“Flyash Utilization and Disposal" was the Subject for the December 3 Hot Topic Hour

Coal ash is being depicted as a toxic and hazardous waste by environmentalists and the main stream press. Actually, by properly utilizing CCPs (coal combustion products), both the economy/infrastructure and the environment have benefited. For example, concrete with 20 percent and up to 40 percent flyash is much more durable and long-lasting than normal concrete.  Now the EPA is considering classifying flyash as a hazardous waste, which would be a tragic mistake. Currently approximately half the flyash generated by burning coal is sold for use in a variety of applications. If EPA declares flyash a hazardous material, the utility industry will be literally buried in mountains of coal ash instead of it being used beneficially and will have even greater problems disposing of a "hazardous material." This will result in a higher cost of electricity affecting everyone and require many industries to find and utilize more expensive and frequently less desirable substitutes. The situation was very capably assessed by five speakers with considerable expertise on the subject.

Patrick  Garcia Strickland of Frontier GeoSciences, Inc. showed test data indicating that the use of mercury controls has effects on CCP.

• All CCPs used as soil fill where there is direct human contact are testing greater than national soil standards for arsenic.
   
• All CCPs disposed of in landfills will most likely pass RCRA TCLP metals requirements.
   
• Chemical leaching of CCPs is very dependent on the type of coal, processing of the coal, and mercury control technology. Some are below drinking water and surface water criteria, some are not. Testing of the individual materials is suggested to determine chemical leaching.
   
• Volatility of metals in landfill and soil fill applications is minimal.
   
• Volatility in wallboard and cement application is very dependent on the type of coal, processing of the coal, and mercury control technology. In some cases, almost 100 percent of Hg and Se is re-released but others have zero percent. Testing to determine the amount of metals released in various processes is suggested to determine the fate of volatile metals.
   
• Mercury control technologies increase the total concentrations of metals such as selenium and mercury but do not necessarily increase the leaching and volatility of these metals.

James (Jim) Niehoff, PE, Practice/Program Leader at Golder Associates Inc., discussed the failure of a major ash pond in Tennessee in December of 2008, including an assessment of the possible causes and the extent of the damage to neighboring properties and waterways. He presented details on the ways over $1 billion will be spent in clean-up, transportation and final disposal of the flyash in a landfill in central Alabama.

Mark D. Rokoff, Principal Project Manager at URS Corp., outlined the path ahead and the looming proposed rule expected this month. EPA believes the costs will not be significantly different if CCP is categorized under Sub Title C as hazardous instead of under its present Sub Title D non-hazardous classification.

• Unlike other Subtitle D wastes (e.g. MSW), no federal minimum requirements exist for CCPs, which results in regulations which vary significantly from state to state.

• The Resource Conservation and Recovery Act (RCRA) Subtitle C establishes a federal program to manage hazardous wastes from cradle to grave.

• Subtitle C includes an enforcement and tracking component (absent in Subtitle D).

• RCRA Subtitle C designation is the leading option considered for CCPs.

One option may be a hybrid approach where beneficial reuse is non-hazardous.

Ms. Ari Lewis of Gradient Corporation presented an evaluation on the safety of CCP beneficial use. Their studies show that

·         Screening risk assessments have shown that mercury risk from wallboard, concrete, and structural fill do not pose a health risk.

·         Risk assessments for potential exposures to other compounds in CCP by multiple pathways should be examined to demonstrate safety of beneficial uses of CCPs.

·         More data amenable to risk assessment is needed for reliable evaluations.

Tom Adams, Executive Director of the American Coal Ash Association, updated us on what will happen next.

·         EPA Administrator Jackson has promised Congress she would propose rules before the end of 2009.

·         Key December dates include

o   December 9 potential Jackson appearance at House Transportation and Infrastructure Committee.

o   December 22 anniversary of Kingston impoundment failure.

·         Actions that could slow the process:

o   OMB/Inter-agency review issues.

o   Requests for Small Business Advisory Review panel by American Coal Ash Association and National Rural Electric Cooperatives Association.

·         EPA announcement will trigger public comment period that could stretch through much of 2010.

Bob McIlvaine spent a few minutes showing attendees the Universal Environmental Burden Index which would be an ideal way to assess the value or harm of various CCP options. This analysis appears on the McIlvaine website at http://www.mcilvainecompany.com/SURS/subscriber/Default.htm

Bob Moore, corrosion consultant for URS-WD, sent us comments after the webinar. He observed that Mark Rokoff provided a “great overview of the history of CCPs, legislation, beneficial uses, TVA ash pond spills, and the possible changes in EPA regulations and was the highlight of the webinar. The other speakers were also effective in addressing various aspects of coal ash utilization and disposal. Dave Goss, ACAA Consultant and former Executive Director, commended Mark’s presentation in his concluding remarks. If only the EPA participated in this webinar and listened with open minds…. How can a non-hazardous waste used beneficially for decades to improve both products (e.g., concrete) and the environment suddenly become a hazardous waste because of two ash pond spills?  Environmentally, CCPs are often captured and contained in concrete, wallboard, etc., so they’re basically entombed.  The mercury issue was discussed and doesn’t appear to be a real problem. Of the leachable metals in drinking water only arsenic seems to pose a possible factor.  I applaud the idea of sending a combined white paper to the EPA to report the factual data on CCPs by some of the best specialists in this field with Mark as the editor. 

After viewing and hearing these CCP experts, I’m more convinced than ever that CCP non-hazardous wastes have solved more economic and environmental (e.g. GHG) problems than any other waste byproducts in industry.  To now label CCPs as hazardous is not only wrong but would create monumental, mind-boggling disposal issues. I still remember what those wise Roman engineers did over 2,000 years ago when they utilized volcanic ash as a natural pozzolan to make extremely durable concrete structures and roads that still exist today.  (Compare that with the FHWA 100 year bridge designs and 60 year design life of new nuclear power plants.)  We must preserve and protect the CCPs from the regulators and continue to utilize them for everyone’s benefit. The EPA should be duly informed by this panel that two preventable ash pond spills don’t change the many beneficial and continued uses of CCPs under Subtitle D.  I’ve always believed that: “The truth will out.” Mark and the panel have the facts, versus “60 Minutes' fiction.”

The bios, abstracts and photos can be viewed as follows: Bios, Photos, Abstracts - December 3, 2009.htm

The individual slides are as follows:

Weathering the Storm of Change, presented by Mark Rokoff – URS
http://www.mcilvainecompany.com/Decision_Tree/subscriber/Tree/DescriptionTextLinks/Mark Rokoff - URS.pdf

The Costly Consequences of an Ash Pond Failure, presented by James Niehoff – Golder Associates, Inc.
http://www.mcilvainecompany.com/Decision_Tree/subscriber/Tree/DescriptionTextLinks/James Niehoff - Golder.pdf

Evaluating the Safety of Coal Combustion Product (CCP) Beneficial Use, presented by Ari Lewis – Gradient
http://www.mcilvainecompany.com/Decision_Tree/subscriber/Tree/DescriptionTextLinks/Ari Lewis - Gradient 12-3.pdf

Regulations, presented by David Goss, Consultant – American Coal Ash Association
http://www.mcilvainecompany.com/Decision_Tree/subscriber/Tree/DescriptionTextLinks/David Goss - American Coal Ash Association.pdf

Methods for Testing Trace Metal Mobility in Coal Flyash and FGD Solids, presented by Patrick Garcia Strickland – Frontier GeoSciences
http://www.mcilvainecompany.com/Decision_Tree/subscriber/Tree/DescriptionTextLinks/Patrick Garcia Strickland - Frontier GeoSciences, Inc.pdf