2011SS AWMA Rochelle Routman

8/12/2019 2011SS AWMA Rochelle Routman

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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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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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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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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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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


7/26Environmental Affairs

Ash Handling Facilities

Ash Landfill Ash Pond



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%



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)



Georgia Power Ash Dam Safety

Inspections

Annual

Weekly

Daily

Training

Vegetation control

Instrumentation Ash dam inspection by plant personnel



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



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



TVA Kingston, TN Spill



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



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



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



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



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



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



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



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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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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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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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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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

Documents

2011SS AWMA Rochelle Routman