Environmental Affairs Ash Management from Coal Fired Power Plants Current Practices and Potential Impact of Proposed EPA Regulation Rochelle Routman, PG

Environmental Affairs

Ash Management from Coal Fired Power Plants

Current Practices and Potential Impact of Proposed EPA Regulation

Rochelle Routman, PG

Environmental Specialist

Georgia Power


Georgia Power: Who we areLargest of four Southern Company electric utilities 2.3M+ customers8,600 employeesNearly 13,000 miles of

transmission lines 70,000 miles of distribution

linesHigh customer satisfactionRates below the national average

Georgia

Power

Alabama

Power

Gulf PowerM

ississippiPow

er

GeorgiaPower

AlabamaPower


CoalUS Resources

The US has the largest reserves of coal in the world

Based on current consumption, there is about 200 years of accessible coal remaining to generate energy


Energy GenerationCoal is Vital

45% of energy generated in the US is from coal– About 11% renewables,

including hydro Energy efficiency, clean

coal technology, and renewables are necessary to meet energy needs of the future


AshA coal combustion byproduct

Bottom Ash •Falls to the bottom of the furnace•Sluiced to an ash pond

Fly Ash•Collected by electrostatic precipitators•Either sluiced to an ash pond or handled in a dry landfill


Composition of Ash

Dependant on coal source, combustion, etc.Generally consists of silicon, aluminum, iron,

and calciumAlso contains trace amounts of heavy metals,

such as arsenic, selenium, chromiumIs classified as an industrial solid waste


Ash Handling Facilities

Ash Landfill Ash Pond


Southern Co Ash Handling Practices

Fly Ash Production 2009: 3.9 Million Tons

Bottom Ash Production 2009: 1.0 Million Tons

Fly Ash Management 2009 (% of total)

Bottom Ash Management 2009 (% of total)

Wet -- 29% Wet --74%Dry -- 71% Dry -- 26%


Southern Co. Beneficial ReuseAbout 30% Annually

Bottom Ash Replacement for naturally mined

aggregate (clay and shale)– Road base– Concrete block

Top Ash Cement manufacturing Ready-mix concrete

One ton of fly ash used as replacement for cement conserves landfill space to hold about 1200 lbs of waste, reduces the equivalent of 2 months of an automobile’s CO2 emissions, and saves the same amount of energy used by an average home for 19 days(US EPA, April 2005, EPA-530-K-05-002)


Georgia Power Ash Dam Safety

Inspections– Annual– Weekly– Daily

TrainingVegetation control Instrumentation Ash dam inspection by plant personnel


CCB Regulation

Currently exempt from RCRA regulation–Bevill Amendment

Regulated as an industrial waste in GeorgiaDecember 2008: Tennessee Valley Authority

impoundment failure– Triggered ash pond dam inspections and proposed

CCR rule


TVA Kingston, TN Spill

December 22, 2008– Failure of dam

containing fly ash– Approximately 5.4

million cubic yards of fly ash sludge were released into branch of Emory River


TVA Kingston, TN Spill


TVA Ash SpillRoot Cause Analysis

According to TVA’s web site:1. High water content of the wet ash2. Increasing height of ash3. Construction of the sloping dikes over the wet

ash4. Unusual bottom layer of ash and silt


EPA Ash Pond Inspections

As a result of TVA spill, EPA contractors inspected ash impoundment dam integrity

Tremendous effort by both EPA and the utilitiesEach ash pond received condition ratingReports are posted on EPA web site


EPA Ash Dam InspectionsCondition Ratings

Rating What it means EPA rating of 228 units inspected to date (www.EPA.gov)

Satisfactory No safety deficiencies

106

Fair Acceptable performance

67

Poor Remedial action/ investigations needed

55

Unsatisfactory Unsafe; immediate action required

0


Georgia Power Ash Dam InspectionsCondition Ratings

Rating What it means EPA rating of 25 units inspected to date (www.EPA.gov)

Satisfactory No safety deficiencies

22

Fair Acceptable performance

2

Poor Remedial action/ investigations needed

1 - Conditional

Unsatisfactory Unsafe; immediate action required

0


New Ash Rules Propose to RegulateCCRs = Coal Combustion Residues

CCRs generated by electric utilities and independent power producers

CCRs destined for disposal in– Landfills or–Surface impoundments


EPA’s Proposed Ash Rule: Two Main Options

RCRA Subtitle C Option: Hazardous waste regulation

RCRA Subtitle D Option: Non-hazardous, solid waste regulation

RCRA Subtitle D “Prime” Option–Slight variation of Subtitle D Option—“Useful Life”


Common Requirements Between Subtitles C and D

Dam Safety requirements– Design construction/maintenance documents; closure

plans; inspections ; annual certification by an independent PE

Groundwater monitoring and LinersCorrective action– Used when contamination is detected


RCRA Subtitle C Option

“Special Waste” classification– Subject to most hazardous waste requirements– Includes CCRs intended for disposal, not CCRs intended

for beneficial use

Federal permit requiredRegulation from generation to disposal– Including during and after closure of disposal unit


RCRA Subtitle C OptionSome Industry Implications

Ash Pond phase-outShortage of hazardous waste handling facilities– White House Council on Environmental Quality: Classifying

ash as hazardous waste will add about 130 M tons annually to the 2.5 M tons of hazardous waste now disposed of annually

Likely decline in beneficial reuse due to stigma– American Concrete Association: Designation of fly ash as a

‘hazardous waste’ will likely eliminate its inclusion in future project specifications for fear of possible legal exposure and liability.


RCRA Subtitle D Option

State-led approach; no federal permits– EPA has no direct role

Performance Standards– More focused on performance than Subtitle C Option– E.g., national performance criteria for safe disposal in

landfills


RCRA Subtitle D OptionSome Industry Implications

Retrofit existing surface impoundments with composite liners within 5 years - or close.–Except for D Prime option

Effect of phasing out surface impoundmentsCapacity shortagesStill higher costs; rate recovered


Public Comment

Closing date November 19, 2010EPA received 450,000 commentsLatest newsflash: Rule will not be finalized in

2011, due to the large amount of comments that EPA must review


Proper management of CCBs is an important part of the process of providing reliable, affordable, and environmentally responsible energy

Documents

Environmental Affairs Ash Management from Coal Fired Power Plants Current Practices and Potential Impact of Proposed EPA Regulation Rochelle Routman, PG