The National Waste & Recycling Association has been working extensively to gather accurate and developing information on the issue of coal ash disposal following the new rules recently set by the U.S. Environmental Protection Agency (EPA). The finalized national regulations will affect changes in the way the material will be regulated and managed, opening up service and disposal opportunities for the solid waste industry.
On April 17, 2015, the Federal Register published the Disposal of Coal Combustion Residuals from Electric Utilities providing new requirements for management of coal ash. The rules were developed in response to a large spill in Kingston, Tenn., six years ago when an ash dike ruptured at the Tennessee Valley Authority power plant. Over 5 million cubic yards of coal ash slurry drained into the Emory and Clinch rivers causing damage to homes, roads and utilities.
Although coal combustion residuals (CCR) are sometimes called coal ash, it is more properly referred to as CCR. This is because CCR is not just comprised of ash but other materials as well. Other solids that are included in the CCR include solids formed from efforts utilized to control air pollutants, in particular, flue gas desulfurization materials. In general, the make-up of CCR includes four different solids. These include fly ash, bottom ash, boiler slag, and flue gas desulfurization material. Each component of the CCR has its own properties. According to the American Coal Ash Association, almost 115 million tons of material was produced in 2013, with a little over half requiring disposal. The remainder is beneficially reused.
The proposed changes improve the management coal ash disposal sites. Landfills receiving the coal ash must be equipped, experienced and prepared to manage it in a safe manner. The proposed rules subject coal ash to the Resource Conservation and Recovery Act’s (RCRA) Subtitle D requirements. Subtitle D are the technical rules governing municipal solid waste.
Subtitle D landfills have safely managed municipal solid waste in the country for over twenty years, providing safeguards to ensure effective operations and groundwater protections. These landfills are generally distributed geographically in every part of the country. Many Subtitle D landfills have accepted and managed coal ash in the past. And, given landfill capacity projections, sufficient landfill capacity exists to handle the coal ash waste.
Subtitle D requirements include specific criteria to protect both the water and air. The rule establishes requirements to assess the structural integrity of coal ash disposal facilities and ensure that the facility achieves a minimum factor of safety. This decision provides the framework necessary to ensure the safe disposal and appropriate reuse of these non-hazardous materials.
The guidelines released on the EPA website include:
- Groundwater monitoring around surface impoundments and landfills;
- Liner requirements for new surface impoundments and landfills to protect groundwater;
- Groundwater cleanup from coal ash contamination;
- The closure of unlined surface impoundments that are polluting groundwater;
- The closure of surface impoundments that fail to meet engineering and structural standards or are located too close to a drinking water source;
- Restrictions on the location of new surface impoundments and landfills so that they cannot be built in sensitive areas such as wetlands and earthquake zones; and
- Proper closure of all surface impoundments and landfills that will no longer receive CCRs.
Because existing landfill capacity exists, there are opportunities for both the coal ash industry and the solid waste industry to work together to solve disposal issues. Existing infrastructure provides flexibility to generators to develop alternative beneficial use options without having to consider potential infrastructure investments. In addition, smaller facilities that do not generate large quantities of materials may see advantages in acquiring disposal management services rather than continuing to develop that capacity internally.
Many utilities are beginning the process of ensuring environmental compliance and reducing liability by relocating coal ash. For example, Duke Energy began the process of relocating 1.2 million tons of ash years earlier than required by the rules in order to regain the public’s trust. In order to protect groundwater or surface water from coal ash, utilities are beginning the journey to comply with the new rules and the public will be safer as a result.
The association encourages the exploration of these valuable opportunities for our members that have resulted from this development. We believe the EPA’s ruling opens the door for the waste and recycling industry to apply its expertise and experience in handling waste to become more involved in coal ash disposal—particularly with respect to landfills. Working within industry guidelines as well as with members, utilities and regulators, the association is spearheading efforts to maximize education, awareness and partnership-building around this timely issue.
Anne Germain is director of waste and recycling technology for the National Waste & Recycling Association.