By Nick GarlischNick.garlisch@gmail.com

What is Coal Ash?Coal ash is what remains after coal is burnedWhen coal is burned, roughly 10% of the coal

remains as ashCoal ash is comprised of several

types of ash including fly ash, bottom ash, and boiler slag

Fly AshFly ash is the ash that rises up and is trapped

by the stack filtersAbout 74% of the ash generated is fly ashStack filtration devices such as scrubbers

reduce fly ash emissions by around 95%Around 5% of the fly ash

produced is released into the atmosphere

Bottom AshBottom ash is too heavy to rise so it settles at

the bottom of the boilerAbout 20% of the ash generated is bottom

ash

Boiler SlagBoiler slag is formed when the ash melts

under the intense heatIt is collected at the bottom of the boiler and

at the exhaust stack filtersAbout 6% of the ash

generated is boiler slag

Coal Ash ConstituentsCoal ash contains pollutants such as arsenic,

cadmium, lead, selenium, and other toxic metals that can cause cancer and neurological harm in humans

Other constituents of potential concern include mercury, aluminum, antimony, barium, boron, and thallium

Should We Be Concerned?Pollution from coal ash dumps significantly

increases both cancer and noncancer health risks and degrades water quality in groundwater supplies

Unlined coal ash waste ponds pose a cancer risk 900 times above what is defined as acceptable

At least 23 states have poisonedsurface or groundwater suppliesfrom improper disposal of coal ash

Magnitude of Ash GeneratedThe US derives over half its electricity from

coal fired power plantsBurning this much coal results in nearly 140

million tons of coal ash produced each year

What happens to all that ash?

Where it goesAround 40% of the ash is reused as an

additive in a variety of applications such as a cement substitute in concrete and a filler for asphalt

Coal ash is also used in construction projects to level out uneven terrain

The remaining 60% isdisposed of in landfills

Beneficial ReuseAllows for the ash to be recycled instead of

disposedDecreases demand for cement and overall

energy requirements for certainprojects

Recycling reduces waterconsumption and greenhousegas emissions

FGD GypsumOne way coal ash is reused is to make FGD

GypsumFGD Gypsum is a product produced from the

sulfur dioxide emissions control scrubbersFGD Gypsum has many

uses including agriculture, highway construction, cement production, water treatment, and glass making

Agriculture

Sham Recycling?Concerns that the industry is using the ash

improperly and labeling it recyclingConsumer products such as bowling balls and

carpetsGolf coursesPlacing the ash in

deserted mines whereit might leach into into groundwater-groundwater

RegulationsNo uniform federal standardsState by state regulationsEach state must meet baseline federal

standardsEPA does not currently

consider coal ash a hazardous waste

DisposalCoal ash is disposed of in surface

impoundments (aka coal ash pond) where the ash is suspended in water

There are up to 1,300 impoundments nationwide

Some states have recently started requiring liners for new impoundments scheduled to be built

Catastrophic spillshave occurred

TVA SpillA retention wall collapsed at a coal ash pond

at the Tennessee Valley Authority’s Kingston Plant

Around 5.4 million cubic yards of wet coal ash spilled out of the ash pond

The spill flooded more than 400 acres andentered water systemsused for drinking water

TVA SpillElevated levels of radiation from those typically

found in coal ashLevels of radium 228 and 226 around 8

picocuries per gram, most coal ash is around 5-6 Fears over exposure to airborne particulate

matterAn underwater dam was

constructed to prevent ash from moving further downstream

IllinoisIllinois EPA has required new surface

impoundments built after the early 1990’s to be lined

Groundwater monitoring wells have been installed at some but not all of these new impoundments

The following is a table of power plants with surface impoundments permitted under the NPDES program

Total impoundments

Active impoundments

Inactive impoundments

LinedImpoundments

ImpoundmentswithGroundwatermonitoring

83 68 15 31 28

IllinoisIllinois EPA Bureau of Water issues permits for

surface impoundments that recently have started to require liners and groundwater monitoring

Surface impoundments must be in compliance with Illinois groundwater and surface water quality standards

IEPA Bureau of Land can issue a permit for coal ash to be disposed in special waste landfills

Proposed RegulationThe EPA is currently engaged in a rule

making process to regulate coal ashEPA has proposed two separate options for

how it would regulate coal ashRegulation would be under the Resource

Conservation and Recovery Act (RCRA)subtitle C or subtitle D

Public comments were due November 19th

Subtitle CCoal ash would be considered a hazardous wasteState and federal enforcement Permits requirementsPhases out the use of existing and new surface

impoundmentsIndustry contends a hazardous label would end

beneficial reuse and cost 12-13 billion dollars more per year which would be pushed onto consumers

Industry contends coal ash is not a hazardous waste

Subtitle DCoal ash would not be considered a hazardous

wasteCitizen suit enforcement where states can act

as citizensNo permit requirementsSurface impoundments would

continue to be used but would require liners

Environmental groups think subtitle D regulation would be too weak

How a Waste Becomes HazardousUnder RCRA, a waste can become hazardous

two ways1) The EPA administrator can list it as

hazardous2) The waste can exhibit certain statutorily

defined characteristics such as ignitability or corrosivity

The characteristics are described in detail in40 CFR 261.4

Is Coal Ash Hazardous?Each quantity of coal ash generated is

different because different coal plants burn different kinds of coal

Testing is the only way to be sure if an individual amount of coal ash is hazardous

Although generators are obligated to test their waste to determine if it is hazardous, few coal ash generators actually test

What Will EPA Do?The public comment period ended November 19,

2010EPA must respond to the concerns in these commentsEPA’s final decision will not be overturned unless it is

found to be arbitrary and capriciousEnvironmental groups contend

subtitle D will continue to provide inadequate regulation

Industry contends subtitle C will endbeneficial reuse and cost consumersmore money

What will EPA choose?