity of the
dewatering discharge. In some cases the decanting of discharge may be allowed under
current discharge permits, however if these permits require revision/update, then the
discharges will be need to meet the new Effluent Limitation Guidelines (ELG),
promulgated by the EPA. Planning for the dewatering of a CCR pond should include the
characterization of expected discharges from both the decanting of the pond and the
dewatering of the pore water. Teaming with experienced engineers and contractors is a
key factor for success in the implementation of CCR pond dewatering. Another key
factor for success is the characterization of the CCR Pond, which includes geotechnical
investigation, hydrogeology and characterization of the expected waste water discharge
from dewatering. This paper will provide general guidance for the planning and
characterization required to facilitate the successful implementation of CCR Pond
dewatering.

NEW FEDERAL RULES GOVERNING CCR POND DEWATERING

Two new federal rules were recently promulgated for CCR disposal, and effluent
limitations for CCR waste water discharges from coal-fired power plants. The first rule,
governing disposal of CCR, became effective on October 19, 2015. The CCR disposal
rule was promulgated under Subtitle D of the Resource Conservation and Recovery Act
(RCRA) and is published in the Code of Federal Regulations in 40 CFR Parts 257 and
261. The rule consists of requirements for the CCR disposal unit location, groundwater
monitoring, groundwater remedial action, engineering design, inspection, operation,
closure design, and post-closure care. The second rule, which establishes effluent
limitations for CCR waste water, became effective on January 4, 2016. Effluent
Limitation Guidelines (ELG) are established in this new rule that was promulgated under
the Clean Water Act and published in 40 CFR Part 23. These ELGs are being used as
guidance for setting stricter limits on CCR pond dewatering discharges.

GENERAL PHYSICAL CHARACTERISTICS OF CCRs

CCRs are by-products from the burning of coal in boilers for steam electric generation of
power. There are two major categories of CCRs: ash materials and Flue Gas
Desulfurization (FGD) solids. Ash materials generally consist of fly ash and bottom ash,
and are generated from coal-fired boilers. FGD solids are generated from scrubbing of
the coal-fired boiler flue gas to remove Sulfur Dioxide. Fly ash and bottom ash are both
vitrified clay materials. Ash materials are relatively lightweight when compared to soil
materials of similar grain size classifications. FGD solids can be from either a
calcium/magnesium-based (limestone or dolostone) or sodium-based scrubbing
systems. This paper will focus on the two types of solids generated using the
calcium/magnesium type scrubbers: Calcium Sulfite (CaSO3) and Calcium Sulfate
(CaSO4).
Fly ash consists of fine spherical particles, of a powdery texture, which are carried up in
the flue gas. Fly ash particles are collected either using wet collection (i.e. electrostatic
precipitators) methods or now more readily used dry collection methods (i.e.
baghouses, cyclones, and dry electrostatic precipitators). Figure 1 shows fly ash
particles at both the scale of naked eye and microscopic scale.

Figure 1. Microscopic and Visible Photographs of Fly Ash Particles

Fly ash consists of grain sizes smaller than 0.075 millimeters in diameter (Number 200
Mesh Sieve). Fly ash is of similar soil type as non-plastic Silt (ML) or Clay (CL), as
based on Unified Soil Classification System (USCS). The fly ash may be of the same
soil type by size; however fly ash does not have the structure of soil and is simply
ceramic/glass spheres. There are two classes of Fly Ash defining the pozzolon cement
properties: Class C (self-cementing high calcium fly ash) and Class F (low calcium fly
ash). The vertical hydraulic conductivity of fly ash is generally on the order of 10-5 to 10-4
centimeters per second (cm/s), based on laboratory testing. Horizontal hydraulic
conductivity testing, using in-situ methods, often results in hydraulic conductivities on
the order of 10-4 to 10-3 cm/s, possibly influenced by inter-beds of bottom ash or coarser
fly ash. Fly ash without bottom ash layers commonly has horizontal and vertical
conductivity on the order of 10-5 to 10-4 cm/sec.

Bottom ash consists of predominately angular gravel to sand size particles, which drop
to the bottom of the furnace and usually into a water-filled quenching tank. Bottom ash
is usually sluiced from the collection tanks or at some plants bottom ash is collected wet
then dewatered using a submerged chain conveyor. Bottom ash is of similar soil type as
Sandy-Silt (SM) or Poorly-Graded Sand or Gravelly Sand (SP), as based on USCS. The
vertical hydraulic conductivity of fly ash is generally on the order of 10-3 cm/s, based on
laboratory testing. Horizontal hydraulic conductivity testing, using in-situ methods, often
results in hydraulic conductivities on the order of 10-2 to 10-3 cm/s.
UNDERSTANDING OF THE OPERATION OF CCR PONDS

In the past, power plants would typically wet sluice all CCR to ponds for disposal. A few
plants dry collected and landfilled CCR or blended wet CCR with dry CCR (i.e. wet FGD
solids with fly ash). Recently, more plants have converted to “dry” CCR disposal
operations (landfills) and have been phasing out CCR ponds.

CCR Pond configurations include ring-dike ponds, canyon-fill ponds, or lay-of the land
ponds. Relatively smaller ponds, less than 100 acres, may be excavated ponds. CCR
ponds generally consist of a beach area closest to the sluice point(s) and a ponded
area, typically adjacent to the outlet of the pond (decant area). CCR would be sluiced
into the pond from either a single point, or multiple points, along the perimeter of the
pond. Pond operators may utilize rim ditching to sluice ash at multiple points for
dredging and stacking ash in areas of the pond. Operators would also direct other waste
water streams to these ponds for disposal and sometimes would pump back decant
water to the power plant for re-use. The decant water (ponded area) is either
discharged to local waterways (streams and river ways), as allowed under the
requirements of discharge permits, or returned to plant for reuse. Figure 2 illustrates a
typical CCR pond with perimeter dikes, ash delta, and ponded area (free water area).

Figure 2. Typical CCR Pond Configuration

A majority of CCR ponds were for collection of fly ash and bottom ash, however the
CCR materials sent for disposal at each pond usually varied by type of material and
operations. These different variabilities in pond configurations and operation are a
significant reason for the amount of work on characterization of the ponds, which is
described in the following sections.

UNDERSTANDING PHREATIC LEVEL, CAPILLARY FRINGE, PORE WATER

PRESSURES, DEGREE OF SATURATION, AND SPECIFIC YIELD

The phreatic level (or phreatic surface), also known as the groundwater level, water
table, or groundwater surface, is the water level during static conditions where pore
water pressure is equal to zero1. Below the phreatic level, the soil is typically fully
saturated (except for trapped gases), and the pore water pressure is generally equal to
the hydrostatic pressure (product of the distance below the phreatic level and the unit
weight of the pore water), provided there is no vertical component of seepage flow and
the soil has fully consolidated. The soil above the phreatic level is also fully saturated to
hc the height of capillary rise, which is inversely related to the average effective capillary
diameter of the soil; this zone is defined as the capillary fringe.
Fine-grained soils, such as silt and clay, have small effective capillary diameters and
relatively large capillary rises, whereas clean coarse-grained soils such as sand and
gravel, have larger effective capillary diameters much lower heights of capillary rise.
Table 1 indicates theoretical capillary rise values for water in various soils2 and has
been annotated with the approximate ranges of capillary rise for fly ash and bottom ash.
The equation used by Fetter for Table 1 is:

hc = (2σ cos λ)/( ρw gR);

where:
hc is the height of capillary rise;
σ is the surface tension of the pore fluid;
λ is the contact angle of the fluid meniscus with the wall of the capillary tube;
ρw is the density of the fluid;
g is the acceleration of gravity; and
R is the radius of the (glass) capillary tube.

There have been problems confirming the theoretical values in Table 1 for fine-grained
soils by observation in the laboratory3, probably because of the inherent difficulties in
estimating the appropriate values of several variables for natural sediment. However,
the table illustrates the relative magnitudes and trends of hc, and is useful for
understanding the behavior of fine-grained CCR above the phreatic level.

Table 1
Theoretical Heights of Capillary Rise for Water in Various Soils (Fetter, 1994)2

Theoretical
Capillary
Pore Radius Rise, hc ,in
Soil in mm cm (ft)
Fine silt 0.02 750 (25) Fly Ash
Coarse silt 0.05 300 (9.8)
Very fine sand 0.15 100 (3.3)
Fine sand 0.30 50 (1.6)
Medium sand 0.60 25 (0.82)
Bottom Ash
Coarse sand 1.00 15 (0.49)
Very coarse sand 4.00 4 (0.13)
Infiltration of rainfall into a subsurface formation is typically vertical and raises the
phreatic level temporarily. Horizontal seepage flow, transpiration by vegetation, and
evaporation lower the phreatic level. Over time, the phreatic level at any given location
fluctuates within a range determined by the variations in these natural processes
(termed the water cycle by hydrologists and water scientists).

A varying percentage of the total pore water will drain readily by gravity, whether this is
using sumps (open pits and channels), wells, or horizontal drains. Specific Yield (Sy) is
a ratio of the volume of water that will drain by gravity to the total volume of pore space.
A varying amount (volume) of water will remain in pore space after all drainage by
gravity is completed. Specific Retention (Sr) is a ratio of the volume of water that
remains, after drainage, to the total volume of pore space. Specific Yield and Specific
Retention has been expressed in terms of total porosity n (ratio of voids to total volume
is soil/rock) by the following:
n = Sy + Sr

Specific Yield and effective porosity are often used interchangeably to express the
same concept that not all pore water is available to drain by gravity from a material.
Specific yields vary over an order of magnitude for soils, ranging from 2 to 32 percent
for clays to fine sands. Specific yields for fly ash and bottom ash typically range from 5
to 15 percent and from 20 to 30 percent, respectively. Comparing the specific yield
(effective porosity) of fly ash to total porosity, which can range from 40 to 55 percent, it
is clear that only a relatively small volume of water is released from the pore space of fly
ash. Larger volumes of water can be released, however, but that would require either
compaction or application of suction to the pore space (vacuum pressure or negative
pressure). In the unsaturated zone, above the capillary fringe, water has drained from
pore space and air has started to enter the drained pore space. Pore water in the
unsaturated zone is semi-continuous and, in equilibrium, is acted upon by its own
weight and surface tension. Pore water pressures (gauge, or relative to atmospheric
pressure) in this zone are negative and can be even lower than negative one
atmosphere. Such water can remain in the sediment indefinitely at any elevation above
the phreatic level, if there is no water loss due to evaporation1. The discontinuous water
in this zone has been studied extensively by soil scientists because of its importance in
agriculture and also by geotechnical engineers and hydrogeologists in the evaluation of
seepage flow in unsaturated sediments. Figure 3 shows the relationship between the
degree of saturation (1.0 = fully saturated) and pore water suction head (1E+3 cm =
about 1 atmosphere at sea level) for varying densities of tested fly ash and bottom ash
specimens from northwestern New Mexico4. The ash specimens tested ranged from
relatively loose to relatively dense for each material. In Figure 3, fly ash differs from
bottom ash in that the degree of saturation is 0.9, or close to full saturation, for pore
water suction (negative gauge) heads of up to 100 cm (3+ ft), but only up to 10 cm (0.3
ft) for bottom ash. A degree of saturation of 0.9 is close to one minus the effective
porosity or Specific Yield of fly ash and therefore approaching the maximum volume of
water that will drain by gravity from fly ash.
 Figure 3, Saturation vs. Pore Water Suction - Fly Ash & Bottom Ash4

Nearly saturated loose fly ash will liquefy when either vibrations or shearing stresses
are imparted to it. This unstable behavior determines the maximum weight and
allowable contact (ground) pressure of construction equipment that can be effectively
operated on fly ash without engulfment of the equipment. The unstable behavior also
requires a layer of drier material above the loose saturated fly ash to reduce shearing
stresses induced by the movement of construction equipment to a level that the ash will
support. Estimates of the required thickness of dry ash commonly range from 5 to 15
feet of “dry” ash (or soil material) with and without geogrid at the base, respectively.
However, opinions vary widely for CCR ponds having saturated loose ash thicknesses
much greater than 15 feet.
PLANNING FOR CCR POND DEWATERING FOR CLOSURE

A typical CCR Pond (unlined impoundment), as illustrated in Figure 4 below, generally

has a perched groundwater regime within the impounded ash (CCR) delta (as illustrated
on the left side of pond). The ponded free water and the perched water in some cases
are mounded above the local/regional groundwater table. The phreatic surface of the
perched water within the delta is usually relatively close to the elevation of free water
surface. The ash within the pond delta above the capillary fringe is unsaturated and has
undergone consolidation due to downward seepage and desiccation. The ash below
phreatic is saturated and usually loose as it usually has not undergone sufficient
consolidation. The void ratios are typically high as a result of its fine grained texture and
the depositional environment, where most of the ash is hydraulically placed and/or
deposited underwater.

Figure 4. Typical Generalized Subsurface Cross-Section of an Ash Pond

Dewatering of CCR Ponds consists of two phases: decanting of free (ponded) water
and dewatering of pore water to lower phreatic level within CCR. The CCR disposal rule
(40 CFR Part 257) requires that removal of free liquid and lowering of the phreatic level
to provide a stable closed configuration. The following questions should be answered
before or during the planning of CCR pond dewatering:
 Schedule of closure - number of months (or years) allocated to dewatering
 Closure Method – Closure In Place (CIP) or Closure by Removal (CR)
 Discharge Limitations – Discharge Permit or Zero-Discharge?

The number of months allocated for dewatering of the pond and the closure method, are
critical to assigning the type of dewatering system that should be utilized and the size
and cost of the system. If the closure method is assigned as a CR, then all of the CCR
will be excavated. Therefore, for a CR the entire depth of CCR pond will need to be
dewatered to facilitate the operation of excavation equipment. In contrast, if CIP closure
method was selected, then the pond will likely require relatively shallower excavations
or may require stabilization of the CCR to support placement of fill for re-grading of the
pond. Illustrations of CIP and CR methods for pond closure are provided as Figures 5
and 6, respectively.
 Figure 5. Closure In Place - General Schematic

Figure 6. Closure by Removal - General Schematic

The location and limitations of the discharge point(s) for the CCR pond dewatering is
critical to evaluating the size and cost of the dewatering system, which may include
water treatment. The water treatment of dewatering discharge can quickly become a
constraint to the dewatering flow rate, which can extend schedules for dewatering and
will certainly add significant cost. If the power plant is a zero-discharge plant or if the
pond lacks a discharge point (permitted outfall), then either a new permitted discharge
will be required or the dewatering flows will need to be sent back to the plant for re-
use/consumption. If the re-use/consumption of water by the plant is the only option for
discharge of dewatering flows, this can significantly limit the flow rate of a decanting and
dewatering system, and extend the schedule for dewatering and ultimately for closure of
the pond.

Additionally, the planning for dewatering should include the characterization of the CCR
pond as follows:
 Type and size of CCR pond(s)
 Review of historical and current operation of the CCR pond(s)
 Assessment and quantification of current waste water inflows
 Geotechnical and hydrogeological investigation(s)
 Water chemistry sampling, testing, and characterization of free water and pore
water
 Pilot testing of dewatering system and trafficability over the CCR surface

Understanding that every pond is different and that the cost spent on characterization
may result in significant schedule reduction and cost savings in the implementation of
dewatering and closure construction.

It is recommended that a focused geotechnical investigation of the pond be performed

after review of the all available pond information: pond site, geologic setting, dam/dike
as-built information, and operational information. Through review of operational history,
an understanding of potential locations of coarser CCR materials may be determined.
Also, the Geotechnical and/or Hydrogeological Investigations may confirm underlying
geological conditions (e.g. a sand layer), which can be critical to providing efficiencies to
dewatering the CCR Pond. These coarser areas (i.e. areas of bottom ash) within the
impounded CCR ponds have been characterized as the “sweet-spots” and may provide
improvement to schedule and cost if dewatering is focused in these locations. Focusing
investigations, including a pilot test (well pumping test) in these areas of coarser
materials may change the dewatering strategy and reduce both schedule and cost.

A preferred exploration tool for dewatering planning for CCR ponds is the Cone
Penetration Test with pore pressure measurements (CPTu). A limited number of test
borings should also performed to confirm the CPT results. Undisturbed samples may
also be collected for laboratory testing of permeability. However, it is opinion of the
authors that laboratory testing is not necessary provided hydraulic conductivity is
calculated using CPT data. Use of a piston sampler is a preferred approach for
collecting undisturbed samples in finer CCR (i.e. fly ash). Proper precautions are
advised when handling and transporting of the fine fly ash samples, which can be prone
to densification. As CCR is a manufactured material with somewhat consistent index
and hydraulic properties, utilization of CPTu soundings with sufficient experience of this
exploration method in CCR can facilitate a relatively quicker geotechnical investigation
of a pond.

CCR POND DECANTING

The first step in dewatering the CCR pond to facilitate closure is decanting of the free
water or ponded water areas. Decanting of the pond can be facilitated through use of:
  existing gravity systems (i.e. pond outlet structures),
 siphons, or
 pumping systems.

The first step in planning and implementation of decanting and later dewatering of pore
water is the shut-down or re-routing of all waste water streams to the CCR pond. The
next step or critical planning/design task is the diversion or attenuation of stormwater
flows and/or the evaluation of the stormwater allocation that may be required to be
maintained during decanting and dewatering. Any limitations on the free water pond
drawdown should be quantified during planning of decanting. Many of these CCR
Ponds are state jurisdictional dams and there may be limitations on drawdown of the
water level behind the dam. Another potential limiter to decanting flow rate may be the
limitations (e.g. effluent limitations) of the discharge point. A determination through
adequate characterization of the CCR pond for the need of a water treatment system
should be completed. The incorporation of a water treatment system (e.g. filtration or
Reverse-Osmosis) will likely reduce decanting flow rates and increase the area required
for decanting equipment.

After the characterization of the pond, and decanting limitations are determined, a
selection of decanting method can be completed. In many cases the use of current
gravity outlets are not feasible either due to water quality concerns or drawdown
limitations for the pond (dam safety). An active system or pumping system is usually
utilized for decanting the free water and allows for connection to an active treatment
system, if required. If an active system is selected, then either a suction pump or
submersible pump system will be utilized for decanting. Use of a suction pump is
preferable over a submersible pump as the suction pump may allow for better control of
water quality at the intake point. However, there is a limitation suction lift height
(approximately 15 to 25 feet), depending on atmospheric pressure, suction head losses,
and the Net Positive Suction Head Required (NPSHR) for the pump. The suction lift
height limitation does not exist with submersible pumps. This suction lift limitation may
be overcome by utilizing a floating suction pump or barge pump.

The decanting of the free water pond, depending on the depth, should help to lower the
phreatic level within the impounded CCR, if given sufficient time for “drain-out” of the
CCR during decanting. Therefore, after decanting and before implementing dewatering
of the pore water, it is recommended that measurement of the phreatic levels within the
CCR be performed. The installation and measurement of piezometers during decanting
may provide a valuable set of data and may help to further characterize the CCR pond
for dewatering of pore water.

CCR PORE WATER DEWATERING/STABILIZATION METHODS

In general there are four categories of methods for dewatering/stabilization:

 open pumping or drainage (passive dewatering method),
 subsurface pre-drainage (active dewatering method), and
 mechanical/chemical stabilization (densification and soil-pozzolan mixing)
This paper focuses only on both passive and active dewatering methods.

Open Pumping or Drainage (Passive Dewatering)

The passive dewatering method consists of using open drainage methods that consist
of drainage channels and sump pits. In general the maximum depth of effective
dewatering is between 10 to 20 feet, with depths between greater than 10 feet usually
reserved for relatively consolidated bottom ash materials, as illustrated in Figure 7.

Figure 7. Open Pumping/Drainage (left - drainage channel, middle – perimeter

drainage channel, right – sump dewatering (bottom ash).

Design of open dewatering systems is more experience-based (state of art versus state
of science), however the spacing of drainage channels can be roughly estimated using
some of the same spacing equations used for the spacing of dewatering wellpoint
systems:

Line Sink Analytical Methods and/or Empirical Drainage Trench Equation

Q = [x·K·(H2 – h2)] / 2·(R0 or 2L) - Powers (2007)5 AND/OR

T= (2·t·kh·H)/(c·ne·L2 ) - Casagrande/Shannon (1952)6

Subsurface Pre-drainage Methods (Active Dewatering)

Active dewatering method is broadly defined as pumping from drains or wells
(wellpoints, wells, or horizontal wells/drains) for the purpose of lowering the phreatic
surface in an unconfined water-bearing stratum to a target elevation that is below the
proposed finished grade. The effective depth of active dewatering systems ranges from
15 feet, for well points, to over 100 feet, for deep wells. Figure 8 provides a general
schematic of active pumping for decanting as well as active dewatering methods (with
exception of horizontal wells/drains).

Figure 8. Schematic of Active Pumping Decant and Active Dewatering Methods

Deep wells are cased holes with a perforated well screen opposite the formation
pumped and have a length-to-diameter ratio that is typically greater than 20. Deep wells
are pumped with a pump in the well, usually a submersible, but sometimes a jet eductor
pump. They are usually surrounded by a sand or gravel filter designed to hold back the
fine particles in the permeable formation in which the well is installed. The well is sealed
with an impervious backfill around the casing above the screen to prevent leakage
through the annulus around the casing. Wells in CCR are usually pumped with 4-in.
diameter submersible electric pumps and sometimes sealed for application of vacuum
to the well casing to induce drainage of fine-grained CCR (e.g., fly ash). Vacuum pumps
and a separate air manifold are required if vacuum is applied to a well system. Pumps
for wells in coarser grained CCR (e.g. bottom ash) may be larger in diameter but usually
never larger than 6 inches for well capacities of up to 300 gallons per minute (gpm). The
smallest practical submersible pump capacity is about 5 gpm; the pump flow capacity is
limited by the diameter of pump that will fit in the well casing. The efficiency of small
submersible pumps is typically between 65% and 75%. The principal advantages of
using wells for dewatering is that the submersible pumps are not subject to the suction
lift limitations of wellpoint pumps (self-priming suction pumps with air handling capacity),
and fewer wells are required than wellpoints. Disadvantages are that the CCR may be
too weak to support well installation equipment without constructing “floating” roads, and
the unit cost of wells is significantly greater than the unit cost of wellpoints, even without
the cost of improved access.

Eductor wells are wells that are pumped with jet pumps (consisting of a cast iron body
with a foot valve, nozzle, and venturi tube) and are typically 4 inches inside diameter
(ID), which is the minimum ID for commercially available twin-pipe jet eductors (Figure
9).
 Figure 9. Typical Jet Eductor Well (courtesy AECOM)

The typical efficiency of a jet eductor is about half of the efficiency of a submersible
pump with the same capacity. The advantages of pumping a well with a jet eductor are
that (a) the lift is practically unlimited, and (b) the eductor will pump both air and water
and can maintain a partial vacuum inside the well casing and well filter. The initiation
and maintaining of partial vacuum in well is dependent on proper well casing seal and
the stratification of the aquifer is such that air entry is small. Eductor wells are typically
advantageous in dewatering only when the expected steady state flow to the wells is not
greater than about 2 to 3 gpm per well. Also inducing a small (5 to 10 ft. of water) partial
vacuum in the well filter is desirable to improve drainage of a fine-grained soil (e.g. fly
ash) that either will not drain or does not drain as well when no partial vacuum is
applied. A variation of an eductor well is an eductor wellpoint, in which a small diameter
wellpoint screen is attached to the suction of either a twin- or concentric-pipe jet eductor
(Figure 10).
 Figure 10. Typical Jet-Eductor Wellpoint System Plan, Section, and Details (U.S.
Army Corps of Engineers, TM 5-818-5, 1985)

Operation of a jet eductor system requires a pump supplying high pressure water
through a pipe manifold to the wells and a low pressure return manifold that conveys the
return water (including the drive water plus the groundwater picked up in the wells) back
to a recirculation tank at the pumping station. A typical jet eductor system is shown in
plan, section, and detail in Figure 10.

Wellpoint systems have been used in pre-drainage of CCR. Usually, wellpoints are
about 2 inches in diameter with screens 2 to 4 feet long. Wellpoints are well suited to
pervious and semi-pervious soils and a wellpoint system consists of individual
wellpoints in the ground connected to a suction pump system on the ground surface. By
definition, a dewatering wellpoint includes a drawdown pipe so that water entering the
wellpoint screen above the bottom of the drawdown pipe is forced to flow downward in
the annulus between the drawdown pipe and the wellpoint screen. Wellpoints are
typically installed in rings or lines, with center to center spacing varying from 3 feet to 10
feet. Screens, meshes, and or geotextiles are included in each wellpoint to prevent
infiltration of surrounding soils during pumping, and a select sand filter is placed in the
annulus between the wellpoint and the drilled or jetted hole in which it is installed.
Wellpoints are usually jetted into place. Small (2-in. diameter) wellpoints can be jetted
into place manually using a small (about 5 men) crew working on plywood and/or
geogrid with the jetting pump located on stable ground at a distance from the installation
locations. Filter sand, pipe, and wellpoints can be transported in a suitably sized swamp
buggy to the wellpoint locations. The filter for wellpoints in fine CCR should be carefully
designed in order to prevent pumping solids. Aggregate filters are usually best, but
geotextiles can be used also if test pumping shows that the CCR will not plug the
geotextile.

Wellpoints operate by applying vacuum to the wellpoint from a pumping system at the
ground surface. In an ideal wellpoint system, the vacuum is regulated such that the
wellpoints either will not break suction or every wellpoint is installed at a depth (30 feet
or more) below the pump suction such that breaking suction is not possible. High
vacuum wellpoints, used only in very fine silty soils (such as fly ash) that do not readily
drain by gravity, are installed a maximum of 15 feet below the pump suction and are
designed to break suction in order to develop a partial vacuum in the sand filter around
the wellpoint screen and riser pipe. To minimize air entry, the holes for the wellpoints
are sealed around the riser pipes, preferably against a continuous clay stratum.
Because high vacuum wellpoints are intended to break suction, providing adequate air
handling capacity in the pumping system is crucial. If seals are ineffective, the most
practical way to overcome excessive air entry is generally to increase the air handling
capacity of the pumping system. An idealized example of a high vacuum wellpoint
installation is shown in Figure 11.

Figure 11. High Vacuum Wellpoint Installation (U.S. Army, TM 5-818-5)

Although horizontal wells or drains have not been widely used or reported for
dewatering of CCR, they have the potential to be economical and effective when the
stratigraphy, pond geometry, CCR characteristics, and groundwater conditions are
favorable. Seeger and Kosler7 (WOCA 2017) have reported results of field and
demonstration and laboratory bench testing of a proprietary method (Vacuum
Consolidation Dewatering, or VCD) as well as conceptual sketches of a device that
could be used to install horizontal drains at CCR ponds. A horizontal drain or well is
usually pumped with a wellpoint pump (centrifugal or positive displacement pump that
can handle both water and high air volume at high relative vacuum or low absolute
pressure). The principal advantage of a horizontal well system is that it can conceivably
be installed near the bottom of the CCR pond and the surface would be clear of
obstructions. Drawdown would be limited to around 15 feet if pumped with a wellpoint
pump. Using submersible pumps would require installation of manholes or vertical riser
pipes to tee into the horizontal portions. A compromise to overcome the lift problem
would be to install a straight inclined section of pipe at the beginning or end of the
horizontal well if there is sufficient room and push a submersible pump on skids to the
base of the inclined section of the well, above the curvature. One important problem
with horizontal wells is that there is no technology available to install a natural
aggregate filter of adequate thickness around the slotted well and a geotextile has to be
used for filtration. If the geotextile becomes blinded by mineral precipitation and/or
bacterial slimes, it will likely be impossible to rehabilitate the well to restore its efficiency.

As introduced in the previous discussion of open dewatering methods, the design (or
spacing) of active dewatering methods can initially be evaluated using line sink
equations. The length of pumping time available in advance of closure construction
activities will have a significant effect on overall cost of pre-drainage in fine-grained
CCR. The longer the available pumping time, the more widely spaced the dewatering
devices can be to achieve the required drawdown by the time grading for closure starts.
Evaluation of pumping time requires knowledge of the hydraulic characteristics
(hydraulic conductivity and storativity) of the: CCR, CCR pond containment structures,
the underlying soil and rock stratigraphy. This evaluation also requires knowledge of the
local and regional groundwater conditions

Pilot Testing
In addition to test borings and cone penetrometer soundings, pilot pump testing at
several locations in a large pond is highly recommended to confirm the practicality of
pre-drainage and the effectiveness of filters, because CCR hydraulic characteristics in
sluiced ponds vary widely both laterally and vertically. Many ponds have been used for
the disposal of fly ash, gypsum (FGD), and bottom ash. The presence of deeper layers
or interbeds of laterally extensive bottom ash can reduce pre-drainage costs greatly,
and the existence of very fine CCR with plasticity may mean that pre-drainage is not
practical for locations where it exists. Testing can be as simple and inexpensive as test
pumping individual wellpoints at several locations to pumping multiple test wells or
wellpoint lines for 1 to 3 days. To evaluate the performance of the pilot dewatering
pumping system, measurements of drawdown in piezometers at varying radial
distances from the pumping well(s) or at varying distances from a wellpoint line should
be collected. These data should be analyzed to evaluate the hydraulic conductivity and
storativity characteristics of the CCR, test excavations, and trafficability testing to
evaluate what earthmoving, excavating, and grading equipment can be used for
closure.

MANAGEMENT AND CHARACTERIZATION OF FREE WATER AND PORE WATER

DISCHARGES DURING DEWATERING

Management of wastewater discharges from CCR pond closures involve:

1. Understanding the discharge limits (typically a federal or state surface water

discharge permit) establishing permissible concentrations (or mass loadings) of
physical and chemical constituents in the free water and interstitial (pore) water
(i.e. ash entrained water) during decanting and dewatering operations. These
permits may be issued with specific limits applied to decanting and dewatering
operations which may be more stringent than the CCR ponds’ previous operating
discharge permit.

2. Characterizing free water and pore water physical and chemical constituents to
determine compliance status with the wastewater discharge permit and, if
necessary, physical, chemical, and/or biological treatment required to meet
discharge compliance requirements.

Table 2 provides an example of the typical sampling and analysis for a suite of physical
and chemical parameters for characterization of free and pore water.

Table 2
CCR Pond Free Water Characterization – Typical Physical and Chemical
Parameter Analyses
Physical Parameters Metals Nutrients
 pH  Arsenic  Nitrate (NO3)
 Total Dissolved Solids  Selenium  Nitrite (NO2)
 Total Suspended Solids  Mercury  Total Kjeldahl Nitrogen
 Oil & Grease  Copper  Phosphorus
 Petroleum Hydrocarbon  Iron
 Turbidity

CCR Pore Water Characterization -

Laboratory evaluation of groundwater samples collected from one or more wells is
useful technique for identifying well fouling mechanisms. Each well selected should be
pumped or bailed for approximately 5 minutes and a 1-liter sample collected for
shipment to a laboratory. The temperature, total dissolved solids (conductivity method),
oxygen reduction potential (ORP) and pH of the well water should be measured and
recorded in the field when samples are collected. The following tests are recommended
(as a minimum) for evaluation of the pore water chemistry as it relates to well fouling:
 pH
 Temperature
 Oxidation-Reduction Potential (ORP)
 Total Alkalinity as CaCO3
 Total dissolved solids (TDS)
 Hardness (including carbonate and non-carbonate)
 Calcium ion concentration as CaCO3
 Silica ion concentration (as SiO2)
+2 +3
 Iron concentrations (including Fe , Fe , and total)
 Manganese concentration

These parameters will aid in two ways. First, these parameters can be used in the
calculation of the Langelier Saturation Index (LSI) to characterize the base water
chemistry. Second, they will allow for the monitoring of changes in key ion
concentrations that may reflect accumulation or dissolution occurring down-hole.
The LSI is a measure of the saturation of calcium carbonate and as such, is a predictor
of whether a scale will form or not. For scale formation, the water must have a LSI
greater than 0.0. The LSI is calculated approximately using the following formula:

LSI = pH - pHs

pHs = (9.3 + A + B) - (C + D)

where:

A = (Log10 [TDS] - 1) / 10

B = -13.12 x Log10 (°C + 273) + 34.55

C = Log10 [Ca+2 as CaCO3] - 0.4

D = Log10 [Alkalinity as CaCO3]

There are a number of on-line calculators for the LSI.

Bacteriological analyses are useful in predicting the probability of bacterial as well as

mineral plugging being a problem. Schnieders8 recommends performing the
heterotrophic plate count (HPC) test to determine the number of colony-forming units
per unit volume of water and the adenosine triphosphate test (ATP) to determine the
number of bacteria per unit volume. The HPC allows correlation with other work in the
industry while the ATP accounts for a much better assessment of the actual population
numbers as it is not dependent on culturability as with the HPC. More than 90% of all
bacteria are non-culturable. Schnieders also recommends microscopic examination of
water samples to identify bacteria that can be identified visually as well as iron-oxide
accumulation, sand infiltration, presence of protozoa, and other abnormalities 8.

The ORP measurement provides a reasonable way to distinguish between aerobic vs.
anaerobic bacterial activity. This statement is true where high population numbers are
present or verified by analysis.

Finally, it is recommended that a laboratory with experience in evaluating incrustation

and corrosion problems in water wells be engaged perform the pore water analytical
work and to provide an interpretive report along with the laboratory test results.

The actual suite of analytical parameters to be selected for characterizing free and pore
water will be site and receiving water specific, dictated primarily by the discharge
receiving water and associated discharge permit under which the site’s closure
decanting and dewatering operations will be conducted. Soliciting guidance from
regulatory permitting authorities is recommended early in the pond closure planning
process to understand site specific wastewater management/discharge requirements
under which pond closure activities will be conducted.

In addition to conducting physical and chemical analyses of free and pore water, the
following are important considerations in the pond closure planning with respect to
water quality and wastewater management

 Collection of free water samples and pore water samples at various depths
through the free water matrix and accumulated ash material. Changes (i.e.,
increases) in pollutant concentrations with increasing depth may present and
need to be considered in any discharge compliance and treatment planning.
 Conducting metals and Total Suspended Solids analyses on filtrate from serial
filtrations of collected samples (suggest 20µ, 10µ, and 0.45 micron filtration). This
will allow observation of the effect of physical filtration (as a presumptive
treatment) on reducing the concentrations of various metal species (present in
particular form) and Total Suspended Solids.
 Analyzing samples to determine the presence and concentrations of speciated
Arsenic and Selenium. In wastewaters associated with coal combustion
residuals, Arsenic and Selenium may exist as oxyanions (Arsenite [As III],
Arsenate [As V], Selenite [Se VI], and Selenate [Se VI]). Unlike cation forms of
other heavy metals (e.g., Cu+2, Pb+2, Cr+3), the anionic complexes of Arsenic and
Selenium will not be removed from wastewater using conventional chemical
precipitation processes.
 If discharge toxicity limits are applicable to a specific surface water discharge
permit, conduct Whole Effluent Toxicity (WET) testing on free water and pore
water samples to determine if (and which) discharge pollutants may be toxic to
the permit stipulated test organisms. A discharge to surface water may exhibit
 toxicity even though the concentrations of discharge permit monitoring
parameters are below the established discharge permit limits.
 Be aware if the discharge receiving stream is designated as impacted by specific
discharge loading restrictions not included in the permit (i.e., the receiving stream
is Total Maximum Daily Load restricted).

Expect the characteristics of free water and pore water within the same pond to vary
with depth (i.e., concentrations increasing with depth and for pore water to be of lower
quality than free water). Free water and pore water from pond to pond (on the same
site) and from site to site may differ significantly. These differences may be attributed to
(but not necessarily limited to):

 The influent waste stream sources to the CCR ponds (i.e., historical operations)
and how these waste streams may be (or may have been) managed upstream of
the CCR ponds.
 The sources and management of precipitation runoff streams as influent to the
CCR pond.
 The sources/types of coal being burned or historically burned at the plants.
 Source waters used for conveyance of combustion residual materials to the CCR
ponds.

Treatment of free water and pore water may require implementation of one or more of
the following:

Total Suspended Solids and Turbidity

 Sedimentation (conventional or enhanced), including lamella clarification,

ballasted flocculation, with chemical coagulation.
 Filtration, including enhanced filtration (e.g., membrane microfiltration).

Dissolved Metals

 Chemical precipitation (as metal hydroxides or metal sulfides)

 Molecular filtration (reverse osmosis)
 Electrocoagulation
 Sulfur impregnated activated carbon (mercury)

Oxyanion Metal Species

 Zero Valent Iron

 Anaerobic biological treatment

Nutrients

 Chemical precipitation (Phosphorus, chemical precipitation/coagulation and

magnetite ballasted flocculation)
  Aerobic/anoxic biological treatment (phosphorus and nitrogen).

Zero Liquid Discharge

 Brine evaporation/crystallization
 Recycle as plant process water

In addition to addressing requirements for meeting site specific discharge limits, the
selection, design, configuration and implementation of treatment technology for CCR
pond closure free water and pore water discharges should include the following
considerations:

 Treatment systems operations will be temporary and decommissioned following

removal/discharge of free and pore water.
 Mobile treatment configurations allow for the restaging of treatment at multiple
locations on a particular site when multiple pond closures are part of a closure
project portfolio.
 Remote location staging of wastewater treatment system require the use of
portable (non-grid) electric power generating systems (e.g., diesel generators,
micro turbines).
 Ground surface located influent and effluent conveyance piping may require
protection from severe weather conditions (e.g., freeze protection/heat tracing).
 Unattended/remote treatment systems should incorporate telemetry for
emergency remote operation and operation monitoring/alarm annunciation and
communication.
 Attended operations and maintenance to be conducted by plant site personnel or
through contract operations (by treatment system vendor or operations and
maintenance contractor).
 Packaged mobile systems minimize on-site construction activities and expedite
treatment system commissioning and decommissioning activities.

Two options for the procurement and implementation of required wastewater treatment
system typically employed for CCR pond closure projects are (1) engineer
designed/specified procurement package and (2) performance based specification
procurement of vendor designed/supplied system.

The advantages and limitations for each of these procurement/implementation options

are summarized in the following table:
 Table 3
CCR Pond Dewatering – Water Treatment System Implementation Option

Treatment System Implementation Option

Engineer Design/Specification Performance Based Specification
Advantages  Treatment process selection  Opens options to vendors for
by engineer – all base bids proposing multiple treatment
to the same treatment. technologies (no limitations on
 Simplifies/expedites bid technology options).
evaluations.  Likely results in lower total
implementation costs.
 Provides opportunity for
expedited project
implementation.
Limitations  Limits bidders’ flexibility in  Complicated bid evaluation
providing treatment process by requiring review of
technology (unless bid multiple treatment technologies.
options are included in the  Vendors’ bids will tie
technical specifications) performance warrantees to
 Likely results in a higher wastewater characterizations
implementation cost. provided in performance
specifications (deviations from
specified wastewater
characterization will likely void
performance warrantee, delay
project execution, and likely
result in higher execution costs.

In planning CCR pond CCR pond closures, with respect to free water and pore water
management, the following guidance and lessons learned are offered:

 Engage environmental regulators early in the closure planning process in order

to have a mutual understanding of the potential discharge permit limits that will
apply to the project and to maintain an opportunity for negotiations. Don’t assume
that an existing (or historical) pond operating wastewater discharge permit will
necessarily apply to free and pore water discharges during closure activities.

 Prepare comprehensive characterizations for free and pore water including:

o Sampling/analyses through vertical profiles in the free water and accumulated

ash.
o Conducting analyses for Arsenic and Selenium species.
o Conducting Whole Effluent Toxicity (WET) testing on free and/or pore water
samples if WET requirements will be part of the closure project’s wastewater
discharge permit.
 o Consider conducting treatability testing (or include in the treatment system
performance based specifications).

SUMMARY
In closing this paper has provided guidance for planning and characterization for the
dewatering of CCR Ponds to facilitate closure. Dewatering of CCR ponds consists of
decanting the free water and dewatering of pore water to lower the phreatic condition to
allow for operation of construction equipment for closure. The schedule and cost of
dewatering may be determined by the overall schedule for closure, the free water
drawdown limits (i.e. dam safety), and the requirement for water treatment.

REFERENCES

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[2] Fetter, C.W., Applied Hydrogeology, 3rd Edition, Macmillan, New York, 1994

[3] Salim, R.L., Extent of Capillary Rise in Sands and Silts, Master’s Theses, Paper 688,
Western Michigan University, April 2016

[4] Webb, R.W. Stormont, J.C., Stone, M.C., and Thonsen, B.M., Characterizing the
Unsaturated and Saturated Hydraulic Properties of Coal Combustion By-Products in
Landfills of Northwestern New Mexico, Journal of the American Society of Mining and
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[5] Powers, J. Patrick, Corwin, Arthur B., Schmall, Paul C., Kaeck, Walter E.,
Construction Dewatering and Groundwater Control – New Methods and Applications,
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[6] Casagrande, A. and Shannon, W.L., 1952, Base Course Drainage For Airport
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[7] Seeger, David M., Kosler, Steven, Smarter, Cheaper, Ash Pond Dewatering, World
Of Coal Ash, 2017, Lexington, Kentucky.

[8] Sterrett, R.J., Groundwater and Wells, Third Edition, Chapter 13, Well Blockage and
Rehabilitation, John Schnieders, Author, pages 597-628, Johnson Screens, a
Weatherford Company, New Brighton, MN, 2007.