To CoueRsss; WASTES F/tort THE COHBUSTIO/J OF
COAL ey a.ecT*ic UTILITV
EXECUTIVE SUMMARY £,PA/53C?-S W-
530SW88002 8»-oo.a.A.l
The Environmental . Protection Agency (EPA) has prepared this report on
fossil fuel combustion wastes pursuant to the requirements of Section 8002 (n)
of the Resource Conservation and Recovery Act (RCRA) , as amended in 1980 .
These amendments to the Act added Section 8002 (n) , which directed the
Administrator of EPA to
conduct a detailed and comprehensive study and submit a
report on the adverse effects on human health and the
environment, if any, of the disposal and utilization of fly
ash waste, bottom ash waste, slag waste, flue gas emission
control waste, and other by-product materials generated
primarily from the combustion of coal or other fossil fuels.
Pending the completion of this study, fossil fuel combustion wastes were
exempted from the hazardous waste requirements established under RCRA. Under
Section 3001(b) (3) (A) , EPA is prohibited from regulating these wastes until at
least six months after this report is submitted to Congress.
If EPA determines that fossil fuel combustion wastes are hazardous under
RCRA, and therefore subject to regulation under Subtitle C, EPA has some
flexibility to promulgate regulations that take into account the unique
characteristics of these wastes. Section 3004(x) states ...
If ... fly ash waste, bottom ash waste, slag waste and flue
gas emission control waste generated primarily from the
combustion of coal or other fossil fuels ... is subject to
regulation under this subtitle, the Administrator is
authorized to modify the requirements of subsections (c),
(d), (e), (f), (g), (o) and (u) and section 3005(j) ... to
take into account the special characteristics of such wastes,
the practical difficulties associated with implementation of
such requirements, and site-specific characteristics ... so
long as such modified requirements assure protection of human
health and the environment.
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This report examines only those wastes generated from the combustion of coal
by the electric utility industry. These wastes account for approximately 90
percent of all wastes generated from the combustion of fossil fuels. EPA has
deferred study of the disposal of wastes generated by the combustion of other
fossil fuels and from coal combustion in industries other than the electric
utility industry until a later date.
Coal-fired power plants produce substantial quantities of wastes. In 1984
' about 69 million tons of ash and 16 million tons of flue gas desulfurization
wastes were generated. Because of increasing reliance on coal for producing
electricity, by the year 2000 the amount of ash waste is expected to increase by
about 75 percent to about 120 million tons annually; production of FGD wastes is
expected to triple to about 50 million tons annually.1 In addition to the
high-volume ash and flue gas desulfurization wastes, coal-fired power plants
also generate several lower-volume waste streams as a result of equipment
maintenance and cleaning activities.
About one-fifth of all waste generated at coal-fired electric utility power
plants is currently reused; the remaining four-fifths are typically disposed in
surface impoundments or landfills. The recycled wastes, usually fly ash, bottom
ash, or boiler slag, have been used primarily as cement additives, high-volume
road construction material, and blasting grit. There is some potential for
increased use of these wastes in such applications. However, barring the
1 It is possible that advances in coal combustion technology will alter
the amount and types of coal-combustion wastes produced in the future. An
analysis of these technological advances is beyond the scope of this report.
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development of new utilization techniques, or major changes in combustion and
environmental control technologies, the proportion of coal combustion wastes
that are reused is unlikely to change significantly.
While utility waste management sites are currently exempt from RCRA
hazardous waste requirements, they are subject to state and local level solid
waste laws and regulations. There is substantial variation in the
state-mandated disposal requirements.
Most utility waste management facilities were not designed to provide a high
level of protection against leaching. Only about 25 percent of all facilities
have liners to reduce off-site migration of leachate, although 40 percent of the
generating units built since 1975 have liners. Additionally, only about 15
percent have leachate collection systems; about one-third of all facilities have
ground-water monitoring systems to detect potential leachate problems. Both
leachate collection and ground-water monitoring systems are more common at newer
facilities.
The primary concern regarding the disposal of wastes from coal-fired power
plants is the potential for waste leachate to cause ground-water contamination.
Although most of the materials found in these wastes do not cause much concern
(for example, over 95 percent of ash is composed of oxides of silicon, aluminum,
iron, and calcium), small quantities of other constituents that could
potentially damage human health and the environment may also be present. These
constituents include arsenic, barium, cadmium, chromium, lead, mercury, and
selenium. At certain concentrations, these elements have toxic effects.
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To assess the potential threat to health and the environment posed by these
wastes and to document any specific damage cases, EPA, other agencies, and
various private organizations sponsored several studies. The main research
efforts cited in this Report to Congress are a 1985 study by Arthur D. Little,
Inc. for EPA, which -characterized the environmental effects of waste disposal at
several utility disposal sites, and a series of reports submitted to the Agency
in 1982 by the Utility Solid Waste Activities Group, the Edison Electric
Institute, and the National Rural Electric Cooperative Association.
The findings of these various research efforts indicate that most coal
combustion wastes do not exhibit any of the four hazardous characteristics
defined in RCRA Subpart C. The results of a substantial number of extraction
procedure tests were examined; these tests indicated that metals do not
generally leach out of coal combustion wastes at levels classified as hazardous
under RCRA. The only metals which were found in any ash or sludge samples at
"hazardous" levels were cadmium and arsenic. For boiler cleaning wastes,
chromium and lead were sometimes found at levels classified as hazardous under
RCRA. This waste stream was also found to be corrosive in a number of samples.
Results of EP Tests performed on co-disposed high and low volume wastes
indicate, however, that boiler cleaning wastes do not exhibit hazardous
characteristics when co-disposed with ash.
While most of the laboratory results indicated that coal combustion wastes
do not possess RCRA hazardous characteristics, in some instances, data on actual
field observations indicate that migration of potentially hazardous constituents
from utility waste disposal sites has occurred. For example, observed
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concentrations of contaminants found in ground water downgradient from the sites
exceed the Primary Drinking Water Standards about 5 percent of the time.
Although the magnitude of the PDWS exceedances are typically not many times
greater than the standard, a large number of disposal facilities report at least
one PDWS exceedance at some time.
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While a causal connection cannot always be made between the utility waste
disposal site and the presence of contaminants at concentrations in excess of
these standards, the available information indicates that some ground-water
contamination from utility disposal sites is indeed occurring. The actual
potential for exposure of human and ecological populations is likely to be
limited, however, since ground water in the vicinity of utility waste disposal
sites is not typically used for drinking water; the concentrations of
contaminants in the ground water also tend to be diluted in nearby surface water
bodies. These surface water bodies are typically used by electric utilities in
the power plants for cooling and other purposes.
The electric utility industry currently spends about $800 million annually
to dispose of its coal-fired combustion wastes. Under current practices, costs
for waste management at most basic facilities range from as little as $2 per ton
to as much as $31 per ton. Mitigative measures to control potential
leaching include installation of liners, leachate collection systems, and
ground-water monitoring systems and corrective action to clean up ground-water
contamination. These mitigative measures, which are currently used at some
utility waste disposal sites, may reduce the likelihood of ground-water
contamination, but may also substantially increase disposal costs. For example,
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the incremental cost of new waste disposal practices, excluding corrective .
action costs or higher recycling costs, could range up to $70 per to-n, or $3.7
billion annually if all wastes were listed as hazardous. While substantial on a
total cost basis, these increases would be unlikely to significantly affect the
rate at which existing power plants consume coal. Due to the competitiveness of
alternative fuels for electricity generation at future power plants, however,
any increase in disposal costs could potentially slow the growth in electric
utility coal consumption in future years. Moreover, if new disposal standards
require corrective action measures as set forth in 40 CFR 264.100, the costs to
utilities could be extremely high and could have a substantial effect on the
utility industry.
Based on the findings from this Report to Congress, the Agency presents
three preliminary recommendations for those wastes included in the scope of this
study. The recommendations are subject to change based on continuing
consultations with other government agencies and new information submitted
through the public hearings and comments on this report. Pursuant to the
process outlined in RCRA 3001(b)(3)(C), EPA will announce its regulatory
determination within six months after submitting this report to Congress.
First. EPA has concluded that coal combustion waste streams generally do not
exhibit hazardous characteristics under current RCRA regulations. EPA does not
intend to regulate under Subtitle C flv ash, bottom ash, boiler slag, and flue
gas desulfurization wastes. EPA's tentative conclusion is that current waste
management practices appear to be adequate for protecting human health and the
environment. The Agency prefers that these wastes remain under Subtitle D
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authority. EPA will use section 7003 of RCRA and sections 104 and 106 of CERCIA
to seek relief in any cases where wastes from coal combustion waste disposal
sites pose substantial threats or imminent hazards to human health and the
environment. Coal combustion waste problems can also be addressed under RCRA
Section 7002, which authorizes citizen lawsuits for violations of Subtitle D
requirements in 40 CFR Part 257.
Second. EPA is concerned that several other wastes from coal-fired utilities
may exhibit the hazardous characteristics of corrosivity or EP toxicitv and
merit regulation under Subtitle C. EPA intends to consider whether these waste
streams should be regulated under Subtitle C of RCRA based on further study and
information obtained durine the public comment period. The waste streams of
most concern appear to be those produced during equipment maintenance and water
purification, such as metal and boiler cleaning wastes. The information
available to the Agency at this time does not allow EPA to determine the exact
quantity of coal combustion wastes that may exhibit RCRA Subtitle C
characteristics. However, sufficient information does exist to indicate that
some equipment maintenance and water purification wastes do occasionally exhibit
RCRA hazardous characteristics, and therefore, may pose a danger to human health
and the environment. These wastes are similar to wastes produced by other
industries that are subject to Subtitle C.regulation, and waste management
practices for coal combustion wastes are often similar to waste management
practices employed by other industries. EPA is considering removing the
exemption for all coal-fired utility wastes other than those identified in the
first recommendation. The effect would be to apply Subtitle C regulation to any
of those wastes that are hazardous by the RCRA characteristic tests. EPA
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believes there are various treatment options available for these wastes that
would render them nonhazardous without major costs or disruptions to the
utilities.
Third. EPA encourages the utilization of coal combustion wastes as one
method for reducing the amount of these wastes that need to be disposed to the
extent such utilization can be done in an environmentally safe manner. From the
information available to the Agency at this time, current waste utilization
practices appear to be done in an environmentally safe manner. The Agency
supports voluntary efforts by industry to investigate additional possibilities
for utilizing coal combustion wastes.
Through its own analysis, evaluation of public comments, and consultation
with other agencies, the Agency will reach a regulatory determination within six
months of submission of this Report to Congress. In so doing, it will consider
and evaluate a broad range of management control options consistent with
protecting human health and the environment. Moreover, if the Agency determines
that Subtitle C regulation is warranted, in accordance with Section 3004(x) EPA
will take into account the "special characteristics of such waste, the practical
difficulties associated with implementation of such requirements, and
site-specific characteristics . . .," and will comply with the requirements of
Executive Orders 12291 and 12498 and the Regulatory Flexibility Act.
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