1. By Nick Garlisch Nick.garlisch@gmail.com

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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?

9. 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

10. 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

11. 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

12. Agriculture

13. 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 intointo groundwater- groundwater

14. 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

15. 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

16. 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

17. 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

19. 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 with Groundwater monitoring 8368153128

20. 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

22. 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

23. 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

24. 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

25. 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

26. 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

27. 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?