Coal Ash Ponds and Ash Disposal Issues is Hot Topic on January 13 and 14,
2011
NOTE: Because of the strong interest in this subject and the number of persons
that will make presentations, this Hot Topic Hour has been split into two
sessions – one on Thursday, Jan. 13th and the second on Friday, Jan. 14th both
starting at 10 a.m. CST. Persons that register to attend will be able to
participate in both sessions.
The extended period for public comments on the proposed rule on Coal Combustion
Residuals (CCR) (commonly referred to as coal ash) concluded on Nov. 18, 2010.
Now, if the EPA follows their normal rule making process, we can expect a final
rule promulgated in early 2011. The big question is will the final rule classify
CCR as special wastes subject to regulation under subtitle C of RCRA (Resource
Conservation and Recovery Act) when destined for disposal in landfills or
surface impoundments (essentially hazardous waste) or as non-hazardous wastes
regulated under subtitle D of RCRA. If EPA decides to classify CCR as
“hazardous,” under subtitle D, EPA would create federally enforceable
requirements for ash management, including waste generation, transportation and
disposal. If CCR is declared non hazardous, under subtitle C, EPA would only
mandate a set of minimum national standards and leave it up to state governments
and citizen litigation to enforce them.
There are four basic types of “coal ash” - fly ash, bottom ash, boiler slag and
FGD gypsum sludge. Up until the 1970’s, almost all coal burning plants have been
transporting all ash wet as a slurry and dumping it into holding ponds (also
call surface impoundments) for long-term disposal. In the 1970’s, plants began
to adopt dry handling systems especially for the fly ash so it could be sold or
disposed of in a dry landfill. Today approximately 90 percent of fly ash is
handled dry but 90 percent of bottom ash and much of the gypsum sludge are still
handled wet and placed in ponds. EPA has identified 580 surface impoundments for
wet disposal and 300 landfills for dry (or semi-dry) disposal in use today. In
addition, about 40 to 50 percent of the fly ash generated and 50 percent of the
FGD gypsum are being sold for beneficial reuse in concrete, wallboard and a
dozen other applications. In either of the above regulatory scenarios, the more
stringent regulations will require that protective liners be added to the ponds
and landfills that hold coal ash and most likely eventually eliminate wet ash
handling entirely and phase out surface impoundments (ponds) for all coal-fired
power plants. If coal ash is declared a hazardous waste, the phase out will
proceed much faster and this will significantly reduce the portion of ash and
gypsum sold for beneficial uses.
The following speakers will address the potential impacts of the eventual
regulations on the coal-fired power plant industry, methods that can be employed
to mitigate the problems sure to be created, what will need to be done to comply
with the expected regulations and systems and technology for eliminating wet ash
handling and slurry storage in ponds.
The speakers on Thursday, January 13th will be:
Tom Adams, Executive Director, American Coal Ash Association (ACAA), will
provide comments on the impact of the proposed regulations on the beneficial
uses of coal ash. The U.S. EPA has proposed regulations for the disposal of coal
combustion products (CCP). While there is a consensus that some form of disposal
regulation is needed, there is a wide range of opinion on what the impact of a
hazardous waste regulation would be on the future of beneficial use of CCP. The
agency believes it can exempt preferred beneficial uses from any hazardous waste
regulations and markets for those preferred beneficial uses will be unaffected
at the least, or flourish as generators will invest in technologies to make
their CCP more attractive to the end users. In over eighteen months of
discussions with CCP marketers, project owners, engineers and architects,
contractors, material producers and other stakeholders, the ACAA has determined
that the U.S. EPA is wrong in its prediction of market behavior. The stigma of
association with hazardous waste regulations and potential liability exposure
are primary concerns in the marketplace. This discussion will detail examples of
these concerns and others provided to the EPA in the docket for the proposed
rule.
Joshua R. More, Partner, Schiff Hardin LLP, will discuss compliance issues with
the proposed CCR RCRA rule and present a case study of closure of an unlined CCR
impoundment. On May 4, 2010, U.S. EPA issued a proposal to regulate Coal
Combustion Residue (CCR) under the Resource Conservation and Recovery Act. The
proposal consists of two regulatory options: (1) regulating the material as a
“special waste” under Subtitle C or (2) as a solid waste under Subtitle D. Under
Subtitle C, CCRs would be regulated as a “special waste” and most of the
hazardous waste requirements would apply to CCRs – including generation,
transportation and storage requirements. Under Subtitle D, CCRs would be
regulated as a solid waste and only the disposal of CCRs would be regulated. The
CCR landfill engineering/technical requirements of the two proposals are very
similar; the differences are primarily in how the proposals will be enforced and
implemented.
The second part of his presentation describes how working with state regulators
a utility was able to close an unlined surface impoundment. Like most states,
surface impoundments in Illinois are regulated under groundwater quality rules.
These rules provide for protection of groundwater quality and do not
specifically address design or closure standards for surface impoundments. The
Illinois Environmental Protection Agency initially proposed to regulate the
closure of surface impoundments under the landfill rules. However, the landfill
rules were promulgated after many of the CCR impoundments in Illinois were
built, specifically exclude surface impoundments and include numerous design
criteria that are impractical for surface impoundments. Therefore, the utility
and its legal team, supported by technical analyses from its environmental
consulting team, worked with the state to develop a set of site-specific rules
governing closure of a CCR impoundment. The site specific rule has become the
model for closing CCR impoundments in the State of Illinois.
Mr. R. Glenn Lunger, PE, Manager, Power Market at FLSmidth, Inc., Pneumatic
Transport - Wet conveying and storage of combustion products appear to be on the
brink of extinction with proposed regulation of coal combustion residuals and
water usage. There are many considerations that need to be addressed in
retrofitted and new dry conveying systems as utilities kick off mitigation
projects. FLSmidth has been providing a number of dry pneumatic conveying
solutions for combustion products for over 40 years and will review specific
options.
The speakers on Friday, January 14th will be:
Ari Schoen Lewis, Environmental Toxicologist and Manager of the Toxicology Team
at Gradient Corporation, will discuss human health risk assessment and the
regulation of coal combustion residues (CCRs). In support of the Proposed Rule
to regulate CCRs, U.S. EPA has published several assessments on the potential
human and ecological risks associated with various coal ash disposal practices.
This presentation will discuss the role of human health risk assessment in the
rule-making process, including how risk assessment information was used in the
cost-benefit analysis to distinguish among different regulatory options. Also,
in light of changing (but as yet unknown) regulations, this presentation will
address how human health risk analysis will be important to address future
safety concerns associated with disposal and beneficial use of CCRs, and the
importance of emerging toxicological assessments of the chemical constituents in
CCRs (e.g., arsenic, cobalt and chromium).
Patrick Garcia Strickland, Laboratory Director at Frontier GeoSciences, Inc.,
will discuss metals mobility in coal combustion residues and analytical
techniques for monitoring fly ash ponds. Knowledge of the ability of metals to
be released from coal combustion residues is an important factor in determining
the potential effects on the environment. Frontier GeoSciences, in conjunction
with the Department of Energy, recently completed an exhaustive three year study
to better understand trace metals in coal combustion residues. The effect of
rainwater on the mobility of trace metals in coal combustion residues will be
described as well as how this relates to fly ash ponds. In addition, a
description of current analytical techniques that can be used for monitoring low
level metals in surrounding groundwater as well as ambient air and particulate
matter will be described.
Gary D. Mooney, Sales Engineer, Clyde Bergemann Delta Ducon, will discuss Bottom
ash conversion options for ash pond removal. As an ash handling systems OEM,
Clyde Bergemann Delta Ducon, CBDD, offers four (4) viable bottom ash systems and
solutions that can be retrofitted to existing power plants desiring or being
required to remove an ash pond. Two systems involve replacement of the existing
equipment under the boiler while two more retain the existing boiler island
equipment and divert the ash slurry to new dewatering equipment.
To register for the "Hot Topic Hour" on January 13th and 14th, 2011 at 10 a.m.
CST (Chicago time), click on: on: http://www.mcilvainecompany.com/brochures/hot_topic_hour_registration.htm
Bob McIlvaine
President
847 784 0012 ext 112
rmcilvaine@mcilvainecompany.com
www.mcilvainecompany.com