By Nick Garlisch
Nick.garlisch@gmail.com
What is Coal Ash?
 Coal ash is what remains after coal is burned
 When coal is burned, roughly 10% of the coal remains
as ash
 Coal ash is comprised of several
types of ash including fly ash,
bottom ash, and boiler slag
Fly Ash
 Fly ash is the ash that rises up and is trapped by the
stack filters
 About 74% of the ash generated is fly ash
 Stack 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 Ash
 Bottom ash is too heavy to rise so it settles at the
bottom of the boiler
 About 20% of the ash generated is bottom ash
Boiler Slag
 Boiler slag is formed when the ash melts under the
intense heat
 It is collected at the bottom of the boiler and at the
exhaust stack filters
 About 6% of the ash
generated is boiler slag
Coal Ash Constituents
 Coal 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 poisoned
surface or groundwater supplies
from improper disposal
of coal ash
Magnitude of Ash Generated
 The US derives over half its electricity from coal fired
power plants
 Burning this much coal results in nearly 140 million
tons of coal ash
produced each year
 What happens to
all that ash?
Where it goes
 Around 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% is
disposed of in landfills
Beneficial Reuse
 Allows for the ash to be recycled instead of disposed
 Decreases demand for cement and overall energy
requirements for certain
projects
 Recycling reduces water
consumption and greenhouse
gas emissions
FGD Gypsum
 One way coal ash is reused is to make FGD Gypsum
 FGD Gypsum is a product produced from the sulfur
dioxide emissions control scrubbers
 FGD 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 recycling
 Consumer products such as bowling balls and carpets
 Golf courses
 Placing the ash in
deserted mines where
it might leach into
into groundwatergroundwater
Regulations
 No uniform federal standards
 State by state regulations
 Each state must meet baseline federal standards
 EPA does not currently
consider coal ash a
hazardous waste
Disposal
 Coal 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 spills
have occurred
TVA Spill
 A 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 and
entered water systems
used for drinking water
TVA Spill
 Elevated levels of radiation from those typically found
in coal ash
 Levels of radium 228 and 226 around 8 picocuries per
gram, most coal ash is around 5-6
 Fears over exposure to airborne particulate matter
 An underwater dam was
constructed to prevent ash
from moving further
downstream
Illinois
 Illinois 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
Lined
Impoundments
Impoundments
with
Groundwater
monitoring
83
68
15
31
28
Illinois
 Illinois 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 Regulation
 The EPA is currently engaged in a rule making process
to regulate coal ash
 EPA has proposed two separate options for how it
would regulate coal ash
 Regulation would be under the Resource
Conservation and Recovery Act (RCRA)
subtitle C or subtitle D
 Public comments were due
November 19th
Subtitle C
 Coal ash would be considered a hazardous waste
 State and federal enforcement
 Permits requirements
 Phases out the use of existing and new surface
impoundments
 Industry 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 D
 Coal ash would not be considered a hazardous waste
 Citizen suit enforcement where states can act as
citizens
 No permit requirements
 Surface impoundments would
continue to be used but would
require liners
 Environmental groups think subtitle
D regulation would be too weak
How a Waste Becomes Hazardous
 Under RCRA, a waste can become hazardous two ways
 1) The EPA administrator can list it as hazardous
 2) The waste can exhibit certain statutorily defined
characteristics such as ignitability or corrosivity
 The characteristics are described in detail in
40 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, 2010
 EPA must respond to the concerns in these comments
 EPA’s final decision will not be overturned unless it is
found to be arbitrary and capricious
 Environmental groups contend
subtitle D will continue to provide
inadequate regulation
 Industry contends subtitle C will end
beneficial reuse and cost consumers
more money
 What will EPA choose?