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Last Revised: 10/6/2011

Coal Combustion Byproducts Advocacy

Pre Proposal Letters
Comments
Congressional Letters
Testimony at EPA Public Meetings

NEW!
American Road & Transportation Builders Association Study on Coal Ash and Road and Bridge Construction Costs|ARTBA Press Release


Veritas Study: Utility Coal Ash Regulation Could Lead to As Many As 316, 000 Job Losses


Comments/Letters on EPA's Proposed Regulations

Pre-Proposal Letters

White Papers/Fact Sheets/Testimony

News Releases/Letters to Media

Letters

Draft/Model Letters

Congressional Letters

State Letters to EPA on CCP Regulation

Labor

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Tribal Goverment

Technical/Educational Organization Letters

Environmental Groups' Letters

Coalition & Other Stakeholder Meetings with OMB - List of Meetings Along with Materials Provided to OMB by Coalition Members

Small Business Advocacy Review Request Letters

Regulatory Proposals

 

Coal Combustion Byproducts

CCP Background

Coal combustion products (CCPs) are materials produced when we burn coal to produce electricity. CCPs are categorized in four groups, each based on physical and chemical forms derived from coal combustion methods and emission controls: fly ash, bottom ash, boiler slag, and flue gas emission control wastes. Coal ash has been studied extensively for decades by universities and government regulatory agencies and the US EPA has conclusively determined that it is not a hazardous waste.

Coal Ash Fact Sheet

Potential Health Effects

Coal ash particles are essentially insoluble aluminosilicate glasses that contain minute traces of compounds, such as manganese, boron, arsenic and other metals that may be soluble.  The Electric Power Research Institute (EPRI) and other research institutions have comprehensively studied the health and environmental effects of ash used in various applications throughout the United States and have concluded that the risks from coal ash are minimal whether in the form of CCPs that are disposed or when the CCPs are beneficially used.  Numerous researchers -- US DOE, USGS and EPRI -- have also has found that radiation in coal ash is minimal -- well below EPA's action standards -- and that the use of coal ash as a recycled material can have important economic and environmental benefits.  EPA studies over the past 15 years confirm this position, showing that the use of coal combustion products in construction projects has resulted in little to no impact on groundwater and surface water quality, but that some precautions are necessary.

EPRI Environmental Focus on Coal Ash      EPA Fact Sheet on CCP Health Effects
Is Coal Ash Toxic? (EPRI Technical Brief)     USGS Report on Fly and Radioactivity

Regulatory Background

In 1980, Congress passed the Bevill Amendment to RCRA, which required EPA to study the management of CCPs, including disposal, utilization, proven environmental damage attributable to CCPs, and economics.  Pending the completion of that study, EPA was barred from applying its hazardous waste regulations to CCPs.  Once the study was completed, EPA reported its findings and recommendations to Congress, and after notice and comment, determined in 1993 that coal combustion wastes do not warrant hazardous waste regulation; and again in 2000 that the remaining fossil fuel combustion wastes do not warrant regulation as a hazardous waste. EPA did identify specific areas of concern that led the Agency to announce plans for developing non-hazardous waste regulations for CCP disposal. 

EPA also made findings regarding the beneficial use of CCPs.  Except for mineplacement of CCPs, which EPA addressed separately, EPA did not identify any beneficial uses of CCPs “that are likely to present significant risks to human health or the environment” and reported that there were “no documented cases of damage to human health or the environment” from beneficial uses of CCPs.

Throughout the Bevill process, the regulation of CCP management has remained a state regulatory responsibility and the states have taken the initiative to develop and implement regulatory programs tailored to the wide-ranging circumstances of CCP management throughout the country.  In 2007, EPA and DOE conducted a comprehensive study of CCP disposal facilities permitted or constructed since 1994 and a review of state CCP regulations. This report, Coal Combustion Waste Management at Landfills and Surface Impoundments, 1994-2004 confirmed the positive trend toward more protective waste management observed by EPA in 2000 has continued and, in several key respects, has significantly accelerated. For example, EPA found that nearly all new CCW disposal units had installed liners and nearly all new landfills were monitoring groundwater, thereby addressing groundwater protection concerns. The report also addressed trends in state regulation, and found that state regulatory controls have increased and that deviations from state regulatory requirements were being granted only on the basis of sound technical criteria.  EPA and DOE found state regulations were generally administered in a responsible manner and were improving. These findings demonstrate a continuing commitment by the states to ensure proper management of CCWs. 

CCP Mineplacement

In 2006, The National Academy of Sciences (NAS) published a comprehensive report on the mineplacement of coal ash that concluded that that placing CCPs in coal mines as part of the reclamation process is a viable management option when conducted in a manner that (a) avoids significant adverse environmental and health impacts and (b) includes public involvement in the regulatory permit process. Neither the NAS nor the U.S. Department of Interior’s Office of Surface Mining (OSM) have identified any sites where the mineplacement of CCPs has resulted in the generation of leachate that would threaten public health or degrade the environment. To provide a regulatory framework to ensure the continued use of CCPs in mineplacemnt activities, OSM is in the process of developing CCP mineplacement regualtions under the Surface Mining Control and Reclamation Act (SMCRA).

National Mining Association Fact Sheet on CCP Mineplacement

CCP Generation and Utilization

The American Coal Ash Association reports that in 2007, the United States produced more than 130 million tons of CCPs. Over 45 percent of the CCPs produced were beneficially used. The potential for CCP utilization is exceptional and the environmental benefits significant. CCP use conserves natural resources as the need to extract virgin materials is eliminated. Millions of acres of land otherwise used for disposal are preserved by using CCPs. Substituting one ton of fly ash for one ton of Portland cement clinker eliminates one ton of CO2 otherwise released during cement production.

Applications span an infinite variety of possibilities in the architecture, engineering and construction industries as well as in manufacturing. Various applications for each CCP type include:

  • Fly ash is most commonly used as a high-performance substitute for Portland cement or as clinker for portland cement production. Cements blended with fly ash are becoming more common. Building material applications range from grouts and masonry products to cellular concrete. Many asphaltic concrete pavements contain fly ash. Geotechnical applications include soil stabilization, road base, structural fill, embankments and mine reclamation. Fly ash also serves as filler in wood and plastic products, paints and metal castings.
  • Flue gas desulfurization (FGD) materials are produced by chemical “scrubber” emission control systems that remove sulfur and oxides from power plant flue gas streams. Residues vary, but the most common are FGD gypsum (or “synthetic” gypsum) and spray dryer absorbents. FGD gypsum is used in almost thirty percent of the gypsum panel products manufactured in the U.S. It is also used in agricultural applications to treat undesirable soil conditions and to improve crop performance. Other FGD materials are used in mining and land reclamation activities. 
  • Bottom ash and boiler slag can be used as a raw feed for manufacturing portland cement clinker, as well as for skid control on icy roads. These materials are also suitable for geotechnical applications such as structural fills and land reclamation. The physical characteristics of bottom ash and boiler slag lend themselves as replacements for aggregate in flowable fill and in concrete masonry products. Boiler slag is also used for roofing granules and as blasting grit.

Coal Combustion Products Partnership (C2P2)

C2P2 Fact Sheet

In response to EPA's Resource Conservation Challenge, EPA and the utility industry are jointly implementing the Coal Combustion Products Partnership (“C2P2”), a collaborative effort to reduce barriers and encourage increased beneficial use of CCPs. While over 45% of CCPs are currently beneficially used, the balance of CCPs must be managed in landfills and surface impoundments.  The goal of C2P2 is to increase the percentage of CCP beneficial use and decrease the volume of CCPs managed in landfills and surface impoundments.

USWAG CCP ACTION PLAN

The industry is committed to C2P2 as a means of ultimately achieving complete resource conservation of CCPs.  Until full beneficial use of CCPs is achieved, however, continued management of CCPs in an environmentally responsible manner will remain an essential component of electric power generation.  The utility industry through USWAG developed this Action Plan to complement the goals of C2P2 by ensuring that, until complete resource conservation of CCPs is achieved, the remaining CCPs will be managed in a manner that protects human health and the environment.

USWAG CCP Action Plan | Action Plan Press Release

CCP Management & Guidance

USWAG regularly provides compliance assistance to the utility industry regarding the management of CCPs and other materials produced at coal-fired power plants. For example, USWAG, working in conjunction with EPRI, has produced Guidance for Comanagement of Mill Rejects at Coal-Fired Power Plants to provide the industry with information regarding the environmentally sound disposal of mill rejects, and Groundwater Monitoring Guidance to provide guidance regarding the implementation of the CCP disposal facility groundwater monitoring established in the USWAG Action Plan.

In addition, EPA, in partnership with state and tribal representatives and a focus group of industry and public interest stakeholders, developed a set of recommendations and tools to assist facility managers, state and tribal regulators, and the interested public in better addressing the management of land-disposed, non-hazardous industrial wastes: Guide for Industrial Waste Management

EPA has also created a section on their web site addressing industrial waste management located at: http://www.epa.gov/industrialwaste/

 

Utility Solid Waste Activities Group | 701 Pennsylvania Ave., N.W. | Third Floor | Washington, D.C. 20004-2696
202-508-5645 | jim.roewer@uswag.org

 
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