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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
Environmental Affairs
Georgia Power: Who we are
Largest of four Southern Company electric utilities
2.3M+ customers
8,600 employees
Nearly 13,000 miles of
transmission lines
70,000 miles of distribution
lines
High customer satisfaction
Rates below the national average
Georgi
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Power
Alabam
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Power
Gulf Power
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Georgia
Power
Alabama
Power
Environmental Affairs
Coal
US 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
Environmental Affairs
Energy Generation
Coal 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

Environmental Affairs
Ash
A 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
Environmental Affairs
Composition of Ash
Dependant on coal source, combustion, etc.
Generally consists of silicon, aluminum, iron,
and calcium
Also contains trace amounts of heavy metals,
such as arsenic, selenium, chromium
Is classified as an industrial solid waste
Environmental Affairs
Ash Handling Facilities
Ash Landfill Ash Pond
Environmental Affairs
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%
Environmental Affairs
Southern Co. Beneficial Reuse
About 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 automobiles CO
2
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)
Environmental Affairs
Georgia Power Ash Dam Safety
Inspections
Annual
Weekly
Daily
Training
Vegetation control
Instrumentation
Ash dam inspection by plant personnel
Environmental Affairs
CCB Regulation
Currently exempt from RCRA regulation
Bevill Amendment
Regulated as an industrial waste in Georgia
December 2008: Tennessee Valley Authority
impoundment failure
Triggered ash pond dam inspections and proposed
CCR rule


Environmental Affairs
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

Environmental Affairs
TVA Kingston, TN Spill
Environmental Affairs
TVA Ash Spill
Root Cause Analysis
According to TVAs web site:
1. High water content of the wet ash
2. Increasing height of ash
3. Construction of the sloping dikes over the wet
ash
4. Unusual bottom layer of ash and silt
Environmental Affairs
EPA Ash Pond Inspections
As a result of TVA spill, EPA contractors
inspected ash impoundment dam integrity
Tremendous effort by both EPA and the utilities
Each ash pond received condition rating
Reports are posted on EPA web site

Environmental Affairs
EPA Ash Dam Inspections
Condition 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
Environmental Affairs
Georgia Power Ash Dam Inspections
Condition 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
Environmental Affairs
New Ash Rules Propose to Regulate
CCRs = Coal Combustion Residues
CCRs generated by electric utilities and
independent power producers
CCRs destined for disposal in
Landfills or
Surface impoundments
Environmental Affairs
EPAs 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 OptionUseful Life
Environmental Affairs
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 Liners
Corrective action
Used when contamination is detected

Environmental Affairs
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 required
Regulation from generation to disposal
Including during and after closure of disposal unit


Environmental Affairs
RCRA Subtitle C Option
Some Industry Implications
Ash Pond phase-out
Shortage 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.


Environmental Affairs
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
Environmental Affairs
RCRA Subtitle D Option
Some Industry Implications
Retrofit existing surface impoundments with
composite liners within 5 years - or close.
Except for D Prime option
Effect of phasing out surface impoundments
Capacity shortages
Still higher costs; rate recovered


Environmental Affairs
Public Comment
Closing date November 19, 2010
EPA received 450,000 comments
Latest newsflash: Rule will not be finalized in
2011, due to the large amount of comments
that EPA must review
Environmental Affairs
Proper management of CCBs is an important
part of the process of providing reliable,
affordable, and environmentally responsible
energy

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