Coal Ash Disposal is an Important Concern - Hot Topic January 13 & 14

Two very enlightening days of discussions on the CCR issue. The extended period for public comments on the proposed rule on Coal Combustion Residuals (CCR) (commonly referred to as coal ash) concluded on November 18, 2010. According to the speakers we can expect a final rule promulgated in 2011 or 2012. 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 C, EPA would create federally enforceable requirements for ash management, including waste generation, transportation and disposal. If CCR is declared non hazardous, under Subtitle D, EPA would only mandate a set of minimum national standards and leave it up to state governments and citizen litigation to enforce them.

Tom Adams, Executive Director American Coal Ash Association (ACAA), explains that 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.  

Joshua R. More, Partner Schiff Hardin LLP, described how in 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 – observed that wet conveying and storage of combustion products appears 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. The costs of the conversion are likely to be only a few million dollars.

Ari Schoen Lewis, Environmental Toxicologist and Manager of the Toxicology Team at Gradient Corporation, indicated that human health risk analysis is important in shaping the regulations. EPA is anticipating more input. One complication is the importance of emerging toxicological assessments of the chemical constituents in CCRs (e.g., arsenic, cobalt and chromium). Because the risk is now deemed higher, some constituents have assumed new importance

Patrick Garcia Strickland, Laboratory Director at Frontier GeoSciences, Inc., discussed metals mobility in coal combustion residues and analytical techniques for monitoring flyash 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.

At the end of the presentation there was a discussion of the benefits of leaching the metals out of the flyash at the plant site. Coal –fired power plants can make 30 percent hydrochloric acid and at the same time leach metals from the flyash. The metals are captured in ion exchange resins and the purified acid is sold. This will make higher chlorine coals more attractive and result in a metal free fly ash, rare metals, hydrochloric acid and gypsum as byproducts. 

Gary D. Mooney, Sales Engineer Clyde Bergemann Delta Ducon (CBDD), discussed four 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. Many power plants are using wet sluices for bottom ash. The dry system has the advantage of increasing boiler efficiency if only slightly. The other systems are easier retrofits in many instances.

The entire January 13 recording can be heard at: Coal Ash Ponds and Ash Disposal Issues    98 minutes     Password: hth829

The entire January 14 recording can be heard at: Coal Ash Ponds and Ash Disposal Issues - Part 2    92 minutes     Password: hth829

The Bios, Abstracts and Photos for both days are linked below.

BIOS, PHOTOS, ABSTRACTS - JANUARY 13-14, 2011.htm