Ash Management from Coal Fired Power Plants Current Practices and Potential Impact of Proposed EPA Regulation

1. Ash Management from Coal Fired Power PlantsCurrent Practices and Potential Impact of Proposed EPA Regulation Rochelle Routman, PG Environmental Specialist Georgia Power

2. Alabama Power Georgia Power Mississippi Power Gulf Power 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 Alabama Power Georgia Power

3. CoalUS Resources • The US has the largest reserves of coal in the world • Based on current consumption, there is about 200 years of accessible coal remaining to generate energy

4. Energy GenerationCoal is Vital • 45% of energy generated in the US is from coal • About 11% renewables, including hydro • Energy efficiency, clean coal technology, and renewables are necessary to meet energy needs of the future

5. 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

6. 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, chromium • Is classified as an industrial solid waste

7. Ash Handling Facilities Ash Landfill Ash Pond

8. Southern Co Ash Handling Practices

9. Southern Co. Beneficial ReuseAbout 30% Annually Bottom Ash Top Ash Cement manufacturing Ready-mix concrete • Replacement for naturally mined aggregate (clay and shale) • Road base • Concrete block One ton of fly ash used as replacement for cement conserves landfill space to hold about 1200 lbs of waste, reduces the equivalent of 2 months of an automobile’s CO2 emissions, and saves the same amount of energy used by an average home for 19 days (US EPA, April 2005, EPA-530-K-05-002)

10. Georgia Power Ash Dam Safety • Inspections • Annual • Weekly • Daily • Training • Vegetation control • Instrumentation Ash dam inspection by plant personnel

11. 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

12. 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 of Emory River

13. TVA Kingston, TN Spill

14. TVA Ash SpillRoot Cause Analysis • According to TVA’s web site: • High water content of the wet ash • Increasing height of ash • Construction of the sloping dikes over the wet ash • Unusual bottom layer of ash and silt

15. 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

16. EPA Ash Dam InspectionsCondition Ratings

17. Georgia Power Ash Dam InspectionsCondition Ratings

18. New Ash Rules Propose to RegulateCCRs = Coal Combustion Residues • CCRs generated by electric utilities and independent power producers • CCRs destined for disposal in • Landfills or • Surface impoundments

19. EPA’s Proposed Ash Rule: Two Main Options RCRA Subtitle C Option: Hazardous waste regulation RCRA Subtitle D Option: Non-hazardous, solid waste regulation RCRA Subtitle D “Prime” Option Slight variation of Subtitle D Option—“Useful Life”

20. Common Requirements Between Subtitles C and D Dam Safety requirements Design construction/maintenance documents; closure plans; inspections ; annual certification by an independent PE Groundwater monitoring and Liners Corrective action Used when contamination is detected

21. RCRA Subtitle C Option “Special Waste” classification Subject to most hazardous waste requirements Includes CCRs intended for disposal, not CCRs intended for beneficial use Federal permit required Regulation from generation to disposal Including during and after closure of disposal unit

22. 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 about 130 M tons annually to the 2.5 M tons of hazardous waste now disposed of annually • Likely decline in beneficial reuse due to stigma • American Concrete Association: Designation of fly ash as a ‘hazardous waste’ will likely eliminate its inclusion in future project specifications for fear of possible legal exposure and liability.

23. 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

24. RCRA Subtitle D OptionSome Industry Implications • Retrofit 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

25. 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

26. Proper management of CCBs is an important part of the process of providing reliable, affordable, and environmentally responsible energy