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The Coal Combustion Product Partnership Opportunities and Challenges John Sager, USEPA

The Coal Combustion Product Partnership Opportunities and Challenges John Sager, USEPA C2P2 Coordinator July 26, 2006. C2P2 Today. C2P2 is 3 years old with 137 members.

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The Coal Combustion Product Partnership Opportunities and Challenges John Sager, USEPA

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  1. The Coal Combustion Product Partnership Opportunities and Challenges John Sager, USEPA C2P2 Coordinator July 26, 2006

  2. C2P2 Today • C2P2 is 3 years old with 137 members. • Department of Energy, Federal Highway Administration, American Coal Ash Association, and Utility Solid Waste Activities Group are considered major partners. • C2P2 is generally regarded as a model Resource Conservation Challenge Program. • CCP use increased from 31% in 2001 to 40% in 2004, with total generation in 2004 of 122 million tons, based the most recent ACAA survey. • Successful C2P2 program development led to formation of the Industrial Recycling Council of secondary material industries and EPA’s Industrial Material Recycling Team. • 2006 C2P2 awards scheduled for National Recycling Council Congress in Atlanta in October with NRC adopting industrial materials as focus area.

  3. C2P2 Core Activities Today • Membership and Award Program • State reviews • Technical assistance workshops • Publications • Outreach: web site, fact sheets, case studies • Related activities: • IWEM and risk assessment tool development • Beneficial Use Summit support • Green Highways • Construction Initiative • American Concrete Institute Sustainability Committee, ASTM committees, EPA Sector Strategies, Office of International Activities

  4. Membership and Award Program Highlights and Next Steps • Awards ceremony at World of Coal Ash Symposium in Lexington, KY in 2005 was a great success, invigorating the entire CCP industry. • 2006 awards will be held at NRC congress in Atlanta in October. Details are still to be worked out, but this development highlights the success of C2P2 and the “mainstreaming” of industrial material “recycling.” • Current membership roll is predominantly made up of CCP sellers. Significant increases in membership would likely require changes, such as more EPA staff devoted to recruiting (e.g., account reps like Energy Star), and the development of incentives for consumers such as concrete companies and state DOTs to join.

  5. State Review Highlights and Next Steps • Texas review report was published in 2005. Findings include: --high rate of utilization (60 – 70%) --supportive regulatory environment based on a history of cooperation between Texas CEQ and well organized industry. • Florida review conducted in 2005; report expected in 2006. Findings include: --high rate of utilization based on widespread residential and commercial construction and an estimated 500,000 tons of ash imported from out of state --significant quantity of fly ash generated in state can not be used in concrete due to air emission controls. --State regulations can be restrictive for land placement --Florida DEQ is considering new regulations. DEQ and CCP industry plan increased dialogue as a result of well received review. • Northern state expected for review in 2006 • Plans are in the works for state review summary report to be led by DOE in 2007 or 2008.

  6. Technical Assistance Workshops Highlights and Next Steps • Successful 2005 workshops held in Puerto Rico, Atlanta, Chicago, Denver, Milwaukee and Washington, D.C. • Puerto Rico workshops (2) were a major undertaking, involving meetings with industry and commonwealth offices of environment, transportation, agriculture, and economic development. • Milwaukee workshop was the first of its kind for C2P2, held in conjunction with the University of New Hampshire and expanded to include foundry sands and other materials. • Cosponsored workshop with OPEI on use of byproduct materials in cement kilns. • 2006 workshop plans include early discussions with Regions 1 and 9 and targeted FHWA and DOT locations.

  7. Publications and Outreach Highlights and Next Steps • “Health and Environmental Impacts” booklet on highway construction (Green Book) published in 2005 to positive reception • Building construction resources web site created in 2006 • C2P2 web site continues in development and is a primary source of information • Interagency agreement in place in 2006 – 2007 to begin update to FHWA “User Guidelines for Industrial Byproduct Materials in Pavement Construction.” Additional joint efforts to be identified. • Analysis and report or booklet on use of flue gas desulfurization material planned for 2006-2007. • Significant cooperation and interaction with Regions expected in 2006, including support of beneficial use summit in San Francisco and industrial material recycling training for regional EPA staff in October. • Construction Initiative continues to hold promise for promoting C2P2 goals • Report to Congress on mineral recycling due in 2007 may have impact on federal purchasing of CCPs.

  8. IWEM and Risk Assessment Tool Development • IWEM can be an effective tool for supporting beneficial use determinations. Use is slowly taking hold in States and Regions following release in 2003 (e.g., Minnesota guidance, Ohio reg development, and Region 8 solid waste conference). • Results of IWEM assessment by University of New Hampshire due in 2006. • C2P2-sponsored beneficial use modeling conference in New Hampshire held in 2005; attended by EMRAD and ORD was a great success. • C2P2 will continue to promote development of monitoring data to assess and benchmark IWEM and 3MRA.

  9. C2P2, Highways, and Building Construction • Promoting use of CCPs in highway construction has occupied more resources to date than similar work in the area of building construction. • Green Highways may afford opportunities for targeted workshops, changes in specifications, and possibly a third party certification process like LEED. --Increased dialogue between environmental and transportation planners is good. • Biggest growth area for CCP use in concrete – where GHG savings can be realized – may be in building construction, not highways, as long as new asphalt continues to be used in highways. • Emergence of American Concrete Institute Sustainability Committee provides a god opportunity for serious discussion about increasing use of CCPs in concrete. • Development of a goal for use of supplementary cementitious materials (SCMS) in concrete, including coal ash, silica fume and cement kiln dust, may help promote GHG emission benefits associated with CCPs and other materials.

  10. Challenges and Opportunities • EPA Strategic Plan goal of 50%CCP recycling by 2011 • Mercury emissions • Low NOx burners • National Academy of Sciences report "Managing Coal Combustion Residues in Mines" • IWEM • Report to Congress on mineral recycling • Construction Initiative • Green Highways

  11. Impact of Air Regulations • Air regulations pose challenges for use of CCPs in some applications. • Low NOx burners burn less carbon, which creates a fly ash that may not meet concrete specifications (e.g., specifications for coloration). For example, Florida has huge need for ash but does not use some of available in-State ash. • Mercury issues are increasingly identified as barriers to CCP utilization. • EPA Office of Air and Radiation has previously said they do not expect recent mercury regulations to significantly impact fly ash. • ORD research suggests that mercury does not leach readily from CCPs, nor is off-gassing from wallboard a problem. Biggest concern in recent, draft ORD paper seems to be use of CCPs with mercury in cement kilns.

  12. Mercury and CCPs • Many different applications and products for CCPs, need to consider impact of mercury in different situations • C2P2 looks to EPA regulations for applicable limits • EPA’s “Using Coal Ash in Highway Construction: A Guide to Benefits and Impacts” is the primary policy document produced by the Office of Solid Waste. It states: “…Studies…have shown that mercury releases from coal ash to the environment are negligible. Results from water leachate tests showed that mercury was very stable in coal fly ash.” • Nonetheless, careful evaluation is necessary when considering land placement of CCPs near groundwater in road base or in fill, with respect to mercury and other metals.

  13. Mercury and CCPs • C2P2 looks to EPA’s Office of Research and Development and the Department of Energy for some of their research in this area. Please note work from Susan Thorneloe at EPA’s Office of Research and Development and Bill Aljoe at DOE’s National Energy Technology Laboratory. • Proposed regulation of the use of fly ash as feedstock for cement kilns is an area of particular focus today. Please note work from Keith Barnett at EPA’s Office of Air and Radiation. • Worker safety in wallboard manufacture is another area of concern with respect to mercury

  14. Mercury Resources • http://www.epa.gov/airmarkets/camr/index.html • http://www.epa.gov/airmarkets/cair/index.html • http://www.environmentalintegrity.org/pubs/Dirty%20Kilowatts.pdf (do a search for "mercury") • Industry website: http://www.mercuryanswers.org/ • Non-profit Annapolis Center site: www.AnnapolisCenter.org

  15. CCPs in Cement Kiln Feed Following are some questions that can help determine the overall environmental impacts of using fly ash to produce clinker: • What are the mercury contents of fly ash (the DOE data should go a long way to answering that question)? • What specific raw materials does the fly ash replace? • What are the typical mercury contents of he replaced raw materials? • What other impacts does the addition of fly ash have on the kiln, if any. Does it affect fuel use, does it affect other emissions? Are there any data to quantify these impacts? If not, can the impacts be estimated based on some type of combustion calculations?

  16. NAS Report: "Managing Coal Combustion Residues in Mines" • The National Academy of Sciences (NAS) published the report "Managing Coal Combustion Residues in Mines" in March, 2006. which was requested by the EPA under the direction of Congress. • The report generally supports the cautious use of mine placement of coal ash in appropriate circumstances. • Free PDF downloads of the entire report, the summary and the press release are available on their website at http://www4.nationalacademies.org/news.nsf/isbn/0309100496?OpenDocument.

  17. Report to Congress on Mineral Recycling • Report to Congress on use of recovered minerals in cement and concrete due in 2007 • Focus of report is on materials for which the EPA has procurement guidelines, including CCPs, slag, foundry sands and silica fume. • The legislation calls for EPA to make recommendations as to how to increase the use of these materials. • Workgroup participation is open to interested parties.

  18. Possible uses of IWEM to support industrial material recycling goals • How can IWEM, or any other model, help? • Let’s consider coal ash. • C2P2 is a partnership program to promote the beneficial use of coal combustion products (CCPs). • In 2004, 122 million tons of coal ash was generated by electric utilities in the United States, 49 million tons or 40% of which was put to beneficial use as CCPs. • EPA has set a strategic plan goal to increase the recycling rate to 50% by 2011. How do we get there?

  19. Using IWEM to Increase Industrial Material Recycling • The highest environmental and economic value use of CCPs is the use of coal fly ash as a supplementary cementitious material (SCM) in the manufacture of cement and concrete. • IWEM is not going to provide significant insight into the use of SCMs and other, above the ground, encapsulated uses. EPA has taken the position that we support and promote these uses. • The real need is for help in making decisions about putting CCPs in the ground, as structural fill, in flowable fill, in embankments, in road base, and in soil modification.

  20. Using IWEM to Increase Industrial Material Recycling • While EPA does not have any formal policy in this area, it is arguable that use in embankments, flowable fill, and structural fill may be analogous to placement in a an unlined landfill or waste pile for which IWEM may be used in its current form. • IWEM also has a land application module for which beneficial use is already addressed in the Guide. • Modeling road base, sometimes known as “linear landfill,” is another area where IWEM may be helpful with appropriate modeling considerations about the length of roads, infiltration through road surfaces, and capillary effects at the edge of the road. • Similar analogies and engineering evaluations can be made for in-ground applications with foundry sands, C&D material, and other materials.

  21. Issues to Consider • Minnesota was a leader in the development of IWEM and is the first State to incorporate the model into its regulations. Following are some of the issues they have encountered: • (1) What type of long term technical assistance can EPA provide? The manual can answer some questions, but interpretation of unusual results or input of new data often creates new questions. • (2) There is a need for leachate data for construction and demolition disposal sites. Can EPA assist in identifying representative leach ate data and/or link leach ate data to various waste inputs? The pros and cons of using "real" leachate values vs. those from one of the leaching procedures may be helpful. (Boron is material that was discussed) • (3) Some of the current levels in the IWEM database are out of date (e.g., MCL levels, other risk-based levels). These need to be updated to ensure the output...maximum leach ate value...is accurate and protective.

  22. Issues to Consider More Minnesota issues: • (4) There are some special issues with using IWEM for land application of leach ate or other materials: (a) infiltration rate vs. dilution factor not always appropriate in a land application scenario (b) other factors like soil attenuation, etc are not accounted for, but would have a significant affect on public health safety. How can these be addressed by end users? This is an important decision for IWEM's use in ben. use decisions • (5) What is the infiltration rate for composite liners...how was it developed and is it based on double composite liners and not the specific liner that IWEM prescribes? • (6) How can you add unique liner designs? • (7) Why does Tier 1 always looks at both the MCL and a HBN? • (8) When is it appropriate to substitute a Kd value? • (9) Decision needed on the use of HRLs or a % of HRLs for use at the point of compliance in IWEM.

  23. Issues to Consider Additional considerations for use in modeling roadways: • 1. Length and width of the roadway source term; • 2. Widths of the two berms; • 3. Angle of the groundwater direction with respect to the roadway; • 4. Infiltration rates corresponding to the road-bed and the berms on either side of the road-bed. • 5. The enhanced version will have to be tested and verified. • 6. Demonstrations on the use of the enhanced version of IWEM are under consideration. • 7. A user guide and the documentation may be provided along with copies of the enhanced IWEM.

  24. For more information, contact: John Sager USEPA Office of Solid Waste C2P2 Coordinator 703-308-7256 sager.john@epa.gov

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