The Fly Ash Threat
Despite our recent reports on the subject, we here, in our isolate little frontier outpost, remain uncertain as to the current status of Coal Ash regulation/designation by the US EPA.
As we have documented, there are legislative initiatives still "ou there", despite rejection of a proposed Coal Ash addendum to the Surface Transportation Act of 2012; more about which can be learned via:
Coal ash provision removed from transportation bill - Business, Government Legal News from throughout WV.
But, we miners and users of Coal, and we consumers of genuinely economical electricity, it might be heartening to note, are not the only ones who are lobbying for some sort of restraint to be put on the EPA's callous disregard for environmental and economic realities in their seeming drive to designate Coal Combustion Byproducts as hazardous waste.
As we've documented, for just one example, in:
West Virginia Coal Association | Coal Ash in Concrete Saves $100 Billion | Research & Development; concerning: "The Economic Impacts of Prohibiting Coal Fly Ash Use in Transportation Infrastructure Construction; 2011; Prepared by the American Road & Transportation Builders Association Transportation Development Foundation";
Coal Ash is actually viewed by some knowledgeable folk as a "A High-Return 'Green' Building Material"; and, the costs, to us United States citizens, of banning or restricting the use of Coal Ash, only in terms of highway construction and road repair, could, over the next two decades, exceed $100 Billion.
Note that the above assessment was made by a credible trade organization with no direct commercial ties to the Coal and Coal-use industries, excepting that they like to use our Coal Ash to help them do a better and more economical job of what they do: building roads.
We've many times documented the environmental, economic and performance benefits of using Coal Ash as a raw material in the making of Portland Cement and Portland Cement Concrete. In sum, such use of Coal Ash leads to better-quality, higher-performance Cement and Concrete, potentially reduced costs, and, a reduction in Carbon Dioxide emissions from Cement-making processes; which CO2 emissions are, as we've elsewhere documented, quite significant.
And, like "American Road & Transportation Builders", producers of Cement and Concrete, too, are concerned about the environmental and economic costs of their being denied access to what many of them have come to view as an essential raw material: Coal Ash.
As seen in excerpts from the initial link in this dispatch to:
"The Fly Ash Threat:
Designation as Hazardous Waste Could Turn Concrete's Environmental Image On Its Head
(By: William D. Palmer, Jr.; of Complete Construction Consultants; former editor in chief of Concrete Construction magazine.)
Concrete Producer Magazine
January, 2010
The EPA considers fly ash a nonhazardous waste material under Subtitle D of the Resource Conservation and Recovery Act (RCRA). This means that individual states have jurisdiction over the material's storage and disposal. Environmental groups want this ruling changed so that fly ash is classified a Subtitle C hazardous waste which would be regulated by the federal government.
This ruling has been true since 1980 under the so-called Bevill exclusion. This excludes “solid waste from the extraction, beneficiation, and processing of ores and minerals” from regulation as hazardous waste under Subtitle C of RCRA. In 2000, the EPA re-examined the situation.
Again it determined that coal combustion products (CCP, which includes fly ash, bottom ash, and flue-gas desulfurization material) were exempt to classification as a hazardous waste due to the desire to avoid placing “barriers on the beneficial uses of coal combustion waste so they can be used in applications that conserve natural resources and reduce disposal costs.”
The U.S. Energy Information Administration estimates that almost half of the electricity generated in the U.S. comes from coal, resulting in about 130 million tons of CCP. About 55%, or 72 million tons, is fly ash.
About half the fly ash generated is currently used for beneficial purposes, mostly in concrete. This beneficial use not only saves landfill space but reduces the amount of cement being produced and thus the amount of CO2 being generated.
(But, the) EPA doesn't trust the states to properly regulate fly ash but has no legal way to regulate it federally other than to designate the material as hazardous under Subtitle C. This distrust prompted EPA Administrator Lisa Jackson to pledge during her confirmation hearing last January to come up with new disposal regulations for CCPs by the end of 2009.
Unfortunately for the nation, Jackson's pledge may have created a greater environmental problem than she intended. And while EPA has for many years promoted using fly ash, even sponsoring the Coal Combustion Products Partnership (C2P2) to increase its beneficial use, it now appears that some sort of hazardous designation is likely.
Fly Ash in Concrete: Using fly ash as a cement replacement is perhaps the single greatest contributor to making concrete more environmentally friendly. Concrete's greatest environmental liability is the inclusion of portland cement, with its energy-intensive manufacturing process.
The typical equation cited by PCA is that about one ton of CO2 is released for every ton of cement manufactured. Using fly ash in a concrete mix reduces the amount of cement needed, thereby educing the carbon footprint while consuming an industrial waste product rather than sending it to a landfill. The Electric Power Research Institute estimates that beneficial use of CCPs annually saves 159 trillion Btu, 32 billion gallons of water, 11 million tons of CO2 released t the atmosphere, and 51 million cubic yards of landfill space.
Fly ash isn't just filler in concrete.
As a very fine-grained pozzolan, it reacts with the calcium hydroxide that is generated by the hydration reaction of cement and water to take on cementitious properties of its own. The reaction makes concrete stronger, less permeable, and reduces the alkalinity, which can reduce the danger of alkali-silica reactivity in the aggregate - and the need in some parts of the country to import nonreactive aggregate from distant sources.
Fly ash concrete is more workable and pumpable. It also hydrates more slowly, which reduces the heat of hydration - critical to reducing cracking in mass concrete placements. All of this makes fly ash concrete more durable than plain portland cement concrete. And concrete with fly ash costs less, because fly ash is typically less expensive than portland cement.
Due to all these advantages, fly ash is used in about half the concrete placed today. NRMCA (National Ready Mix Concrete Association) estimates that 15% of cementitious materials in concrete are replaced by fly ash and other supplementary cementitious materials. Typically specified as a percentage replacement for portland cement, both Class C and Class F ash is used at dosages as high as 50% (although 15% is more common).
But the percentage of fly ash use has been increasing. To achieve a more sustainable concrete, producers and engineers have been increasing replacement rates. One recent study used fly ash at replacement rates up to 30% with no adverse results on a hard-troweled concrete floor ... .
(Regarding the desirable use of Fly Ash in such concrete floors, see:
West Virginia Coal Association | Wal-Mart Requires Coal Ash in New Store Construction | Research & Development; "Adding Fly Ash to Concrete Mixes for Floor Construction; Wal-Mart institutes a new specification for its steel-troweled floors; Wal-Mart Stores Inc. has changed their construction specifications to require all interior steel-troweled concrete floors placed at Wal-Mart Stores, Supercenters, Neighborhood Markets, Sam's Clubs, and Distribution Centers to contain 15% to 20% fly ash ... ".)
There is a limit to how much fly ash our industry can use (and) contractors often object to using fly ash concrete. These concerns include set time, air content, and strength gain. Some fly ash can retard hydration and lead to longer set times and slower strength gain. And some can lead to loss of entrained air. An experienced concrete producer can easily overcome these issues.
Why a hazardous waste? No one argues that containment pond failures are acceptable - they are not. And no one doubts that there should be tighter regulations governing their design, construction, and maintenance. But to many proponents supporting fly ash use in concrete, regulating final disposal methods is a completely separate matter than designating fly ash as a hazardous waste under Subtitle C.
The problem is that the EPA wants more authority than the current law allows. At the September 2009 meeting of the Environmental Council of the States (ECOS), Matt Hale, director of EPA's Office of Resource Conservation & Recovery, said that while he believes that regulating fly ash under Subtitle D would be sufficient to protect public health and the environment, it doesn't provide the EPA with the authority to enforce more stringent disposal requirements.
InsideEPA.com reports that the agency's current proposal is an unusual “hybrid” approach: designating fly ash as hazardous if it's disposed of in a containment pond or landfill but not hazardous when recycled for “beneficial uses.” This proposal could mean that producers and power plants would have to transport, store, and treat fly ash as a hazardous waste in its powder form, but not after it's incorporated into concrete.
However well-intended, a hybrid approach to fly ash classification would cause our nation significant problems.
First, any hazardous designation is likely to greatly reduce using fly ash in concrete. ACI cautioned the EPA that a hazardous designation would likely result in fly ash being removed from all specifications and standards, including the ACI 318 Building Code Requirements for Reinforced Concrete. ACI concluded that:
'EPA should not risk harm to the environment an material benefits of fly ash use in concrete when addressing the impoundment requirements for fly ash, nor abrogate the ability to make effective and saf use of this industrial byproduct.'
Producers wanting to use fly ash would have to adopt restrictive safety procedures for employees. All current air operating permits for facilities would have to be modified.
The American Coal Ash Association (ACAA) suggest that one potential outcome of a hazardous waste classification is that the electric utilities, which generate fly ash as part of their pollution-control efforts in treating flue gases, will simply stop selling fly ash since they would also be likely to attract liability.
If any of these results occur, the cost of concrete will surely skyrocket.
In a letter to the EPA's Jackson, NRMCA President Robert Garbini wrote, “Eliminating the availability of fly ash would result in cost increases that could render concrete noncompetitive.”
Another implication, ECOS says, would be to overwhelm hazardous waste landfills across the nation with 135 million tons of CCPs, while today they handle only about 2 million tons of hazardous materials. ECOS executive director R. Steven Brown concluded in a letter to the EPA that this could have the perverse effect of reducing the treatment of materials that are truly hazardous, unlike fly ash which has never been shown to be hazardous.
Forty eight of the 50 state environmental agencies have come out against the hazardous designation. (The other two have no coal fired power plants.)
Playing politics To many, the EPA's response to the (highly-publicized Tennessee coal ash dam failure) has been based not on scientific evidence but on politics and a desire on the part of some environmental groups to completely eliminate the burning of coal for electricity generation. The ACAA predicts that the agency will need to take action to satisfy environmental activists who are not looking at the science.
For example, the greatest environmental concern with fly ash has always been the concentrations of heavy metals, such as mercury, cadmium, and arsenic. These materials could potentially leach out of concrete made with fly ash. But TVA's (Tennessee Valley Authority) testing shows that the concentrations in the Kingston ash are well below anything that could be considered hazardous. In fact, it reports that “the concentrations of most metals in the ash are within the range of concentrations found in natural soils in Tennessee.”
(And, the very thought of anything leaching out of durable Fly Ash Concrete at any appreciable, measurable rate is absolutely ludicrous. If any of our readers have made the effort to open the links we provide in our dispatches concerning the use of Coal Ash in Cement and Concrete, you will have seen that scientists frequently observe that using Coal Ash in Concrete is virtually the same as the ancient Romans' use of volcanic ash - a substance very, very similar in composition to Coal Ash - in their own Cement and Concrete structures, which Ash-containing structures, now literally thousands of years after they were built, still stand, virtually unchanged. If any "leaching", of anything, were taking place, those ancient Roman Ash Concrete structures would long ago have collapsed and rotted into piles of sand and stone.)
Bruce Boggs, vice president of research and development for Headwaters, says that tests on fly ash before buying it from an electric utility have never yielded results that would qualify the material as a hazardous waste.
Still, news reports often cite heavy metals in fly ash as a grave danger. For example, Environmental activist Erin Brockovich wrote(:)
'Fly ash apparently contains silicon dioxide and calcium oxide, as well as trace concentrations of heavy metals. In other words, coal ash is nasty stuff to have floating around in your river, air, and drinking water.'
But silicon dioxide and calcium dioxide are sand, and 'trace concentrations' are not a scientific analysis and do not necessarily result in such 'nasty stuff'.
(Unfortunately, we do here have to insert a correction. Brockovich is correct when she asserts that "Fly ash apparently contains ... calcium oxide. Big deal. Calcium oxide reacts immediately with any water it comes in contact with to form Calcium Hydroxide; and, as can be learned via:
Calcium hydroxide - Wikipedia, the free encyclopedia; "It is of low toxicity. Calcium hydroxide is used in many applications, including food preparation".
However, the author of our subject article, William D. Palmer, mis-wrote when he used the label "calcium dioxide". We don't believe there exists a compound with a formula that would qualify it to be called "calcium dioxide". Further, neither Calcium Oxide nor Calcium Hydroxide would be considered "sand"; although particles of "silicon dioxide" certainly would be.)
Actually, fly ash concrete has been used for many years to make impermeable water tanks and pipes, and no elevated concentrations of metals have ever been measured in the water.
The concrete and cement industries have mounted a major effort to combat this threat.
Their message is that the problems with coal ash disposal can be addressed without restricting the beneficial uses of fly ash.
Anyone in the concrete industry can contact his congressional representatives and senators or EPA Administrator Jackson and request that they look at the facts rather than the hysteria. No one has ever been harmed by using fly ash, but the EPA's actions could harm many."
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And, there is an issue here that we miners of Coal and we producers of Coal-based electricity must own up to, which is:
"the problems with coal ash disposal".
The Kingston, Tennessee, failure was inexcusable. And, it was, from our point of view, inexcusable for reasons above and beyond the seeming neglect that was evident in constructing, inspecting and maintaining the flawed Coal Ash impoundment.
It was inexcusable, as well, just as all, even structurally-sound and well-maintained, Coal Ash disposal impoundments might be seen as inexcusable.
They are a waste of a valuable raw material resource and a waste of opportunity.
Simple disposal, in and of itself, is inexcusable; and, that is the essence of one the proposals EPA is dealing with and considering:
If the intent is just to dispose of the Ash, then simple disposal would be heavily regulated.
But, if the Ash were being directed for reuse in the making of Cement and/or Concrete, or another Ash consuming or encapsulating application, then the restrictions and demands would be much less severe.
As again confirmed herein, the United States Cement and Concrete industry recognizes and acknowledges that Coal Ash can be productively utilized in the making of Portland Cement and Portland Cement Concrete.
But, those folks are not going to come around knocking on our door with an empty bucket asking if they can borry some.
Their current raw material - limestone, sand, etc. - suppliers are coming around to their Cement plants to see them, and are offering contracts guaranteeing supply of specified materials at stable prices with volume discounts; and, buying lunch and handing out tickets to games at Mountaineer Field.
If we want to compete for some of that Cement and Concrete business, then, we will have to compete.
There's also a thing called "pull-through" sales, as well; and, that would happen, for instance, if we got off our dead cans and made the effort to demonstrate the demonstrable fact that Coal Ash Cement and Coal Ash Concrete are, simply, better, to someone who needs and buys a fair amount of Cement and Concrete - say, for example, the West Virginia, Pennsylvania and Ohio state highways departments - and, get them to tell the people they buy Cement and Concrete from that, by golly, from now on, they only want to buy and use Cement and Concrete that's made out of Coal Ash; and, that's because it makes sense for the people who use the roads and for the people who own and maintain the roads - the states, and thus the people, of West Virginia, Pennsylvania and Ohio.
Given that Coal Ash can - as can now easily be documented - enable the making of physically better and less energy demanding, more environmentally-friendly, and even cheaper, Cement and Concrete: if we, then, don't take it upon ourselves to even make the effort to "sell" our more local Cement-making industries and our more local consumers of Cement and Concrete products the Coal Ash byproduct arising from our use of Coal in the generation of genuinely economical electricity, and, thereby, clean up the environment a little bit, contribute to the construction of a better concrete-based infrastructure that would serve us all, and, create a few more jobs for our neighbors, that, indeed, would be inexcusable.
We need to get ourselves educated about the genuine value of Coal Ash, get off our dead cans, and get to work.
And, that work needs to start, right now, by letting our elected representatives, and our self-styled providers of news and information, know how we feel about it all.
First and foremost, as Concrete Producer Magazine herein emphasizes, we must, to preserve the commercial viability of Coal Ash, prevent if from being labeled, under any circumstances, as "hazardous" waste. Such a classification would throw difficult hurdles into the path of utilizing Coal Ash in applications, such as the manufacture of Cement and Concrete, where it already does have, and could have even more, great and beneficial economic and environmental effects.
