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Coal Combustion Product Regulation and Remediation
Industrial Outlook
Managing industrial byproducts is an integral part of production. For electric utilities that rely on coal as a fuel source, the coal combustion product (CCP) that is created during power generation requires special attention to protect human health and the environment. The treatment of CCP—and other industrial byproducts that require large-scale storage or disposal impoundments—has become a regulatory hot topic, igniting debate and investigation around the globe. This issue has gained more attention as a result of recent impoundment failures, including a CCP spill in Tennessee, USA, and a red sludge release in Hungary.
CCP, which typically contains trace amounts of metals, but rarely reaches the hazardous waste characteristic levels defined by the U.S. Resource Conservation and Recovery Act, is beneficially reused in a number of ways. According to the Utility Solid Waste Activities Group (USWAG), nearly 45 percent of CCP is recycled each year for use in concrete, cosmetics and other industries. Unused CCP is disposed of by sluicing the coal ash to impoundments, which may be classified as dams, subject to federal or state dam safety regulations. Some utilities have moved to innovative dry stacking systems as a means to avoid the risks associated with these types of wet impoundments.
After recent CCP impoundment safety incidents raised concern across the industry, it has become important for utilities to be aware of the changing regulatory environment, identify risks associated with production, and assess short- and long-term risk management plans.
A Global Concern
Following a CCP spill at the Tennessee Valley Authority’s (TVA) Kingston facility in December of 2008, which flooded more than 300 acres of land, the U.S. Environmental Protection Agency (EPA) started to assess these types of impoundments. The TVA spill prompted the EPA to begin gathering information nationwide to assess further risks and inform future regulation.
Site assessments across the United States are ongoing as new legislation is proposed and discussed, including the possibility of banning these impoundments or regulating CCP as hazardous waste. Electrical utilities also need to be aware of several state-level programs and legislation. For example:
- In North Carolina, CCP impoundments are regulated under state dam safety jurisdiction. Effective January 1, 2010, North Carolina senate bill 1004 brought certain dams used in connection with electric generating facilities under the Dam Safety Act.
- In Texas, utilities using CCP impoundments must comply with the state’s dam safety program. The program monitors, regulates and inspects private and public dams, making recommendations to help utilities maintain safe facilities.
In Europe, the issue of industrial wet byproduct management grew in importance when a Hungarian aluminum company’s sludge reservoir failed. In October of 2010, the reservoir dam ruptured, flooding 800 hectares with red sludge and water. The catastrophic event killed several people, injured hundreds of others and caused Hungary to activate the European Union (EU) Civil Protection Mechanism for urgent international assistance and response. This disaster resulted in calls for stricter EU and international regulations.
Possible Next Steps
Self-assessment and risk management are important, proactive steps that utilities can take to assure safety and prepare for regulatory changes. The EPA has been conducting multi-step assessments of CCP impoundments across the United States, and has discovered several common problems and risks:
- General maintenance—including overgrown vegetation, animal or rodent activity, drainage issues, embankment erosion, mechanical issues, and inadequate records and documentation
- Dam safety inspections—insufficient or infrequent inspection, training and documentation
- Instrumentation and monitoring—abandoned, insufficient or nonexistent devices for monitoring safety
- Dam safety engineering—missing or inadequately documented engineering studies or design
- Permitting and regulation—compliance issues from operator or agency
Taking stock of these issues during self inspection is important. There are several options for CCP management in the future, ranging from upgrading liner systems in CCP ponds to switching to dry ash systems. Self-monitoring and staying informed are key steps to being prepared for possible regulatory changes being discussed by the EPA and European Environment Agency.
Be Informed
To learn more about CCP and remediation issues, visit the following websites:
