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Environmental Affairs
Ash Management from Coal FiredPower PlantsCurrent Practices and Potential Impact of
Proposed EPA Regulation
Rochelle Routman, PG
Environmental SpecialistGeorgia Power
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Environmental Affairs
Georgia Power: Who we are
Largest of four Southern Company electric utilities
2.3M+ customers
8,600 employees
Nearly 13,000 miles oftransmission lines
70,000 miles of distribution
lines
High customer satisfaction Rates below the national average
Georgi
aPower
Alabam
aPower
Gulf Power
Mississippi
Power
Georgia
Power
Alabama
Power
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Environmental Affairs
Coal
US Resources The US has the largest
reserves of coal in the world
Based on currentconsumption, there is about
200 years of accessible
coal remaining to generate
energy
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Environmental Affairs
AshA 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
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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, chromiumIs classified as an industrial solid waste
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Ash Handling Facilities
Ash Landfill Ash Pond
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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%
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Southern Co. Beneficial ReuseAbout 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 2months of an automobiles CO2emissions, and
saves the same amount of energy used by an
average home for 19 days(US EPA, April 2005, EPA-530-K-05-002)
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Georgia Power Ash Dam Safety
Inspections
Annual
Weekly
Daily
Training
Vegetation control
Instrumentation Ash dam inspection by plant personnel
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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
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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 ofEmory River
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TVA Kingston, TN Spill
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TVA Ash Spill
Root Cause AnalysisAccording 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
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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
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EPA Ash Dam InspectionsCondition Ratings
Rating What it means EPA rating of 228units inspected to
date (www.EPA.gov)
Satisfactory No safety
deficiencies
106
Fair Acceptable
performance
67
Poor Remedial action/
investigationsneeded
55
Unsatisfactory Unsafe; immediate
action required
0
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Georgia Power Ash Dam InspectionsCondition Ratings
Rating What it means EPA rating of 25units inspected to
date (www.EPA.gov)
Satisfactory No safety
deficiencies
22
Fair Acceptable
performance
2
Poor Remedial action/
investigationsneeded
1 - Conditional
Unsatisfactory Unsafe; immediate
action required
0
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New Ash Rules Propose to Regulate
CCRs = Coal Combustion ResiduesCCRs generated by electric utilities and
independent power producers
CCRs destined for disposal in
Landfills or
Surface impoundments
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EPAs Proposed Ash Rule:
Two Main OptionsRCRA Subtitle C Option: Hazardous waste
regulation
RCRA Subtitle D Option: Non-hazardous, solidwaste regulation
RCRA Subtitle D Prime Option
Slight variation of Subtitle D OptionUseful Life
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Common Requirements Between
Subtitles C and DDam Safety requirements
Design construction/maintenance documents; closure
plans; inspections ; annual certification by anindependent PE
Groundwater monitoring and Liners
Corrective action Used when contamination is detected
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RCRA Subtitle C Option
Special Waste classification Subject to most hazardous waste requirements
Includes CCRs intended for disposal, not CCRs intendedfor beneficial use
Federal permit required
Regulation from generation to disposal Including during and after closure of disposal unit
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Environmental Affairs
RCRA Subtitle C OptionSome 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 about130 M tons annually to the 2.5 M tons of hazardouswaste now disposed of annually
Likely decline in beneficial reuse due to stigma
American Concrete Association: Designation of fly ashas a hazardous waste will likely eliminate itsinclusion in future project specifications for fear of
possible legal exposure and liability.
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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
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Environmental Affairs
RCRA Subtitle D Option
Some Industry ImplicationsRetrofit 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
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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
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Proper management of CCBs is an importantpart of the process of providing reliable,
affordable, and environmentally responsible
energy