State Governments Specify Use of Coal Ash

As we've documented, our United States Government, through the Federal Highways Administration, has recommended and specified the use of Coal Ash in various applications, including the making of cement and concrete, related to highway construction and road repair.
More can be learned via, for one example, our report of:

"Fly Ash Facts for Highway Engineers; Course No: T06-003; Continuing Education and Development, Inc.; Stony Point, NY 10980; (Reference): Report No. FHWA-IF-03-019; Title: Fly Ash Facts for Highway Engineers; 2003; American Coal Ash Association; Contract No. DTHF61-02-X-00044; Sponsoring Agency: Federal Highway Administration. Coal fly ash is a coal combustion product that has numerous applications in highway construction (including): Fly Ash in Portland Cement Concrete; in Stabilized Base Course; in Flowable Fill; in Structural Fills/Embankments (and) in Soil Improvements".

Herein, we learn that our United States Department of Energy, not long after the FHWA started instructing on the use of Coal Ash in highway construction, engaged the services of the University of North Dakota to survey the government highway departments of each individual state, to see if they were making as much use as possible of that valuable raw material resource.

The intent of the effort, as we understand and summarize, was both to fully catalogue the uses which exist for Coal Ash in road construction, and, to encourage the various and separate state highway agencies to promote those uses for Coal Ash within their own organizations.

Comments follow excerpts from the initial link in this dispatch to:

"ENGINEERING AND ENVIRONMENTAL SPECIFICATIONS OF STATE AGENCIES FOR UTILIZATION AND DISPOSAL OF COAL COMBUSTION PRODUCTS: VOLUME 1 – DOT SPECIFICATIONS

Final Report; (for the period ending) August 31, 2005

Prepared by: Bruce A. Dockter, et. al., University of North Dakota; Energy & Environmental Research Center

DOE Award Number: DE-FC26-98FT40028

Abstract: The objective of this report is twofold. The first is to present a state-by-state comparison of
U.S. Department of Transportation (DOT) specifications governing the use of coal combustion products.

Because of a lack of resources, namely, time and funding, most transportation and materials engineers cannot fully research all of the current technologies of coal ash utilization. This compilation allows these professionals to become familiar with other department practices and to identify areas where specifications need to be developed within their own transportation offices.

Engineering practices are slow to change for many reasons. To facilitate changes, a systematic approach must be taken. The results from this effort will help familiarize DOT engineers and officials with coal ash use applications and will help the coal ash industry develop a plan to work with these departments and individuals in expanding their knowledge and familiarity while expanding coal ash markets.

The second goal is to establish a comparison of state environmental laws and regulations as they pertain to utilization and/or disposal. As a result of the interpretation of the Bevill Amendment, utilization and disposal are not regulated at the federal level. These issues have been left to the states. Many states have enacted laws, adopted regulations, or both governing the utilization and disposal of coal combustion by-products. These laws and regulations vary widely. Thus a particular utilization authorized in one state may not be authorized in the adjoining state.

(As a result of the above-noted Bevill Amendment, the USEPA have, subsequently, taken it upon themselves
to legislate by dictate; but, that isn't as bad, we think, as it might sound. Our various disabilities prevent us from directly seeking informed interpretation and summary, but, our take on information accessible via:

"Coal Combustion Residuals, often referred to as coal ash, are currently considered exempt wastes under an amendment to RCRA, the Resource Conservation and Recovery Act. They are residues from the combustion of coal in power plants and captured by pollution control technologies, like scrubbers. Potential environmental concerns from coal ash pertain to pollution from impoundment and landfills leaching into ground water and structural failures of impoundments, like that which occurred at the Tennessee Valley Authority’s plant in Kingston, Tennessee. The need for national management criteria was emphasized by the December 2008 spill of CCRs from a surface impoundment near Kingston, TN. The tragic spill flooded more than 300 acres of land with CCRs and flowed into the Emory and Clinch rivers. EPA is proposing to regulate for the first time coal ash to address the risks from the disposal of the wastes generated by electric utilities and independent power producers. EPA is considering two possible options for the management of coal ash for public comment. Both options fall under the Resource Conservation and Recovery Act (RCRA). Under the first proposal, EPA would list these residuals as special wastes subject to regulation under subtitle C of RCRA, when destined for disposal in landfills or surface impoundments. Under the second proposal, EPA would regulate coal ash under subtitle D of RCRA, the section for non-hazardous wastes. The Agency considers each proposal to have its advantages and disadvantages, and includes benefits which should be considered in the public comment period"; and:

"On October 12, 1980, Congress enacted the Solid Waste Disposal Act Amendments of 1980 (Public Law 96-482) which amended RCRA in several ways. Pertinent to special wastes was the addition of sections 3001(b)(2)(A) and 3001(b)(3)(A). These new sections—frequently referred to as the Bentsen and Bevill Amendments—exempted “special wastes” from regulation under Subtitle C of RCRA until further study and assessment of risk could be performed. Specifically, the Bentsen Amendment (§3001(b)(2)(A)) exempted drilling fluids, produced waters, and other wastes associated with the exploration, development, and production of crude oil or natural gas or geothermal energy. The Bevill Amendment (§3001(b)(3)(A)(i-iii)) exempted fossil fuel combustion waste; waste from the extraction, beneficiation, and processing of ores and minerals (including phosphate rock and overburden from uranium ore mining); and cement kiln dust.

The Bevill and Bentsen Amendments also required EPA to complete full assessments of each exempted waste and submit a formal report to Congress on its findings. Section 8002 explicitly identified the requirements for each special waste study and established deadlines for submission of the final reports. After completion of each respective “Report to Congress”, EPA was then required to make a final regulatory determination within six months as to whether the special waste in question warranted regulation as a hazardous waste under Subtitle C of RCRA"; and:

"Coal combustion products (CCPs) are the materials produced primarily from the combustion of coal in coal-fired power plants. The characteristics and physical properties of CCPs vary. In general, the size, shape, and chemical composition of these materials determines their beneficial reuse as a component of building materials or as a replacement to other virgin materials such as sand, gravel, or gypsum.

The beneficial use of CCPs involves the use of or substitution of coal combustion products for another product based on performance criteria. Beneficially using CCPs can generate significant environmental, economic, and performance benefits. For purposes of C2P2, beneficial use includes, but is not restricted to, raw feed for cement clinker, concrete, grout, flowable fill, structural fill, road base/sub-base, soil-modification, mineral filler, snow and ice traction control, blasting grit and abrasives, roofing granules, mining applications, wallboard, waste stabilization/solidification, soil amendment, and agriculture";

is, that:

If we just want to dump our Coal Ash somewhere and walk away from it, then the regulations are now, or are going to be, very, very strict.

On the other hand, if we want to put some effort into seeing to it that our Coal Ash is directed into productive applications that have been identified for it, the regulations governing it will be much less onerous.

Not to mention the facts, that, as we've documented in a number of reports, such as for one example:

"United States Patent 5,766,339 - Producing Cement from a Flue Gas Desulfurization Waste; 1998; Dravo Lime Company, Pittsburgh; Abstract: Cement is produced by forming a moist mixture of a flue gas desulfurization process waste product containing 80-95 percent by weight calcium sulfite hemihydrate and 5-20 percent by weight calcium sulfate hemihydrate, aluminum, iron, silica and ... wherein said source of aluminum and iron comprises fly ash";

nearly all the solid byproducts arising from our essential use of Coal in the generation of economical electric power can be consumed in the making of Portland-type cement, the market for which, as seen in:

Overview of the Cement Industry | Portland Cement Association (PCA); "In 2008, the United States consumed 93.6 million metric tons of portland cement";
is absolutely huge; and, if we actually get off our butts and put some effort into it, we might actually be able to make a few bucks.
And, further, as seen in:
West Virginia Coal Association | US EPA Headquarters Housed in Coal Ash | Research & Development; concerning, in part, the fact, that: "fly ash has been used in concrete since the 1930’s. Most notably, it has been used in several construction projects and prominent buildings, including the Ronald Reagan Government Office building, home to the Environmental Protection Agency (EPA) in Washington, D.C."; and:
West Virginia Coal Association | Wyoming Converts Coal Ash to Construction Aggregates | Research & Development; concerning: "United States Patent 6,334,895 - Producing Manufactured Materials from Coal Combustion Ash; 2002; Assignee: The University of Wyoming Research Corporation; Abstract: This invention discloses a system ... which enhances both density and strength of ... consolidated combustion ash materials (to form) both normal weight and light weight combustion ash aggregates ... which meet various ASTM and AASHTO specifications";
Coal Ash can also be utilized, with some minimal processing, as both fine and coarse aggregate for that cement, replacing both sand and gravel in the making, from cement, of concrete.
Further, Coal Ash in the unconsolidated state, that is, not formed into an aggregate via a process such as that disclosed by the above-cited "United States Patent 6,334,895", can and does exhibit cementitious properties of it's own, allowing it to serve, when added to Portland-type cement, not just as a fine aggregate, but, as an actual replacement for some of the Portland-type cement. A fact that is highlighted throughout the University of North Dakota report; and, which we will in the future provide more documentation of.)
In any case, there are other construction applications for Coal Ash, as well, and, as the University of North Dakota states, their charge was to assess how and where Coal Ash was specified, or allowed, for use by the governing highway departments in each of the fifty states.)
Introduction and Summary: The efforts on this project were made possible by funding from the National Energy Technology Laboratory Combustion Byproducts Recycling Consortium (NETL CBRC) with industry support from the American Coal Ash Association (ACAA) and the Utility Solid Waste Activities Group (USWAG). Although the twofold objectives of this report are similar in presentation (state by state comparisons), the contents are very distinct from one another. For these reasons, this report will be presented in a two-volume series. This portion of the report, Volume 1, will present existing Department of Transportation engineering specifications as they pertain to the use of coal combustion products. Volume 2 details the environmental statutes and regulations for each state as they pertain to utilization, handling, and disposal of coal combustion products.
(We will make separate report of the above "Volume 2" via separate dispatch.)
The objective of this report is to present a state-by-state comparison of U.S. Department of Transportation (DOT) specifications governing the use of coal combustion products. Because of a lack of resources, namely, time and funding, most transportation and materials engineers cannot fully research all of the current technologies of coal ash utilization. This compilation allows these professionals to become familiar with other department practices and to identify areas where specifications need to be developed within their own transportation offices. Engineering practices are slow to change for many reasons. To facilitate changes, a systematic approach must be taken. The results from this effort will help familiarize DOT engineers and officials with coal ash use applications and will help the coal ash industry develop a plan to work with these departments and individuals in expanding their knowledge and familiarity while expanding coal ash markets.
Although specifications and practices varied between states, several similarities were noted. The specifications used in all reported cases for fly ash were ASTM International (American Society for Testing and Materials) C618 and AASHTO (American Association of State Highway and Transportation Officials) M295. The title for both specifications is “Coal Fly Ash and Raw or Calcined Natural Pozzolan for Use in Concrete.” Under both classification systems, fly ash is defined as "a finely divided residue that results from the combustion of ground or powdered coal.” In addition to concrete, numerous states have used fly ash as a mineral filler in asphaltic concrete and soil stabilization, with many more states beginning to use fly ash in flowable mortar applications.

STATE COAL ASH SPECIFICATIONS AND GUIDELINES

(We are abbreviating excerpts from this section in the extreme, and include only a few examples of the specifications which exist, to give you some idea of the available potentials.)

Kentucky: Substitution of Class F fly ash for cement is at the rate of 25% to 30%, by weight ... .

Maine: Fly ash is allowed to be used in all classes of cast-in-place concrete, flowable fill, and precast
concrete.

Massachusetts: The fly ash, Type F, shall replace 15% by weight of the design cement content, and any
additional fly ash will be considered as fine aggregate. The total amount of Type F fly ash and ... shall constitute 20% by weight of the cement content, and any additional fly ash will be considered as fine aggregate.

(Note that the Massachusetts spec doesn't just allow the use of Coal Ash. It's wording, as in "shall replace", seems to imply that the use of Coal Ash is actually required. That, as opposed to two states, following, whom we would have thought would have been motivated to adopt similarly assertive language.)

Pennsylvania: Portland cement may be replaced with ... fly ash ... weighing as much as or more than the portland cement replaced.

West Virginia: Depending on the class of concrete specified, fly ash may be substituted for cement at a 15% or 19% replacement level.

Conclusion: All states had in place specifications pertaining to coal combustion products and their applications. The single most noted application is the partial replacement of cement in concrete. For this reason, the most commonly referenced specifications were ASTM C618 or AASHTO M295. Both are designed as methods of verifying if an ash can be used as a partial cement replacement in concrete. It was common practice for transportation departments to often change their specification from the indicated ASTM C618 and AASHTO M295 to reflect regional practices.

The specified use of blended cements is an indication of the increased use of fly ash within the cement industry  ... . Some states have already adopted, or are currently in the process of doing so, updated specifications for utilizing coal combustion products. Differences between DOT specifications still varied greatly between states, even neighboring ones. A transition in material specifications to performance specifications will gradually blur the lines between state specifications."

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Again, nearly all of the states responded with specifications and guidelines relating to the use of Coal Ash simply as a fine aggregate, and/or as what is sometimes in the literature labeled a "Supplementary Cementitious Material", or "SCM", in the production, or forming, of concrete.

None of them discussed Cement that, as in the above-cited "United States Patent 5,766,339 - Producing Cement from a Flue Gas Desulfurization Waste", was actually itself made from, as a raw material, Coal Combustion Products.

Nor, did any of them discuss or mention the use of Coal Ash as it can, as in the above-cited "United States Patent 6,334,895 - Producing Manufactured Materials from Coal Combustion Ash", be converted into, and utilized as, a coarse aggregate for structural concrete.

Even though most of the states did have some laws on the books allowing, or, in the case at least of Massachusetts, seemingly requiring, the use of Coal Ash in a rather limited, but still significant, way in highway and road construction, which is encouraging, there is still, obviously, a vast potential lying before us to expand those specifications to include things like Fly Ash-based cement itself and Fly Ash-based coarse aggregate.

We will be addressing all of those issues more fully in reports to follow; but, will first, in our next report concerning the productive reuse of the solid residua resulting from our vital use of Coal in the generation of genuinely economical electric power, address the issues and hurdles presented in "Volume 2" of: Engineering and Environmental Specifications of State Agencies for Utilization and Disposal of Coal Combustion Products, which, as noted, "details the environmental statutes and regulations for each state as they pertain to utilization, handling, and disposal of coal combustion products".