http://www.eurelectric.org/
To be perfectly honest, in reference to the title of this dispatch, it was a team of Common Market organizations with ties to the trans-European power generation industry who said, right up front, more than a decade ago, that, not only is Coal Ash an established "commercial product of high quality" within the European building materials market, but, that it is also, most definitely, "non-hazardous".
They do make a darned-good case for it, even documenting that some European countries that don't generate any Coal Ash of their own, or very little of it, actually import Coal Ash for use in construction projects from their Common Market neighbors who have some to spare.
That, of course, would be much like the situation described in our report of:West Virginia Coal Association | US EPA Headquarters Housed in Coal Ash | Research & Development; concerning, in part, the fact, that: Coal power plant "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.".
There aren't, insofar as we have been able to determine, any Coal-fired power plants in the District of Columbia. The Coal Ash used in the construction of the Environmental Protection Agency's offices had to have crossed a state-DC border, it had to have been imported, to get there.
But, we submit the information herein to you in preparation for further reports to follow on what seems the ever-changing US EPA positions on Coal Ash, which they once, as in:
West Virginia Coal Association | US EPA Recommends Coal Ash for Road Construction | Research & Development; concerning: "'Using Coal Ash in Highway Construction; A Guide to Benefits and Impacts'; EPA-530-K-05-002; 2005; One of the most impressive concrete structures in the country, the Hungry Horse Dam near Glacier National Park in Montana, was constructed from 1948 to 1952, with concrete containing coal fly ash. In Washington, DC, both the metropolitan area subway system (Metro) and the new Ronald Reagan Building and International Trade Center were built with concrete containing coal fly ash. Other significant structures utilizing coal fly ash in concrete include the “Big Dig” in Boston and the decks and piers of Tampa Bay’s Sunshine Skyway Bridge. The U.S. Environmental Protection Agency (EPA) encourages the use of coal combustion products (CCPs) in highway construction projects such as in concrete, road base, embankments, flowable fill, and other beneficial applications. The increased use of these materials, which would otherwise be discarded as waste, can reduce greenhouse gases in the atmosphere, reduce energy consumption, and conserve natural resources";
actively promoted the beneficial use of; even to the point of, as seen in:
West Virginia Coal Association | US EPA Confirms Environmental Benefits of Coal Ash Utilization | Research & Development; concerning: "Study on Increasing the Usage of Recovered Mineral Components in Federally Funded Projects Involving Procurement of Cement or Concrete; United States Environmental Protection Agency in conjunction with the U.S. Department of Transportation and the U.S. Department of Energy; Report to Congress; June 3, 2008; EPA530-R-08-007; The most common beneficial use of coal fly ash is as a Supplementary Cementitious Material (SCM) in concrete. Coal fly ash is also used as a raw material in the production of cement clinker and as an additive to blended cements. The consistency and abundance of coal fly ash in many areas present unique opportunities for use in many construction applications, including pavements and highway and transportation structures, and can generate environmental benefits when used as a replacement for virgin materials (e.g., portland cement). Certain performance benefits can be attained through the use of coal fly ash in concrete, including greater workability, higher strength, and increased longevity in the finished concrete product";
not long ago touting the environmental benefits of using Coal Ash in "many construction applications".
In any case, comment follows excerpts from the initial link in this dispatch to:
"Fly Ash from Coal Fired Power Plants A Non-Hazardous Material
Residues Task Force; Union of the Electric Industry - Eurelectric; Brussels, Belgium
The "Union of the Electricity Industry - EURELECTRIC", formed as a result of a merger in December
1999 of the twin Electricity Industry Associations, UNIPEDE (International Union of Producers and Distributors of Electrical Energy) and EURELECTRIC (European Grouping of Electricity Undertakings), is the sector association representing the common interests of the European Electricity Industry and its worldwide
affiliates and associates ... in order to promote the interests of its members at a political level and to create awareness of its policies. Its mission is to contribute to the development and competitiveness of the Electricity Industry and to promote the role of electricity in the advancement of society.
(Concerning the above statement that the entity which made the report was "formed ... December 1999", the report we include herein, supposedly by "Union of the Electric Industry - Eurelectric" is dated, unless we're misreading something, "October 1999". We can't explain the apparent discrepancy.)
At the 3rd Conference of the Parties to the Basel Convention on Transboundary Movements of Hazardous Wastes and their Disposal held in 1995, a ban was adopted on the trade of hazardous wastes from industrialised countries to developing countries. This international agreement was justified by the desire to protect the importing countries from the influx of wastes presenting hazards to public health and the environment. At the 4th Conference of the Parties held in 1998, two lists of wastes were defined; List A,
containing wastes considered as hazardous, and List B, specifying non-hazardous wastes. Both lists are now part of the Basel Convention. Suprisingly, coal-fired power plant fly ash occurs on both lists.
UNIPEDE/EURELECTRIC asserts that the current entry of fly ash on List A is unjustified.
UNIPEDE/EURELECTRIC is therefore asking for the removal of coal fly ash from List A. To support this proposal, this paper summarises information gathered from UNIPEDE/EURELECTRIC member countries which demonstrates that all coal fly ash, including that moved across national boundaries destined for recovery, does not exhibit any of the hazard characteristics listed in Annex III of the Convention.
Coal fly ash is a fine-grained material which is mostly made up of spherical, glassy particles. Elemental analysis shows that the main components are silicon, aluminium and calcium. Coal fly ash is very poorly soluble in water. Heavy metals, tightly bonded to ash particles, typically make up less than 1% of the total mass. Due to its composition and genesis, coal fly ash exhibits pozzolanic properties; it reacts with dissolved calcium hydroxide and water at normal temperature to form strength-developing minerals in a similar manner to cement.
The overall utilization of fly ash has increased in the last few years. It is being used more and more in high quality areas, such as the production of concrete and cement (1993: 20%, 1997: 28%) where it is used as a substitute for natural resources.
Fly ash is also utilised in a wide range of applications in the road construction and in the building industry.
The use of fly ash as building material allows energy savings and the reduction of CO2 emissions as one tonne of fly ash replacing cement saves one tonne of CO2. ... Fly ash is transported within countries and across frontiers mainly for these purposes.(We've documented and reported numerous times that, as above, replacing one ton of Portland-type cement, which is made via a process represented by the formula: CaCO3 (limestone) + Heat = CaO (cement) + CO2, with Coal Ash prevents the emission of at least one ton of CO2; likely more, since the source of the "Heat" for the limestone calcination needs to be added to the equation, as it is likely generated by the combustion of a fossil fuel.)
A proportion of the fly ash produced in some countries is exported for recovery operations. In the main, these movements are to neighbouring countries. The fly ash involved is valued as a commercial product of high quality within the European building material market.
Where it is destined for specific uses, it has to meet quality standards that are set out in documents such as the European (CEN) Standard EN450 “Fly Ash for Concrete”. For the fly ash producers, the users and for the trade associations involved, transboundary marketing is a very important economic issue.
The following examples show the significance of transfrontier movements of fly ash for utilisation. In 1998, France exported about 200 000 tonnes of coal fly ash (less than 10% of the French annual production). Most of this went to Germany, Switzerland and Belgium. In the Netherlands, between 40 and 50% (between 400.000 and 500.000 tonnes) of the national production of coal fly ash leaves the country for recovery operations. In Germany, trade relations exist with other member countries of the European Union, including Austria, Belgium, Denmark, France and the Netherlands, and others, such as the Czech Republic, Poland and Switzerland. The result is that each year approximately 600.000 tonnes of fly ash are imported and about 400.000 tonnes (less than 5% of the German annual production) are exported. Thus, about 1 million tonnes of fly ash are transported within, into and out of the European Union due to the current German market alone.
The EWC (European Waste Catalog) was implemented into German national law in 1996. Since then, coal fly ash has been listed ... as a nonhazardous waste with no further restrictions concerning recovery operations. In earlier German legislation, fly ash from coal-fired power plants was never classified as hazardous.
Coal fly ash is not included on the list of hazardous waste that was implemented in France in 1997.
(In Italy, a) decree of the Ministry of the Environment (1998) facilitates the recovery of fly ash to produce cement, bricks and expanded clay. In earlier legislation, fly ash was also classified as non hazardous.
According to the Portuguese regulation coal fly ash is classified as non hazardous waste.
Coal fly ash is considered as a non hazardous waste under the Austrian Landfill Regulation.
Heavy metal concentrations in fly ash are, on average, well below the lowest threshold values given in (applicable directives) on the use of sewage sludge as a fertiliser.
(Coal Ash, in other words, has lower concentrations of heavy metals than the stuff they currently use to fertilize their food crops with. And, keep in mind that this is modern-day Europe we're talking about here, not a medieval outpost in a Third World nation.)
The compositions of leachates obtained from 1:10 mixtures of fly ash and demineralised water are given in (an accompanying table). The data show that the leachate obtained from fly ash is either below or within an order of magnitude of the threshold values given in (the applicable European directive) concerning the quality of water intended for human consumption.
(Europe, in other words, seems to be saying that water which has passed through Coal Ash is likely okay even to drink.)
In Germany, the fly ash from coal-fired power plants is classified as a substance that typically generates no water pollution.
(In France, neither) fly ash samples nor leachates showed a permanent or adverse effect upon ... tested organisms and no biological threshold was exceeded.
(In Spain, for) all the leachates tested, fly ash was shown not to be ecotoxic (i.e. toxic to the ecology or the environment)
No permanent and no adverse effects have been observed when fly ash and its leachates are submitted to biological tests. The wide range of species that have been used and the total lack of any positive response to the biological tests described (in an included section) lead to the conclusion that coal fly ash is not ecotoxic.
Consequently, when compared to the list of hazardous characteristics, it can be concluded that fly ash is neither:
Ecotoxic (a “substance or waste which, if released, present or may present immediately or delayed adverse impacts to the environment by means of bioaccumulation and/or toxic effects upon biotic systems”), nor
capable, by any means, after disposal, of yielding another material, e.g. leachate, which possesses any of the characteristics listed (which characteristics define an "ecotoxin").
(At least in Europe, in other words, Coal Ash ain’t harmful to the environment around us or to the critters that share our world, no matter what some might want us to believe.)
In addition, the numerous studies summarized in (an included section of the report) on health effects and on the toxic properties of fly ash prove that coal fly ash does not have any adverse effect on the environment or on humans.
The utilization of coal fly ash often actually contributes to global environmental protection and has ecological advantages. Its use as a replacement for minerals or manufactured products acts to preserve natural resources as well as to save energy and to reduce CO2 emissions.
Summarizing, coal fly ash has been shown to have no toxic or ecotoxic properties (and) coal fly ash does not have any adverse effect on the environment or on humans.
No significant impact on either human health or on the environment has been found after laboratory testing or during on-site monitoring. Therefore, the gathered knowledge about fly ash from coal-fired power plants and the fact that coal fly ash is listed as non hazardous in the European Union lead to the conclusion that ... coal fly ash should be properly listed as non-hazardous waste under the Basel Convention."
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So, at least "in the European Union", the "fly ash from coal-fired power plants" is considered by some to be "non-hazardous".
Why it might be hazardous in the United States, presuming the absence of unwarranted influence wielded by unduly interested parties, we have no idea.
As we documented in:
West Virginia Coal Association | Obama White House Blocked EPA Coal Ash 'Hazardous' Label | Research & Development; concerning: "'EPA Backed Off 'Hazardous' Label for Coal Ash After White House Review'; May 7, 2010; U.S. EPA's proposed regulation of coal ash as a hazardous waste was changed at the White House to give equal standing to an alternative favored by the coal industry and coal-burning electric utilities";
President Obama and his staff not that long ago blocked one attempt by the US EPA to reclassify Coal Ash as hazardous.
And, as we will document in a report soon to follow, it seems his influence has had some good effect in a new proposal, or opinion, which seems to be being promulgated at the EPA, regarding what uses Coal Ash can safely, without regulation, be employed in.
But, in the European Union, a decade ago, the opinion being promoted and promulgated was, that, "coal fly ash has been shown to have no toxic or ecotoxic properties" (and) coal fly ash does not have any adverse effect on the environment or on humans".
Further: the "utilisation of coal fly ash ... contributes to global environmental protection".