vvEPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Resoonse
Washington, DC 20460
EPA/530-SW-88-002
February 1988
Solid Watt*
Report to
Congress
Appendices
Wastes from the Combustion
of Coal by Electric Utility
Power Plants
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i
' UN'TED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
MAR 8
THE ADMINISTRATOR
Honorable George Bush
President of the Senate
Washington, D.C. 20510
Dear Mr. President:
I am pleased to transmit the Report to Congress on
Wastes from the Combustion of Coal by Electric Utility
Power Plants. The report presents the results of
studies carried out pursuant to Section 80O2(n) of
the Resource Conservation and Recovery Act of 1976 as
amended (42 U.S.C. Section 6982(n)).
The report provides a comprehensive assessment of the
management of solid wastes generated by the combustion of
coal from electric utility power plants. These wastes
account for approximately 90 percent of all wastes
generated from the combustion of fossil fuels. The
principal waste categories covered include fly ash,
bottom ash, boiler slag and flue gas emission control
waste.
The report and appendices are transmitted in two
separate volumes.
Sincerely
Lee M. Thomas
Enclosure
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* ^m> i
I J5£ * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\, X^ WASHINGTON. 0 C 20460
t »«o^
MAR 8 1988
THE ADMINISTRATOR
Honorable James C. Wright
Speaker of the House
of Representatives
Washington, D.C. 20515
Dear Mr. Speaker:
I am pleased to transmit the Report to Congress on
Wastes from the Combustion of Coal by Electric Utility
Power Plants. The report presents the results of
studies carried out pursuant to Section 8002(n) of
the Resource Conservation and Recovery Act of 1976 as
amended (42 U.S.C. Section 6982(n)).
The report provides a comprehensive assessment of the
management of solid wastes generated by the combustion of
coal from electric utility power plants. These wastes
account for approximately 90 percent of all wastes
generated from the combustion of fossil fuels. The
principal waste categories covered include fly ash,
bottom ash, boiler slag and flue gas emission control
waste.
The report and appendices are transmitted in two
separate volumes.
Enclosure
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY ES-1
I. INTRODUCTION 1-1
1.1 Legislative History 1-1
1.2 Scope and Sources 1-7
1.3 Organization 1-9
II. OVERVIEW OF THE ELECTRIC UTILITY INDUSTRY 2-1
2.1 The Demand for Electricity 2-1
2.1.1 Structure of the U.S. Electric
Utility Industry 2-7
2.1.2 Economic and Environmental Regulation
of the Electric Utility Industry 2-11
2.2 Importance of Coal to Electric Utilities 2-14
2.3 Overview of Coal-Fired Power Plants 2-18
2.3.1 Regional Characteristics of Coal-Fired
Electric Generating Plants 2-18
2.3.2 Electricity Generating Technologies 2-21
2.4 Coal Constituents and By-Products 2-29
III. WASTES GENERATED FROM COAL-FIRED ELECTRIC UTILITY
POWER PLANTS 3-1
3.1 Overview of Electric Utility Wastes 3-1
3.2 High-Volume Wastes 3-3
3.2.1 Ash 3-3
3.2.2 FGD Sludge 3-21
3.3 Low-Volume Wastes 3-41
3.3.1 Boiler Slowdown 3-43
3.3.2 Coal Pile Runoff 3-45
3.3.3 Cooling Tower Slowdown 3-47
3.3.4 Demineralizer Regenerant and Rinses 3-50
3.3.5 Metal and Boiler Cleaning Wastes 3-52
3.3.6 Pyrites 3-57
3.3.7 Sump Effluents 3-60
3.4 Summary 3-62
IV. COAL COMBUSTION WASTE MANAGEMENT PRACTICES 4-1
4.1 State Regulation of Coal Combustion
Waste Disposal 4-1
4.1.1 State Classification of Coal Combustion
Wastes 4-2
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TABLE OF CONTENTS (cont'd)
Page
4.1.2 Requirements for Coal Combustion Waste
Disposal 4-6
4.1.3 Summary 4-9
4.2 Available Waste Management Methods and
Current Practices 4-10
4.2.1 Land Management of Coal Combustion Wastes 4-10
4.2.2 Alternative Waste Management Technologies 4-24
4.2.3 Ocean Disposal 4-44
4.2.4 Waste Utilization and Recovery of
Various Waste By-Products 4-45
4.3 Summary 4-53
V. POTENTIAL DANGERS TO HUMAN HEALTH AND THE ENVIRONMENT 5-1
5.1 RCRA Subtitle C Hazardous Waste Characteristics
and Listing Criteria 5-2
5.1.1 Corrosivity of Coal Combustion Wastes 5-4
5.1.2 Extraction Procedure Toxicity of Coal
Combustion Wastes 5-5
5.2 Effectiveness of Waste Containment at Utility
Disposal Sites 5-28
5.2.1 ADL Study of Waste Disposal at
Coal-Fired Power Plants 5-29
5.2.2 Franklin Associates Survey of State
Ground-Water Data 5-44
5.2.3 Envirosphere Ground-Water Survey 5-48
5.2.4 Summary 5-52
5.3 Evidence of Damage 5-53
5.3.1 Envirosphere Case Study Analysis 5-54
5.3.2 Dames & Moore Study of Environmental
Impacts 5-56
5.3.3 Case Studies of the Environmental
Impact of Coal Combustion By-Product
Waste Disposal 5-63
5.3.4 Summary 5-67
5.4 Factors Affecting Exposure and Risk at
Coal Combustion Waste Sites 5-68
5.4.1 Environmental Characteristics of
Coal Combustion Waste Sites 5-69
5.4.2 Population Characteristics of Coal
Combustion Waste Disposal Sites 5-83
5.4.3 Ecologic Characteristics of Coal
Combustion Waste Disposal Sites 5-89
5.4.4 Multivariate Analysis 5-93
5.5 Summary 5-95
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TABLE OF CONTENTS (cemt'd)
Page
VI. ECONOMIC COSTS AND IMPACTS 6-1
6.1 Waste Disposal Costs Associated With
Current Disposal Methods 6-2
6.1.1 Costs of Waste Placement and
Disposal 6-5
6.1.2 Costs Associated with Lined
Disposal Facilities 6-11
6.2 Costs of Alternative Disposal Options 6-12
6.2.1 Regulatory Alternatives Under
Subtitle C 6-13
6.2.2 Cost Estimates for Individual RCRA
Subtitle C Disposal Standards 6-17
6.2.3 Potential Costs to the Industry of RCRA
Subtitle C Waste Management 6-30
6.3 Impact of Regulatory Alternatives on
Utilization of Coal Combustion Wastes 6-33
6.4 Economic Impacts of Alternative Waste
Disposal Options 6-37
6.5 Summary 6-43
VII. CONCLUSIONS AND RECOMMENDATIONS 7-1
7.1 Scope of Report 7-1
7.2 Summary of Report 7-2
7.2.1 Location and Characteristics of Coal-
Fired Power Plants 7-2
7.2.2 Waste Quantities and Characteristics 7-3
7.2.3 Waste Management Practices 7-5
7.2.4 Potential Hazardous Characteristics . 7-6
7.2.5 Evidence of Environmental Transport
of Potentially Hazardous Constituents 7-7
7.2.6 Evidence of Damage 7-9
7.2.7 Potential Costs of Regulation 7-9
7.3 Recommendations 7-11
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TABLE OF CONTENTS (cont'd)
Page
Bibliography
Glossary
Appendix A:
Appendix B:
Appendix C:
Appendix D:
Letter from Gary N. Dietrich, EPA, to Paul Emler, Jr.,
USWAG, January 13, 1981 and Memorandum from EPA
Headquarters to EPA Regional Directors, February
18, 1981
Methodology For Estimating Volume of Ash and FGD
Sludge Generation
Regulation of Coal Combustion Waste Disposal In
Seventeen High Coal-Burning States
Waste Fluid Studies
A-l
B-l
C-l
D-l
Appendix E: Arthur D. Little Study of Waste Disposal At Coal-Fired
Power Plants E-l
Appendix F: Data On Sample of Coal-Fired Combustion Waste Disposal
Sites F-l
Appendix G: Methodology For Calculating The Cost of Alternative
Waste Management Practices G-l
2923C
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INDEX OF EXHIBITS
Page
CHAPTER TWO
2-1 Growth in Electricity Demand - 1975-2000 2-2
2-2 Electricity Sales By Year and Class of Service 2-4
2-3 Electricity Demand by EPA Region: 1985 2-5
2-4 EPA Federal Regions 2-6
2-5 Generating Capacity in the United States 2-8
2-6 Electricity Generation by Primary Energy
Source: 1975-2000 2-15
2-7 Electric Utility Dependence on Coal by EPA Region: 1985 2-17
2-8 U.S. Coal Consumption by Sector: 1975-2000 2-19
2-9 Total Number and Average Size of Coal-Fired
Plants and Units 2-20
2-10 Range of Coal-Fired Power Plant Sizes 2-22
2-11 Process For Generating Electricity at Coal-Fired
Power Plants 2-23
2-12 Diagram of a Pulverized Coal Boiler 2-25
2-13 Diagram of a Cyclone Boiler 2-27
2-14 Characteristics of Various Types of Stokers 2-30
2-15 Diagram of a Spreader Stoker 2-31
2-16 Total Coal Boiler Capacity by EPA Region 2-32
2-17 Average Coal Boiler Size By Type of Boiler
and By EPA Region 2-33
2-18 Electric Utility Production of FGD Wastes: 1985 2-36
CHAPTER THREE
3-1 Representative Ash Contents By Producing
Region and Coal Rank: 1985 3-9
3-2 Volume of Ash Generated by Coal-Fired Electric
Utility Power Plants -- 1975-2000 3-10
3-3 Average Ash Content of Coal Burned by Electric
Utility Power Plants in the U.S. -- 1975-2000 3-12
3-4 Representative Ranges of Values For the Physical
Characteristics of Fly Ash, Bottom Ash,
and Boiler Slag 3-14
3-5 Low and High Concentrations of Major Chemical
Constituents Found in Ash Generated by
Coal-Fired Power Plants 3-16
3-6 Element Concentrations In Ash From Three
Geographic Sources 3-18
3-7 Effect Of Geographic Coal Source On Ash
Element Concentration 3-19
3-8 Element Concentrations In Three Types Of Ash 3-20
3-9 Major Types of Flue Gas Desulfurization Systems 3-23
3-10 Flow Diagram of Wet Flue Gas Desulfurization System 3-25
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INDEX OF EXHIBITS
Page
CHAPTER THREE (Continued)
3-11 Flow Diagram of Spray-Drying Flue Gas Desulfurization
System 3-27
3-12 Flow Diagram of Dry Injection Flue Gas Desulfurization
System 3-28
3-13 Flow Diagrams of Recovery Flue Gas Desulfurization Systems 3-30
3-14 FGD Capacity and FGD Sludge Generation -- 1970-2000 3-32
3-15 Representative Ranges of Values for the Physical
Characteristics of FGD Sludge 3-36
3-16 Concentration of Major Chemical Constituents of Wet FGD
Sludge Solids by Scrubber System and Source of Coal 3-39
3-17 Concentration of Major Chemical Constituents of Wet FGD
Sludge Liquors by Scrubber System and Source of Coal 3-40
3-18 Concentration of Trace Elements Found in Wet-FGD Sludges 3-42
3-19 Annual Low-Volume Waste Generation At a Representative
Coal-Fired Power Plant 3-44
3-20 Characteristics of Boiler Slowdown 3-46
3-21 Characteristics of Coal Pile Runoff 3-48
3-22 Characteristics of Cooling Tower Slowdown 3-51
3-23 Characteristics of Spent Demineralizer
Regenerants 3-53
3-24 Reported Characteristics of Gas-Side Cleaning Wastes 3-55
3-25 Characteristics of Spent Water-Side Alkaline
Cleaning Wastes 3-56
3-26 Characteristics of Spent Water-Side Hydrochloric Acid
Cleaning Wastes 3-58
3-27 Characteristics of Spent Water-Side Alkaline Passivating
Wastes 3-59
3-28 Characteristics of Pyrites and Pyrite Transport Water 3-61
CHAPTER FOUR
4-1 State Regulations Governing Coal Combustion Waste Disposal 4-3
4-2 Typical Surface Impoundment (Pond) Stages 4-12
4-3 Diagrams of Active and Closed Landfills 4-15
4-4 Utility Waste Management Facilities By EPA Region 4-19
4-5 Location of Utility Waste Management Facilities:
On-site versus Off-site 4-21
4-6 Installation of Liners For Leachate Control at Utility
Waste Management Facilities 4-31
4-7 Summary of Current Handling, Treatment and Disposal
of Low-Volume Wastes 4-39
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INDEX OF EXHIBITS
Page
CHAPTER FIVE
5-1 Maximum Concentration of Contaminants For Characteristic
of EP Toxicity 5-6
5-2 Effect of Geographic Coal Source On Element
Concentration In Ash . 5-10
5-3 Results of Tetra Tech Extraction Tests On Coal Combustion Ash .. 5-12
5-4 Results of Arthur D. Little Testing Showing
The Range of Concentration of Metals In
EP Extracts 5-17
5-5 EP Toxicity Analysis For Untreated and Treated Boiler
Chemical Cleaning Wastes 5-21
5-6 EP Toxicity Test Results For Liquid Low-Volume Wastes 5-23
5-7 Comparison of EP and TCLP Extractions For Low-Volume Sludge
Dredged From Wastewater Ponds 5-24
5-8 EP Toxicity Test Results of Low-Volume Wastes Before
and After Co-Disposal 5-26
5-9 Primary And Secondary Drinking Water Standards 5-30
5-10 Summary of Arthur D. Little's Ground-Water Quality
Data On Primary Drinking Water Exceedances 5-35
5-11 Summary of Arthur D. Little's Ground-Water
Quality Data on Secondary Drinking Water
Exceedances 5-37
5-12 Summary of Arthur D. Little's Surface-Water
Quality Data On Primary Drinking Water Exceedances 5-40
5-13 Summary of PDWS Exceedances in the Franklin
Associates Survey 5-46
5-14 Summary of SDWS Exceedances in the Franklin
Associates Survey 5-47
5-15 Summary of PDWS Exceedances in Envirosphere's
Ground-water Data 5-50
5-16 Summary of SDWS Exceedances in Envirosphere's
Ground-water Data 5-51
5-17 Distance Of Coal Combustion Waste Sites To Surface Water 5-72
5-18 Flow Of Nearest Surface-Water Body 5-74
5-19 Depth To Ground Water at Coal Combustion Waste Sites 5-77
5-20 Hydraulic Conductivity at Coal Combustion Waste Sites 5-78
5-21 Net Recharge at Coal Combustion Waste Sites 5-81
5-22 Ground-Water Hardness at Coal Combustion Waste Sites 5-82
5-23 Populations Within One Kilometer of Waste Sites 5-85
5-24 Populations Within Three Kilometers of Waste Sites 5-86
5-25 Populations Within Five Kilometers of Waste Sites 5-87
5-26 Populations Served By Public Water Systems Near Waste Sites .... 5-89
5-27 Ecological Status of Waste Sites 5-92
CHAPTER SIX
6-1 Overview of Waste Handling and Disposal Options
for Coal Ash 6-3
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INDEX OF EXHIBITS
Page
CHAPTER SIX (Continued)
6-2 Overview of Waste Handling and Disposal Options
for FGD Waste 6-4
6-3 Ranges of Average Capital Costs Associated With
Coal-Fired Electric Utility Waste Disposal 6-6
6-4 Ranges of Average Total Costs For Coal-Fired
Electric Utility Waste Disposal 6-7
6-5 Summary of Costs to Close Existing Waste Disposal
Facilities 6-23
6-6 Summary of Costs For Different Types of Lined
Waste Management Facilities 6-28
6-7 Costs to the Electric Utility Industry For Hypothetical
RCRA Compliance Strategies 6-29
6-8 Summary of Economic Impacts on By-Product Utilization
Under Different RCRA Regulatory Scenarios 6-36
6-9 Impact of Current Waste Disposal Costs on Total
Electricity Generation Costs 6-39
6-10 Impact of Alternative Disposal Options on Electricity
Generation Costs 6-40
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
JAN 131981
OFFICE OF WATER
AND WASTE MANAGEMENT
Mr. Paul Emler, Jr.
Chairman
Utility Solid Waste Activities
Group
Suite 700
1111 Nineteenth Street, N.W.
Washington, D.C. 20036
Dear Mr. Emler:
This is a response to your letter of October 10, 1980 to
Administrator Costle, regarding the recent Solid Waste Disposal
Act Amendments of 1980 and their relation to the electric utility
industry. In your letter and its accompanying document, you
discussed the specific amendments which address fossil fuel
combustion wastes, and suggested interpretive language which
EPA should adopt in carrying out the mandate of the amendments.
You requested a meeting with our staff to make us more fully
aware of the solid waste management practices of the electric
utility industry, and to discuss the effect of the amendments on
the .utility solid waste study which EPA is currently conducting.
I appreciated the opportunity to meet with you, in your
capacity as chairman of the Utility Solid Waste Activities
Group (USWAG), on November 21 to discuss your concerns. I
am taking this occasion to share with you the most recent EPA
thinking on the exclusion from our hazardous waste management
regulations of waste generated by the combustion of fossil
fuels, and to confirm certain agreements which were reached
during our meeting. The language contained in this letter
should provide you and your constituents with an adequate
interpretation of the fossil fuel combustion waste exclusion
in Section 261.4(b)(4) of our regulations. This letter is
also being circulated to appropriate Agency personnel, such
as our Regional Directors of Enforcement, for their information
and use. We intend to issue in the Federal Register an official '
Regulations Interpretation Memorandum reflecting the policies
articulated in this letter.
In our May 19, 1980 hazardous waste management regulations,
we published an exclusion from Subtitle C regulation for those
fossil fuel combustion wastes which were the subject of then
pending Congressional amendments. The language of that exclusion
in §261.4(b) (4). of our May 19 regulations is identical to per-
tinent language of Section 7 of the Solid Waste Disposal Act
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regulations. We clearly explained in the preamble to Part
261 of our May 19 regulations that we fully intend to even-
tually regulate the use and recycling of hazardous wastes and,
in doing so, would probably, in most cases, develop special
requirements that provide adequate protection of human health
and the environment without unwarranted discouragement of
resource conservation. Consequently, although the burning of
hazardous waste as a fuel (a beneficial use assuming that the
waste has a positive fuel value) is not now subject to our
regulations (except as noted above) it may well be subject to
our regulation in the future.
Our second concern with combustion of fuel mixtures is the
one at focus in this interpretation. It must first be noted
that we do not intend for §261.6 to provide an exemption from
regulation for combustion wastes resulting from the burning of
hazardous wastes in combination with fossil fuels; it only
provides an exemption for the actual burning of hazardous wastes
for recovery of fuel value. Thus, if these combustion wastes
are exempted from our regulation, such exemption must be
found through interpretation of §261.4(b)(4). Secondly, we
note that although the pertinent language in Section 7 of the
Solid Waste Disposal Act Amendments of 1980 and the related
legislative history on this matter speak of allowing the burning
of alternative fuel without precisely defining or delineating
the types of alternative fuel, the only examples of alternative
fuels used in the legislative history are refuse derived fuels.
Therefore, a literal reading of the legislative history might
enable us to interpret the exclusion to include combustion
wastes resulting from the burning of fossil fuels and other
fuels, including hazardous wastes. However, since each of these
legislative comments was made in the context of refuse derived
fuels or other non-hazardous alternate fuels, we do not believe
the Congressional intent compels us to make such an interpretation
if we have reason to believe that such combustion wastes are
hazardous.
Presently, we have little data on whether or to what extent
combustion wastes are "contaminated" by the burning of fossil
fuel/hazardous waste mixtures. The data we do have (e.g., burning
of waste oils) suggests that the hazardous waste could contribute
toxic heavy metal contaminants to such combustion wastes. When
coal is the primary fuel, the amount of resulting contamination
is probably in amounts that are not significantly different than
the metals that would be contributed by the fossil fuel component
of the fuel mixture. This may not be the case with oil and gas,
where huge volumes of waste are not available to provide a dilution
effect. We suspect that the other hazardous constituents of the
hazardous wastes that typically would be burned as a fuel are
either thermally destroyed or are emitted in the flue gas (and
therefore are part of our first concern as discussed above). If
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these data and this presumption are true, then combustion wast3s
resulting f~om the burning of coal/hazardous waste mixtures should
not be significantly different in composition than combustion wastes
generated by the burning of coal alone. Because the Congress has
seen fit to exclude the latter wastes from Subtitle C, pending more
study, we feel compelled to provide the same exclusion to the
former wastes.
Accordingly, we will interpret the exclusion of §261.4(b)(4)
to include fly ash, bottom ash, boiler slag and flue gas emission
control wastes generated in the combustion of coal/hazardous
waste mixtures provided that coal makes up more than 50 percent
of the fuel mixture.
We offer this interpretation with great reluctance and
with the clear understanding it is subject to change, if and
when data indicate that combustion wastes are significantly
contaminated by the burning of hazardous wastes as fuel. Ue
also offer this interpretation with the understanding, as dis-
cussed at our meeting of November 21, that the utility industry
will work with us over the next several months to improve our
data on this matter. We believe it is essential that we make
a Jiore informed judgement and possible reconsideration of our
interpretation of the exclusion as soon as possible and before
co^ple-i°n °f our longer-term study of utility waste which is
proceeding. Accordingly, we woul-1 like you to provide to us
all available data on the following questions by August 1, 1981:
1. What types of hazardous wastes are commonly burned as
fuels in utility boilers? In what quantity? In what
ratio to fossil fuels? How often? What is their BTU
content?
2. Does the burning of these wastes contribute hazardous
constituents (see Appendix VIII of Part 261 of our
regulations) to any of the combustion wastes? If so,
what constituents, and in what amounts? How does the
composition of combustion wastes change when hazardous
wastes are burned?
Co-disposal and Co-treatment
The second issue raised in your letter was whether the
exclusion extends to wastes produced in conjunction with the
burning of fossil fuels which are co-disposed or co-treated
with fly ash, bottom ash, boiler slag and flue gas emission
control wastes. As examples of such wastes, you specifically
mention boiler cleaning solutions, boiler blowdown, demineralizer
regenerant, pyrites, cooling tower blowdown, or any "wastes of
power plant origin whose co-treatment with fly ash, bottom
ash, slag and flue gas emission control sludges is regulated
under State-or-EPA-sanctioned management or treatment plans."
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The legislative history on this matter clearly indicates
that the Congress intended that these other wastes be exempted
from Subtitle C regulation provided that they are mixed with
and co-disposed or co-treated with the combustion wastes and
further provided that "there is no evidence of any substantial
environmental danger from these mixtures." (See Congressional
Record, February 20, 1980, p. H 1102, remarks of Congressman
Bevill; also see remarks of Congressman Rahall, Congressional
Record, February 20, 1980, p. H1104.)
We have very little data on the composition, character
and quantity of these other associated wastes (those cited above),
but the data we do have suggest that they are generated in
small quantities relative to combustion wastes, at least when
coal is the fuel, and that they primarily contain the sane
heavy :netal contaminants as the combustion wastes, although
they nay have a signficantly different pH than the combustion
wastes. These limited data therefore suggest that, when thsse
other wastes are nixed with and co-disposed or co-treated with
the much larger quantities of combustion wastes, their composition
and character are "masked" by the composition and character of
the conbustion wastes; that is, they do not significantly
alter the hazardous character, if any, of the combustion wastes.
Given this information base and given the absence of
definitive information indicating that these other wastes do
pose a "substantial danger" to human health or the environment,
we believe it is appropriate, in the light of Congressional
intent, to interpret the §261.4(b)(4) exclusion to include
other wastes that are generated in conjunction with the burning
of fossil fuels and mixed with and co-disposed or co-treated
with fly ash, bottom ash, boiler slag and flue gas emission
control wastes.
v;e offer this interpretation with some reluctance because
it is made in the absence of definitive information about the
hazardous properties of these other wastes or their mixtures
with combustion wastes. We therefore believe it is imperative
that we proceed to collect all available data on this matter
within the next several months and reconsider this interpre-
tation when these data are assessed. Toward that end and
consistent with the discussion at our meeting of November 21,
we are asking that you assist us in collecting these data.
Specifically, we ask that you collect and submit by August 1,
1981, any available data on the following questions:
1. What are the "other" wastes which are commonly mixed
with and co-disposed or co-treated with fly ash,
bottom ash, boiler slag or flue gas emission control
wastes? What are their physical (e.g., sludge or
liquid) and chemical properties? Are they hazardous
wastes in accordance with Part 261?
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2. What are the co-disposal or co-treatment methods
employed?
3. How often are these wastes generated? In what
quantities are they generated? Are they commonly
treated in any way before being co-disposed?
4. Does the industry possess any data on the environ-
mental effects of co-disposing of these wastes?
Groundwater monitoring data? What are the results?
The interpretation on other associated wastes provided in
this letter is limited to wastes that are generated in conjunction
with the burning of fossil fuels. Ke do not intend to exempt
hazardous wastes that are generated by activities that are not
directly associated with fossil fuel combustion, steam genera-
tion or water cooling processes. Thus, for example, the
§261.4(b)(4) exclusion does not cover pesticides or herbicide
wastes; spent solvents, waste oils or other wastes that might
be generated in construction or maintenance activities typically
carried out at utility and industrial plants; or any of the
commercial chemicals listed in §261.33 which are discarded or
intended to be discarded and therefore are hazardous wastes.
Further, the exclusion does not cover any of the hazardous
wastes listed in §§261.31 or 261.32 of our regulations. None
of these listed wastes were mentioned in your letter or our
discussions.
The interpretation on other wastes is also limited to
wastes that traditionally have been and which actually are
mixed with and co-disposed or co-treated with combustion wastes.
If any of these other wastes (e.g., boiler cleaning solutions,
boiler blowdown, demineralizer regenerant, pyrites and cooling
tower blowdown) are segregated and disposed of or treated
separately from combustion wastes and they are hazardous wastes,
they are not covered by the exclusion. In the same vein, the
exclusion does not cover other wastes where there are no
combustion wastes (or relatively small amounts of combustion
wastes) with which they might be mixed and co-disposed or
co-treateda situation which might prevail where natural gas
or oil is the principal fossil fuel being used. Therefore,
this interpretation of the exclusion applies only where coal
is the primary fuel. We feel this is a legitimate interpretation
of Congressional intent, wherein the argument of little potential
environmental hazard, primarily due to the dilution factor,
is clearly based upon co-disposal or co-treatment with the
huge volumes of wastes generated during coal combustion.
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EPA Utility Waste Study
The groups of questions raised above bring us to the final
subject which you address concerning the study cf utility solid
waste management which EPA is conducting. We agree that the
study, as currently being conducted, does not focus on the
matters discussed in this letter. We would, however, like
to address these matters and include them in our report to
Congress, to the extent possible. To accomplish this, we plan
to meet in the very near future with cur contractor, Arthur D.
Little, Inc., to discuss what studies may need to be carried
out in addition to their currently planned activities under
the contract. The inputs of your organization could be quite
useful in this effort. It may be impossible, however, to
modify our present study to include a detailed investigation
of all of the issues discussed above.
Notwithstanding, we would like to address the matters
discussed in this letter within a shorter time frameduring
the next six months. Based on our neeting of November 21,
it is my understanding that the utility industry, working
closely with EPA, is willing to develop data on the questions
put forth above. We agreed that, as a first step, USWAG will
prepare a study outline designed to obtain these data. EPA
staff and industry representatives designated by your organiza-
tion will then mutually review the information needs. The
data collection effort will then follow. Finally, data and
analyses will oe presented to EPA for review. This will enable
us to reconsider the interpretation provided in this letter
and nake any changes deemed necessary. Therefore, I would
appreciate it if you would designate a technical representative
as USWAG's contact person for this coordinated data collection
effort.
In the meantime, and pending completion of this effort,
EPA will interpret 40 CFR §261.4(b)(4) to mean that the following
solid wastes are not hazardous wastes:
(a) Fly ash, bottom ash, boiler slag and flue gas
emission control wastes resulting from (1) the
combustion solely of coal, oil, or natural gas,
(2) the combustion of any mixture of these
fossil fuels, or (3) the combustion of any
mixture of coal and other fuels, up to a 50
percent mixture of such other fuels.
(b) Wastes produced in conjunction with the combus-
tion of fossil fuels, which are necessarily
associated with the production of energy, and
which traditionally have been, and which actually
are, mixed with and co-disposed or co-treated
with fly ash, bottom ash, boiler slag, or flue
gas emission control wastes from coal combustion.
-------
-8-
This provision includes, but is not limited to,
the following wastes:
(1) boiler cleaning solutions,
(2) boiler blowdown,
(3) denineralizer regenerant,
(4) pyrites, and
(5) cooling tower biowdown.
*
I an*, hopeful that our future rasearch activities together
will prove fruitful and that these issues can be rapidly resolved.
I have designated v.s. Penelope Hansen of nuy staff as the ErA
p^int of contact: for this effort. You r.ay reach her at (202.)
755-9206.
Sincerely yours,
Gary N. Dietrich
Associate "eputy Assistant i.iT.ir.istratoc
for Solid "iaste
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D.C 20460
DATE:
SUBJECT: EPA Regulation of Utility Waste
FROM: Steffen W. Plehn, Deputy Assistan
Administrator for Solid Waste (WH
R. Sarah Compton, Deputy Assistant
Administrator for Water Enforceme
TO: Regional Directors
Air and Hazardous Materials Division
Enforcement Division
Surveillance and Analysis Division
Offices of Regional Counsel (see list)
Director, National Enforcement Investigations Center
Attached is a copy of a letter which provides interpretation
of EPA's regulation of solid wastes from fossil fuel combustion.
This letter, addressed to Mr. Paul Emler of the Utility Solid
Waste Activities Group on January 13, 1981, interprets the
language contained in §261.4(b)(4) of the May 19, 1980 regulations
for Hazardous Waste Management, implementing Subtitle C of the
Resource Conservation and Recovery Act of 1976 (RCRA).
In those regulations, we published an exclusion from Subtitle C
regulation for those fossil fuel combustion wastes which were the
subject of then pending Congressional amendments. The language
of the exclusion in §261.4(b)(4) is identical to pertinent language
of Section 7 of the Solid Waste Disposal Act Amendments of 1980
(P.L. 96-482) which was enacted on October 21, 1980 and which
mandates that exclusion. Specifically the exclusion language of
our regulations provides that the following solid wastes are not
hazardous wastes:
"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."
In the January 13 letter, EPA interpreted this exclusion lan-
guage to mean that the following solid wastes are not hazardous
wastes:
-------
- 2 -
(a) Fly ash, bottom ash, boiler slag and flue gas
emission control wastes resulting from (1) the
combustion solely of coal, oil, or natural gas,
(2) the combustion of any mixture of these
fossil fuels, or (3) the combustion of any
mixture of coal and other fuels, up to a 50
percent mixture of such other fuels.
(b) Wastes produced in conjunction with the combus-
tion of fossil fuels, which are necessarily
associated with the production of energy, and
which traditionally have been, and which actually
are, mixed with and co-disposed or co-treated
with fly ash, bottom ash, boiler slag, or flue
gas emission control wastes from coal combustion.
This provision includes, but is not limited to, the
following wastes:
(1) boiler cleaning solutions,
(2) boiler blowdown,
(3) demineralizer regenerant,
(4) pyrites, and
(5) cooling tower blowdown.
This exclusion from hazardous waste regulation applies only
until such time as EPA studies the environmental effects of
disposal of these wastes and makes a determination as to how they
should be managed. The utility industry will be assisting EPA
in the collection of such information. In the meantime, utility
waste is regulated as a solid waste, subject to RCRA Subtitle D
criteria.
After receipt of information from the utility industry,
our current interpretation of the fossil fuel combustion waste
deferral may be revised. In the meantime, however, the guidance
provided to Mr. Emler represents EPA's position on this issue.
I urge each of you to study carefully the details of and ration-
ale behind the guidance, and make the appropriate persons on
your staff aware of it. If you have any questions on this issue
or on the letter itself, please contact John Heffelfinger,
in the Office of Solid Waste, at (202) 755-9206.
Attachment
-------
Pamela A. Hill
Office of Regional Counsel
U.S. EPA - Region I
, John F. Kennedy Federal Building
Boston, Mass. 02203
David Stone
Office of Regional Counsel
U.S. EPA - Region II
26 Federal Plaza
New York, New York 10007
Lawrence Bass
Office of Regional Counsel
U.S. EPA - Region III
Curtis Building
6th & Walnut Streets
Philadelphia, Pa. 19106
Gloria Ellis
Office of Regional Counsel
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308-
Mary C. Bryant
Office of Regional Counsel
U.S. EPA - Region V
230 South Dearborn Street
Chicago, Illinois 60604
Barbara Greenfield
Harless Benthal
Office of Regional Counsel
U.S. EPA - Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
jane Werholz
Office of Regional Counsel
U.S. EPA - Region VII
1735 Baltimore Street
Kansas City, Miss. 64108
Wilkes McClave, III
Office of Regional Counsel
U.S. EPA - Region VIII
1860 Lincoln Street
Denver, Colorado 80203
David Stromberg
Office of Regional Counsel
U.S. EPA - Region IX
215 Fremont Street
San Francisco, Calif. 94105
Cheryl Kashuta
Office of Regional Counsel
U.S. EPA - Region X
1200 6th Avenue
Seattle, Washington 98101
-------
METHODOLOGY FOR ESTIMATING VOLUME OF
ASH AND FGD SLUDGE GENERATION
The estimates of future ash and FGD sludge generation presented in Chapter
Three were derived based on assumptions regarding future coal consumption, the
amount of coal-fired capacity, the types of boilers in service, and
environmental regulations. Estimates were derived for 1985, 1990, 1995, and
2000. This appendix explains the key assumptions and methodology used to
develop the estimates of future ash and FGD sludge generation. The major
source used to develop these estimates was Analysis of 6 and 8 Million Ton and
30 vear/NSPS and 30 Year/I.2 Ib Sulfur Dioxide Emission Reduction Cases
(prepared by ICF Incorporated for EPA, February 1986).^
B.I ASH
The first step in developing estimates of the volume of ash generated by
coal-fired utilities was to determine for each coal-producing region in the
U.S. (see Exhibit B-l) an average ash content of coal (on an as-shipped basis),
specified by rank, heat content, and volatility level. These average ash
contents are shown in Exhibit fi-2. Next, these average values were multiplied
by the quantity of coal expected to be shipped from each coal-producing region,
using the following formula:
Ash Content of Coal (%) x Amount of Coal (Million Tons)
- Amount of Ash (Million Tons)
-------
B-2
EXHIBIT B-l
GOAL-PRODUCING REGIONS OF THE UNITED STATES
Northwest Westtrn Northern
Great Plains Eastern Northern
u Plains Central Midwest
Rockies
3 :3fl 130 )00
SCALE Q4MIUS
Shaded areas not incorporated
into coal supply regions
Northern AppalachU
Pennsylvania. Central (PC)
Pennsylvania. West (PW)
Ohio (OH)
Maryland (MD)
West Virginia. North (WN)
Central Appalachia
West Virginia. South (WS)
Virginia (VA)
Kentucky. East (KE)
Tennessee (TN)
Southern Appalachia
Alabama (AL)
Midwest
Illinois (IL)
Indiana (IN)
Kentucky. West (KW)
Central West
Iowa (IA)
Missouri (MO)
Kansas (KS)
Arkansas. North (AN)
Oklahoma (OK)
Guir
Texas (TX)
Louisiana (LA)
Arkansas South/Mississippi (AS)
Eastern Northern Great Plains
North Dakota (NO)
Montana. East (ME)
Western Northern Great Plains
Montana. Powder River (MP)
Montana. West (MW)
Wyoming. Powder River (WP)
Rockies
Wyoming, Green River (WO)
Colorado. Green River (CG)
Colorado. Denver (CD)
Colorado. Raton (CR)
Colorado. Uinta (CU)
Colorado. San Juan (CS)
Utah. Central (UC)
Utah. South (US)
New Mexico. Raton (NR)
Southwest
New Mexico. San Juan (NS)
Arizona (AZ)
Northwest
Washington (WA)
Alaska
Alaska (AK)
Imports
Imports (IM)
-------
B-3
EXHIBIT B-2
AVERAGE ASH CONTEST OF COAL
(percent)
B i tmminous
Hieh Volatility I/
Coal -Producing Region
Central Pennsylvania
Western Pennsylvania
Ohio
Maryland
Northern West Virginia
Southern West Virginia
Virginia
Eastern Kentucky
Tennessee
Alabama
Illinois
Indiana
Western Kentucky
Iowa
Missouri
Kansas
Northern Arkansas
Oklahoma
Texas
Louisiana
Southern Arkansas
North Dakota
Eastern Montana
Montana, Powder River
Western Montana
Wyoming, Powder River
Wyoming, Green River
Low and
Medium \J
Volatility
12.0
7.0
12.0
7.0
12.0
12.0
12.6
12.0
12.4
10,500- 11,500-
11,500 14,000
Btu/lb Btu/lb
12.0 12.0
12.0
12.0
12.0
12.0
12.0
12.0
12.0
12.6
10.3
10.4
12.0
10.0 10.0
12.0
14.0
12.4 12.4
13.0 13.0
10.0 10.0
Over
14,000
Btu/lb
12.0
12.0
12.0
12.0
12.0
12.0
12.0
12.0
12.6
10.3
12.0
12.7
Subbituminous Lignite
6.9
6.9
6.0
10.0
15.3
12.0
14.0
9.1
8.0
-------
B-4
EXHIBIT B-2
AVERAGE ASH CONTENT OF COAL
(percent:)
Bituminous*
Subbituminous Lignite
Coal-Producing Region
Colorado, Green River
Colorado, Denver
Colorado, Raton
Colorado, Uinta
Colorado, San Juan
Central Utah
Southern Utah
New Mexico, Raton
New Mexico, San Juan
Arizona
Washington
Alaska
Low and
Medium I/
Volatility
8.0
High Volatility I/
10,500-
11,500
Btu/lb
10.0
12.0
18.3
11,500-
14,000
Btu/lb
10.0
10.0
8.0
10.0
8.0
9
13,
10.0
Over
14,000
Btu/lb
10.0
8.0
10.0
8.0
13.1
18.0
18.3
16.0
9.0
18.0
I/ Volatility Content, as measured on a dry, mineral-matter-free basis.
Low : 14.0-21.9 percent volatile matter
Medium : 22.0-30.9 percent volatile matter
High : Over 31.0 percent volatile matter
Source: See Attachment B-l for the major assumptions used to develop these average
ash contents. These assumptions were used in the analysis summarized in
Analysis of 6 and 8 Million Ton and 30 Year/NSPS and 30 Year/I.2 Ib. Sulfur
Dioxide Effljg?jon Reduction Cases, prepared by ICF Incorporated for the
Environmental Protection Agency, February 1986.
-------
B-5
The results represent the quantities of ash received by electric utility power
plants throughout the United States. It was assumed that the total quantity
of ash received by utilities would not burn; therefore, the amount of ash
generated is equal to the amount received. Exhibit B-3 presents estimates by
state of the total amount of ash that will be generated by electric utilities
between 1985 and 2000 and the average ash content of the total quantity of
coal received by the utilities in each state.
To determine quantities of each type of ash that would be generated, the
amount of ash produced by each type of electric utility boiler was calculated.
This was determined by apportioning the total quantity of ash generated
according to the capacity of each boiler type (as a fraction of total capacity
of coal-fired utilities in the U.S.). In Exhibit B-4 total electric utility
capacity is described by boiler type. The majority of future coal-fired power
plants are expected to use dry-bottom pulverizers, which can burn a greater
variety of coals than other boilers. Therefore, it is assumed that the
capacity assigned to the "unknown" category in Exhibit B-4 is additional
dry-bottom pulverizer capacity.
Once the amount of ash generated by each type of boiler was determined, the
quantities of the different types of ash formed could be estimated. Each
major boiler type (dry-bottom pulverizers, wet-bottom pulverizers, cyclones,
and stokers) produces different proportions of fly ash, bottom ash, or boiler
slag, depending on the design of the boiler and operating conditions. The
percentage of ash generated as fly ash, bottom ash, and boiler slag by each
type of boiler is presented in Exhibit B-5. These percentages were used to
determine the amount of each ash type generated by the four types of boilers,
-------
B-6
EXHIBIT B~3
AWil^BlU A
State
Maine/Vermont/New Hampshire
1985
mill on
Tons
0.2
Ma»sacbu»«tts/Connecticut/Rhode Island 0.5
New York
Pennsylvania
New Jersey
Maryland/Delaware/District of
Virginia
West Virginia
North Carolina/South Carolina
Georgia
Florida
Ohio
Michigan
Illinois
Indiana
Wisconsin
Kentucky
Tennessee
Alabama
Mississippi
Minnesota
North Dakota/South Dakota
Iowa
Missouri
Kans as /Nebraska
Arkansas
Oklahoma
Louisiana
Texas
Montana
Wyoming
Colorado
New Mexico
Utah
Arizona
Nevada
Washington/Oregon
California
Total U.S.c/
a/ For each year, the numbers
electric utility power plants
0.8
5.0
0.4
Columbia 1.0
0.9
3.2
3.9
3.0
2.0
6.0
3.2
3.1
4.1
1.4
2.6
3.4
1.6
0.5
0.8
1.8
1.3
2.7
1.5
0.8
0.9
0.6
8.2
0.4
1.5
1.3
2.8
0.5
1.7
0.8
0.8
w«nn».
1
12.0
12.0
11.2
12.4
12.0
9.7
12.0
11.2
12.0
11.6
11.8
11.8
10.6
9.0
9.8
8.2
12.0
11.6
12.6
10.7
7.0
9.1
7.4
10.3
7.1
6.0
6.0
6.0
12.5
6.9
7.8
8.3
18.1
8.3
12.6
9.7
13.9
!» " * "-'
niu
_Is
0.
0.
0.
5.
0.
0.
1.
3.
3.
3.
2.
6.
3.
2.
4.
1.
3.
3.
1.
0.
0.
2.
1.
2.
1.
0.
1.
1.
10.
0.
1.
1.
2.
0.
2.
0.
0.
A* CV
1990
BS_
1
9
9
1
4
9
0
8
8
4
5
0
3
8
6
6
9
3
9
5
9
1
3
8
6
7
1
0
0
6
5
3
6
9
2
8
8
rvstv. r ! n
ASJJ
12.0
12.0
10.5
12.3
12.0
10.4
12.0
11.2
12.0
11.7
11.8
11.8
10.2
8.8
9.9
7.6
12.0
11.4
12.5
10.7
7.0
9.1
7.5
10.4
7.2
6.0
6.0
7.8
12.8
6.9
7.8
8.3
17.8
8.2
14.1
9.7
14.0
b/ 8.0 b/ 8.0
75.0 10.5 83.
in the left column indicate the amount
in the indicated state(s)
average percentages of ash content in the coal received
b/ Amount of ash is less than
£/ Totals may not add due to
0.1 million tons.
independent rounding
Source: See Attachment B-l for the major assumptions us
assumptions were used in the analysis summarize
Year/NSPS and 30 Year/1 2 Ib Sulfur Dioxide Em
; the
1995
mm on
Tons
0.2
0.9
1.6
5.1
0.6
1.2
1.2
3.5
4.1
3.8
3.1
6.3
3.4
3.1
4.8
1.7
4.1
3.0
2.2
0.6
1.1
2.1
1.3
3.0
1.6
0.6
1.1
1.0
15.7
0.6
1.9
1.4
2.9
1.3
2.1
1.0
1.0
_2J,
auvumf
2000
12
12
11
12
12
10
11
11
12
11
11
11
10
8
9
7
12
11
12
10
7
9
7
9
7
6
6
7
13
6
7
8
17
8
13
9
13
&
.0
.0
.5
.4
.0
.3
.7
.3
.0
.8
.8
.9
.3
.9
.7
.6
.0
.3
.4
.5
.1
.1
.5
.6
.2
.0
.0
.6
.6
.9
.3
.2
.0
.1
.0
.8
.8
mn
IS
0.
0.
1.
4.
1.
2.
2.
3.
4.
4.
5.
7.
3.
3.
4.
1.
4.
4.
2.
0.
1.
3.
1.
3.
1.
0.
1.
2.
23.
0.
2.
1.
3.
1.
2.
1.
1.
Ton
as_
4
9
5
9
0
0
7
7
8
3
0
8
4
3
9
6
0
6
0
6
1
3
2
6
7
8
8
0
9
8
1
8
2
5
3
0
9
9.0 0.3
1 10.5 94.5 10.6
of ash generated by coal fired
numbers in the
by utilities in the
ed to develop these
d in Analysis of 6 a
119.
1
i
11.6
12.0
10.2
12.4
12.0
10.0
11.8
11.5
12.0
11.9
11.9
10.9
10.3
6.3
9.7
7.8
12.0
11.5
12.4
11.1
7.1
8.3
7.5
8.5
7.1
6.0
6.0
9.1
13.3
6.9
7.1
7.7
16.2
8.1
11.9
9.9
9.5
9.8
10.5
right column are the
indicated
estimates .
nd 8 Millie
ission Reduction Cases Drenari
Incorporated for the Environmental Protection Agency
, February
1986
state(s).
These
td by ICF
30
-------
B-7
EXHIBIT B-4
ELECTRIC GENERATING CAPACITY
OF COAL-FIRED UTILITIES BY BOILER TYPE a/
(glgawatts)
Wet-Bottom Pulverizers
Dry-Bottom Pulverizers
Cyclones
Stokers
Unknown b_/
TOTAL
1985
15.2
199.1
23.8
1.1
30.1
269.3
1990
15.2
198.9
23.8
1.1
.54,4
293.4
1995
15.2
198.7
23.7
1.1
68.4
306.9
2000
15.0
198.1
23.7
1.1
140.9
378.8
a/ A gigawatt equal 1,000 megawatts.
b/ Plants yet to be constructed are assumed to have primarily dry-bottom
pulverizer boilers.
Source: See Attachment B-l for the major assumptions used to develop these
estimates. These assumptions were used in the analysis summarized
in Analysis of 6 and 8 Million Ton and 30 Year/NSPS and 30
Year/1.2 Ib. Sulfur Dioxide Emission Reduction Cases, prepared by
ICF Incorporated for the Environmental Protection Agency, February
1986.
-------
B-8
EXHIBIT B-5
PERCENTAGE OF EACH TYPE OF ASH
GENERATED BY EACH BOILER TYPE
Wet-Bottom Pulverizers
Dry-Bottom Pulverizers
Cyclones
Stokers
Flv Ash
50%
80%
25%
50%
Bottom Ash
20%
50%
Boiler Slag
50%
75%
Source: Babcock & Wilcox, Steam: Its Generation and Use. New York: The
Babcock & Wilcox Company, 1978, pp. 15-7 - 15-8.
-------
B-9
and then these amounts were aggregated to determine total ash generation by
the electric utility industry in 1985, 1990, 1995, and 2000.
Some minor variances were noted between these estimates and historical
trends in ash generation as reported by the American Coal Ash Association.
Some adjustments were made in the distribution among ash types (but not the
total quantities) so that forecasted quantities were more consistent with
historical trends. The ash production forecasts, as well as historical data
for 1980 to 1984, are presented in Exhibit B-6.
B.2 FGD SLUDGE
Because the sludge produced by flue gas desulfurization systems can vary
a great deal in composition, consistency, and water/solids content, several
simplifying assumptions were made to arrive at values for future FGD sludge
generation.
Wet scrubbers were assumed to be of the direct limestone
type, producing a waste composed of unreacted reagent
(limestone) and reacted reagent (gypsum). Dry scrubbers
use lime as a reagent and were assumed to produce a waste
composed of 25 percent gypsum and 75 percent
CaS03-l/2(H20).
The stoichiometry for wet scrubbers is 1.4, while that for
dry scrubbers is 1.86.
The proportion of dry solids in sludge from wet scrubbers
is 50 percent^; in sludge from dry scrubbers it is 100
percent.
The purity of the reagents (limestone for wet scrubbers
and lime for dry scrubbers) was assumed to be 95 percent.
-------
B-10
EXHIBIT B-6
ASH GENERATION BY ELECTRIC UTILITY POWER PLANTS
(millions of tons)
Flv Ash
Bottom Ash
Boiler Slag
Total
Historical
1980
1981
1982
1983
1984
Estimated
1985
1990
1995
2000
48.3
50.2
47.9
47.2
51.3
54.4
60.8
69.4
89.0
14.5
12.9
13.1
12.7
13.6
15.7
16.9
19.1
22.9
3.6
5.2
4.4
3.9
4.2
66.4
68.3
65.4
63.8
69.1
4.9
5.4
6.0
7.2
75.0
83.1
94.5
119.1
Source: 1980-1984: American Coal Ash Association
1985-2000: See Attachment B-l for the major assumptions used to
develop these estimates. These assumptions were used in the analysis
summarized in Analysis of 6 and 8 Million Ton and 30 Year/NSPS and 30
Year/I.2 Ib. Sulfur Dioxide Emission Reduction Cases, prepared by IGF
Incorporated for the Environmental Protection Agency, February 1986.
-------
B-ll
Sludge factors for wet and dry scrubbers, in pounds of sludge generated
per pound of sulfur dioxide removed, were derived by applying the assumptions
noted in the following equation:
(Ibs.sludge/ - Molar Weight Molar Weight
Ibs. S02 removed) of Reacted By- + of Reagent x (Stoichiometry-1)
Product and Including
Waste 3 Waste 4
t Molar Weight x Percent Dry
of S02 5 Solids
For wet scrubbers this factor equals 6.90, and for dry scrubbers the factor
can be 3.14 or 3.08, depending on the percent of sulfur dioxide that is
required to be removed (either 90% or 70% was assumed, depending on which
level of sulfur removal was most consistent with the Revised New Source
Performance Standard for sulfur dioxide from utility boilers).
Based on the expected sulfur content and total quantity of coal consumed
by electric utilities, future federal and state sulfur dioxide regulations,
and the amount of scrubber capacity forecasted to be in operation in future
years, amounts of sulfur dioxide removed were estimated on a state basis. The
sludge factors explained above were then applied to the quantities of sulfur
dioxide removed to arrive at total FGD sludge generation. Exhibit B-7
presents historical and future FGD capacity and FGD sludge generation for the
U.S.
-------
B-12
EXHIBIT B-7
FGD CAPACITY AND FGD SLDDGE GENERATION
FGD Capacity FGD Sludge Production
(103 megawatts) (millions of tons)
Historical
1970
1972 0.7 0.2
1975 6.7 2.3
1980 27.4 9.5
Estimated
1985 45.2 16.0
1990 62.4 24.1
1995 80.7 30.9
2000 179.3 50.3
Sources: 1970-1980: Energy Information Administration, Cost and Quality of
Fuels for Electric Utility Plants - 1980. DOE/EIA-0191(80), and
Arthur D. Little, Inc., Full Scale Field Evaluation of Waste
Disposal from Coal-Fired Electric Generating Plants. Volume I, June
1985.
1985-2000: See Attachment B-l for the major assumptions used to
develop these estimates. These assumptions were used in the
analysis summarized in Analysis of 6 and 8 Million Ton and 30
Year/NSPS and 30 Year/1.2 Ib. Sulfur Dioxide Emission Reduction
Cases. prepared by IGF Incorporated for the Environmental Protection
Agency, February 1986.
-------
B-13
ATTACHMENT B-l
MAJOR ASSUMPTIONS USED IN THE DERIVATION
OF FUTURE ASH AND FGD SLUDGE GENERATION ESTIMATES
-------
MAJOR ASSUMPTIONS USED IN THE DERIVATION OP FUTURE ASH AND PGO SLUDGE GENERATION ESTIMATES
Critical Parameter
Value
Comments
Global Energy and Economic Conditions
GNP (% Per Year Real Growth)
World Oil Prices (aid-1985 $/bbl)
Natural Gas Prices and Availability
Electric Utility Energy Demand _
Electricity Growth Rate (t Per Year)
Nuclear Capacity (Gw)
1983-1985
1986-1990
1991-1995
1996-2000
2001-2010
1985
1990
1995
2000
2010
1985 deregulation
1980-1984 »
1984-1985
1986-1990
1991-1995
1996-2000
2001-2010
1985
1990
1995
2000
2010
5.0
3.5
3.0
3.0
3.0
28.10
29.20
34.10
38.90
49.80
is assumed
2.2
2.4
2.5
2.5
2.5
2.5
67
105
108
109
120
GNP growth is forecasted to be higher during the
current recovery and then slow to a 3 percent
average per annusi growth rate by 1990.
ICP forecasts assume that oil prices will regain
constant in nominal terns through 1985 because of
near-tern Market conditions. Prices are assumed to
recover somewhat by 1990, with 2.5-3.0 percent
Increases per year in real terms thereafter.
Capacity estimates through 2000 reflect most recent
announcements, postponements, and delays of
currently planned power plants. Nuclear capacity
in 2010 reflects an assumed upturn in nuclear
capacity additions after 2000, which sore than
offset the forecasted retirement of 27 gigawatta of
nuclear power plant capacity expected between 2001
and 2010.
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MAJOR ASSUMPTIONS USED IN THE DERIVATION OF FUTURE ASH AND FGD SLUDGE GENERATION ESTIMATES
Critical Parameter Value Comments
Nuclear Capacity Factors (%)
Substitution of Coal for Oil and Gas
(Gw)
1985
1990
1995
2000
2010
60
64
67
67
67
Reconversion
capacity
(1982-1995)
11.3
Utility Capital Costs (1980 $/kw)
Capital Cost Surcharges
(1980 «/kw)
Coal
Nuclear
Turbine
Scrubbers, Dry
Scrubbers, Wet
- 717- 851
- 1375-1561
- 219- 251
79- 91
- 163- 189
198S-1990i
1995-2000)
2010:
500-2000
(varies by region)
500 for HO, CN, CS
750 for all others
0
Improvement in the availability of nuclear
units is expected as recent regulatory and
technical problems resulting primarily from the
Three-Nile Island experience are resolved.
Reconversions and accelerated replacement are
limited by institutional (e.g., state utility
commissions) and financial (e.g., bond and equity
markets) constraints. Latest estimates reflect
expected delays and cancellations. Capital
surcharges, which vary by CEUM region, are Imposed
on accelerated replacements to reflect these
constraints.
Capital costs Include 10 percent real escalation
from 1980 to 1985. Nuclear capital cost estimates
have been Increased about 35 percent above previous
EPRI estimates, reflecting (1) significantly longer
construction and lead times, (2) more safety
requirements for future plants, and (3) additional
escalation in materials, equipment and labor
costs. Nuclear capital cost estimates correspond
to recent DOE estimates. Other power plant cost
estimates are based on EPRI figures.
Capital cost surcharges are Imposed on new capacity
builds to limit economic replacements. Surcharges
reflect regulatory, financial, and institutional
constraints to capital investment.
Power plant Lifetime (Years)
Coal Steam - 60
Oil/Gas Steam - 45
Nuclear - 35
Oil/Gas Turbine - 20
Power plant units are assumed to retire based on the
assumed number of years after their initial date of
commerial operation except for announced retire-
ments. Coal power plants are refurbished after 30
years for $200/kw (early-1985 $). This is assumed
to extend their useful lifetime from 45 to 60
years. Reconversions are assumed to retire 30
years after their reconversion date.
-------
MAJOR ASSUMPTIONS USED IN THE DERIVATION OP PUTURB ASH
Critical Parameter Value
Coal Power plant Heat Rates Over Time
Minimum Turndown Rates
Canadian Imports of Electricity
(BKHH transmitted)
Financial Parameters
Inflation Rate (% Per Year)
0.25% per year increase
over current levels,
After refurbishment improves
heat rates are improved
(decreased) by five percent
from previous forecasts
levels.
Coal - 35%
Oil/Gas Steam - 20%
1985
1990
1995
2000
2010
1984
1985
1986-2010
45
69
89.9
86.8
96.9
3.8
4.0
5.0
PGD SLUDGE GENERATION ESTIMATES
Comments
Based on empirical studies and engineering assess-
ments of heat rate deterioration over time and the
effects of power plant refurbishment.
Coal and oil/gas steam units must operate at or
above minimum load during the week. Minimum load
levels assumed herein are based on various
empirical studies of operating practice and
constraints.
Imports reflect current contracts and announced
plans.
Latest forecasts anticipate a small increase in
average annual inflation rates.
Real Discount Rate (% Per year)
Real Capital Charge Rates (%)
Coal/Nuclear/Combined Cycle
Pollution-ControlNew
Pollution-ControlRetrofit
Combustion Turbine
Book Life (years)
Coal/Nuclear/Combined Cycle
Combustion Turbine
Pollution Control-Retrofit
Pollution Control-New
Coal Mine
Utility
9.0
9.0
6.5
10.5
30
20
30
30
6.00
4.27
The retrofit pollution-control capital charge rate
is lower than the new pollution-control rate because
of the rapid tax write-off provision available to
retrofits only. Use of Industrial revenue bond
financing was not assumed.
Longer book life for pollution-control equipment
assumed in the previous EPA base is the major reason
for lower real capital charge rates for this
equipment.
-------
MAJOR ASSUMPTIONS USED IN THE DERIVATION OP FUTURE ASH AND fGD SLUDGE GENERATION ESTIMATES
Critical Parameter Value Comments
Tax Depreciation Life (years)
Retrofit Pollution Control
Others
5
IS
Tax depreciation based on Accelerated Cost Recovery
Systesi (ACRS) under Economic Recovery Tax Act of
1981.
Input Year Dollars
Output Year Dollars
Escalation Input to Output Dollars
Real Cost Escalation Parameters
Coal Transportation Rates
(% Total Real Escalation)
early 1980
early 1985
1.34
Rail
1981 - 1985
1986 - 2000
Truck and Barge
1981 - 1985
1986 - 2000
Coal Mining Productivity
Mining Costs (% Annual Real Escalation) Capital
Labor
Mining Productivity Base Level (1985)
(% of Standard)
Materials
UMHA
Non-UMHA
Mixed
-5.0
0.0
5.0
0.0
1.0
1.0
in 1984;
2.0/3 yrs.
thereafter
0.0
80
95
90
Growing competition will hold down the Marginal rail
rates to levels below current average rail rates.
Truck and barge rates are assumed to escalate in
real terms to account for long-term fuel price
increases.
t Annualized Productivity Increase
(1985-95)
Utility Power plant Capital Costs
(t Total Real Escalation)
Surface - 1.0
Deep-Continuous
Mine - 1.0
Deep-Longwall 2.0
1980-1985 - 10.0
1985-2000 - 0.0
Expected real escalation in nuclear plant coats Is
higher and is incorporated in base nuclear cost
estimates.
-------
MAJOR ASSUMPTIONS USED IN THE DERIVATION OF FUTURE ASH AND FGD SLUDGE GENERATION ESTIMATES
Critical Parameter Value Comments
Other Governmental Regulations
Federal Leasing Policy
Ale Pollution Regulation*
Enough
Most recent federal and
state rules.
Federal leasing is assumed to be sufficient to
avoid artificially driving up market prices.
Sulfur dioxide emission Units assumed to be
tightened in New York and Wisconsin over the next
ten years in light of recent state legislation
aimed at responding to acid rain and/or ambient air
quality concerns. Certain variances are assumed to
expire and revisions are assumed to occur. No
other changes assumed beyond current emission
limitations.
Non-Utility Coal Demand
Industrial/Retail Coal Use
(106 tons)
Steam Coal Exports (106 tons)
Metallurgical Coal Use (106 tons)
Export
Domestic
1985
1990
1995
2000
2010
1985
1990
1995
2000
2010
1985
1990
1995
2000
2010
1985
1990
1995
2000
2010
82
109
135
170
220
28
25
48
69
120
53
49
53
61
65
54
61
62
62
62
Reflects recent forecasts of industrial boiler
coal demand combined with forecast of the kiln and
residential/commercial coal Markets. Low oil prices
and increased reliance on waste products and
conservation are expected to dampen near-tera coal
demand.
Reflects low growth in worldwide electricity demand
and less market share going to U.S. producers,
particularly in 1985 and 1990. Reduction in longer-
term demands concentrated mainly in the Pacific Rim.
Reflects sluggish growth expected in world markets.
Continuing trends in steel substitution limit
forecasted domestic metallurgical coal use
through most of the 1980's. Steel's recovery
from the present slump is not yet complete by
1985.
-------
MAJOR ASSUMPTIONS USED IN THB DERIVATION OP FUTURE ASH AND PGD SLUDGE GENERATION ESTIMATES
Critical Parameter Value Coaaenta
Synthetics (Coal Input in 106 tons)
(Million Tons)
1985
1990
1995
2000
2010
4
8
8
8
8
Outlook Cor ooal-based projects continues to be
unfavorable. Some slippage seen in on-line dates
of Major near-term projects. Great Plains Gasifi-
cation Project assuscd to stay on schedule.
-------
APPENDIX B
NOTES
1 For more detail regarding assumptions, see Analysis of 6 and 8 Million Ton
and 30 Year/NSPS and 30 Year/1.2 Ib. Sulfur Dioxide Emission Reduction
Cases. February 1986, prepared by IGF Incorporated for the Environmental
Protection Agency. The major assumptions concerning future energy
demand, economic conditions, and government regulations used to derive
the estimates in the IGF study are presented in Attachment B-l to this
Appendix.
2 Arthur D. Little, Inc., Full Scale Field Evaluation of Waste Disposal from
Coal-Fired Electric Generating Plants. June 1985.
^ The reacted by-product generated by wet scrubbers has a molar weight of 179;
that generated by dry scrubbers has a molar weight of 146.3.
^ The molar weight of limestone (the reagent used in wet scrubbers), including
5 percent waste, is 105.3. The molar weight of lime (the reagent assumed
used in dry scrubbers), including 5 percent waste, is 59.
5 The molar weight of sulfur dioxide (S02) is 64.064.
° These assumptions were used in the analysis summarized in Analysis of 6 and
8 Million Ton and 30 Year/NSPS and 30 Year/1.2 Ib. Sulfur Dioxide
ftnflsgjprc Reduction Cases, prepared by ICF Incorporated for the
Environmental Protection Agency, February 1986.
-------
REGULATION OF COAL COMBUSTION HASTE DISPOSAL
IN SEVENTEEN HIGH COAL-BURNING STATES
This appendix contains a state-by-state description of coal combustion
waste disposal regulation. The 17 states whose regulations are described below
are the highest coal-burning states in the country -- together they account for
over 70 percent of the nation's coal-fired electric capacity. This appendix
supplements the description of state regulation found in Chapter 4 and serves
as a companion document to the table shown in Exhibit 4-1.
Texas
Coal combustion wastes are regulated under Texas' Industrial Waste
Management Regulations. The regulations cover two types of waste, referred to
as Class I and Class II wastes, although they do not give any information about
how a particular waste stream would be classified. Class I wastes are
controlled to a greater extent than are Class II wastes; ground-water
monitoring is required at Class I waste facilities. The regulations include no
additional design or operating requirements for either type of waste. A permit
is required for off-site disposal; on-site disposal requires notification only.
The report conducted for USWAG by Wald, Harkrader, and Ross, Survey of
State Laws and Regulations Governing Disposal of Utility Coal-Combustion
By-Products. gives information on additional requirements in Texas: "For both
on-site and off-site disposal, the Department performs a site-specific
technical review based on written guidelines that recommend installation of
soil-based liners, ground-water monitoring and vegetative cover. Surface
impoundments containing wet fly ash should be scrutinized for excess leachate
-------
C-2
head." A follow-up interview with a Texas environmental official gave the same
information. According to the interview, a new plant's waste is given
temporary Class 1 classification until the plant proves that the waste is
non-hazardous. (The official could not recall any instance of a plant's
failing to do so.) Although permits are not required for on-site disposal,
plants follow site-specific guidelines issued by the Department when disposing
of wastes on-site.
Texas' Industrial Waste Regulations include impoundments in the definition
of an industrial waste facility, but do not give separate guidelines.
According to the USWAG report and the Texas official, they are subject to the
same requirements as are landfills, and regulated by both state water
authorities, which govern discharges to surface water, and by state solid waste
authorities.
Indiana
Coal combustion wastes are regulated under Indiana's Solid Waste Rules.
According to these rules, permits are required for on-site and off-site
disposal, and ground-water monitoring may be required. According to the USWAG
survey, "both on-site and off-site facilities ... are subject to the sanitary
landfill permit requirements, including ground-water monitoring, a periodic
cover, and a two-foot final cover." A state environmental official stated
during a follow-up interview that ground-water monitoring and other design and
operating standards are required on a case-by-case basis, based on the geology
of the site and on the results of a chemical testing of the waste.
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C-3
The USVAG survey does not address Indiana's regulation of impoundments.
The regulations only specifically apply to sanitary landfills -- impoundments
are not mentioned. An Indiana environmental official states that impoundments
are regulated only by the state's NFDES program, which does not specify design
or operating requirements.
Kentucky
Under Kentucky's hazardous waste regulations, coal combustion wastes are
"special wastes." If a waste fails an EP toxicity test, its disposal will be
regulated as a hazardous waste, and be subject to RCRA Subtitle C-type design
and operating requirements. Otherwise, the disposal is regulated under
Kentucky's solid waste rules. Kentucky's solid waste regulations require
leachate control systems; according to the USWAG survey liners are also
required. Ground-water monitoring requirements are implemented on a
case-by-case basis.
Kentucky's solid waste regulations are for "solid waste disposal
facilities," and do not explicitly exclude or include impoundments. According
to an interview with a Kentucky solid waste official, if the impoundment is
part of a treatment process that discharges to surface water, it must have an
NPDES permit. These permits do not specify design or operating requirements.
If the impoundment no longer discharges to surface water, solid waste
regulations apply.
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C-4
Ohio
Ohio's hazardous waste regulations exempt coal combustion waste from
regulation. The solid waste regulations also exclude "non-toxic fly ash." No
criteria are given in the regulations for determining toxicity. According to
the USWAG survey and a follow-up interview with an Ohio environmental official,
the ash is given an EP toxicity test to determine whether it will be subject to
Ohio's solid waste regulations. Almost all ash passes the test, and is
therefore exempt from all regulation.
Ohio's solid waste regulations specifically exempt "pond or lagoon
operations." Such operations are regulated under Ohio's water regulations,
which do not specify design or operating requirements.
Pennsylvania
Pennsylvania has designed regulations specifically for the disposal of coal
combustion waste. These regulations specify that chemical and geologic
analysis must be performed at the disposal site; and that ground-water
monitoring may be required on a case-by-case basis. However, the lining and
leachate collection systems that are required for other solid waste disposal
facilities are not required for coal combustion waste disposal sites.
According to the USWAG report, "fly ash ponds are regulated by permit under
the Clean Streams Law of Pennsylvania; the permit requires NPDES testing and
design standards, which include ground-water monitoring and leachate control."
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C-5
Illinois
Coal combustion wastes are governed by Illinois' solid waste regulations.
The regulations state that a permit is required for solid waste disposal
facilities. Although the regulations do not distinguish between on-site and
off-site disposal, a state environmental official interviewed for this report
stated that on-site facilities are exempted from the permit requirement.
Although the regulations do not explicitly require liners, ground-water
monitoring, or leachate collection, an Illinois representative indicated that
these standards are often required for coal combustion waste disposal on a
case-by-case basis.
The solid waste regulations only list regulatory requirements for landfills
-- impoundments are not addressed. An agency representative stated that
impoundments are regulated by Illinois' NPDES program, which requires
ground-water monitoring.
West Virginia
Coal combustion wastes are regulated by West Virginia's solid waste
regulations, which require permits for disposal. The regulations contain only
cover and closure requirements, although the USWAG survey, citing interviews
with environmental officials, gives more information: "All disposal sites must
meet leachate, waste confinement, and aesthetic standards. There are specific
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C-6
requirements concerning ground-water monitoring and final cover."
Michigan
Michigan's solid waste regulations call for on-site and off-site landfills
to be permitted and to have ground-water monitoring systems. A Michigan
official and information in the USWAG survey both confirmed this.
North Carolina
According to North Carolina's solid waste regulations, on-site and off-site
landfills must have permits. In order to receive permits, the landfills must
have a ground-water monitoring system. This information is confirmed by the
USWAG report.
The Solid Waste regulations explicitly exclude impoundments, and leave
their regulation to North Carolina's water regulations. The official water
regulations regulate only discharge from impoundments, and do not contain any
design or operating requirements, such as lining or ground-water monitoring,
for surface impoundments.
Georgia
Georgia's solid waste regulations require permits for off-site and on-site
disposal. No mandatory design or operating requirements, such as ground-water
monitoring, liners, or leachate collection, are listed. According to a Georgia
environmental official, design and operating standards are applied on an
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C-7
case-by-case basis.
Only landfills are addressed in Georgia's solid waste regulations.
According to a Georgia environmental official, surface impoundments are
regulated by the state water regulations, which cover only discharge to surface
water, and do not have requirements for ground-water monitoring or liners.
Florida
Florida's solid waste regulations require that off-site disposal facilities
be permitted and have liners, leachate collection, and ground-water monitoring
systems. On-site facilities do not need permits. The regulations have been
changed significantly since 1983, when the USWAG report was written. The
regulations apply only to sanitary landfills - - impoundments are not
specifically mentioned.
Missouri
The regulation of coal combustion utility wastes are handled primarily
under Missouri's solid waste regulations. According to the regulations,
leachate collection systems are required on a case-by-case basis.
The solid waste regulations exempt lagoon operations that have permits from
the Clean Water Commission. The Missouri Water Quality Standards do not
specify any design or operation requirements for impoundments; the USWAG
survey, however, states: "Permits from the Clean Water Commission impose
specific requirements on ground-water quality." A follow-up interview with a
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C-8
Missouri water official confirmed the information derived from the USWAG
report.
Alabama.
Alabama's Solid Waste Regulations require permits for off-site and on-site
disposal. According to the USWAG survey, off-site disposal requires additional
permission from local health authorities. The regulations require ground-water
monitoring and an artificial lining on a case-by-case basis.
Tennessee
Under Tennessee's hazardous waste rules, "fly ash ... [is a] hazardous
waste which [is] exempt from certain regulations." The hazardous waste
regulations that apply to coal combustion by-products are for the testing of
waste. An official from Tennessee indicated that the testing requirement gives
the state waste agency information with which to design suitable disposal
requirements for coal combustion wastes. Tennessee's solid waste rules govern
the design and operation of coal combustion waste disposal facilities.
Tennessee's solid waste regulations allow liners and ground-water monitoring to
be required on a case-by-case basis.
Like most state solid waste regulations, Tennessee's regulations are
unclear about the regulation of on-site facilities. Due to legal challenges,
on-site solid waste facilities in Tennessee are not currently being regulated.
Tennessee's solid waste regulations only explicitly list requirements for
-------
C-9
sanitary landfills. Surface impoundments are not specifically addressed,
although according to a Tennessee Valley Authority official, surface
impoundments are regulated under NPDES permitting until the pond is full; once
the impoundment no longer discharges to surface water, state solid waste
regulations apply.
Nevada
Nevada's solid waste regulations pertain only to landfills, and specify
only siting restrictions, cover, and layering requirements; ground-water
monitoring, lining, and leachate collection are not required. According to the
USWAG report, in practice, more stringent requirements are enforced: "The
Department now requires a liner or its functional equivalent and groundwater
monitoring." Nevada's solid waste regulations require municipalities and
districts to devise a waste management system, and local authorities may adopt
more stringent regulations than currently mandated by state law.
The solid waste regulations of Nevada appear to address only landfills;
impoundments are not explicitly mentioned.
South Carolina
South Carolina regulates the disposal of coal combustion waste under its
solid waste regulations. Disposal facilities must have permits, and minimal
design and operating standards (cover, grade, siting) are imposed. The
regulations require that facilities be designed by state-permitted engineers.
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C-10
Impoundments are addressed in South Carolina's industrial solid waste
disposal regulations: "Disposal of waste sludges and slurries shall be done
with special consideration of air and water pollution, and the health and
safety of employees ... [and} case-by-case provisions [are made]." No specific
requirements are listed.
Wisconsin
In Wisconsin, coal combustion wastes are regulated under the state's solid
waste regulations, which require solid waste disposal facilities to be
licensed. Ground-water and leachate monitoring may be required on a
case-by-case basis. Impoundments are included in Wisconsin's definition of a
solid waste disposal site.
-------
SOURCES FOR APPENDIX C
(By State)
Texas
Texas Industrial Waste Management Regulations. Interview with Richard
Anderson, Industrial Solid Waste Section, Texas Department of Health,
January 2, 1987. Survey of State Laws and Regulations Governing Disposal
of Utility Coal-Combustion Byproducts, prepared by Wald, Harkrader & Ross
for the Utility Solid Waste Activities Group (USWAG), pp. 62-63.
Indiana
Indiana Solid Waste Management Permit Regulations. Interview with George
Oliver, Land Pollution Control Division, State Board of Health, January 2,
1987. USWAG Survey, p. 20.
Kentucky
Kentucky Waste Management Regulations. Interview with Shelby Jett, Natural
Resources and Environmental Protection Cabinet, Department of Environmental
Protection, January 6, 1987. USWAG Survey. p. 24.
Ohio
Ohio Solid Waste Disposal Regulations. Interview with Tina Redman, Office
of Land Pollution Control, Ohio Environmental Protection Agency, January 2,
1987. USWAG Survey, pp. 51-52.
Pennsylvania
Pennsylvania Solid Waste Regulations. Interview with Ron Hassinger, Bureau
of Solid Waste Management, Department of Environmental Resources, January
2, 1987. USWAG Survey, p. 55.
Illinois
Illinois Solid Waste Regulations. Interview with Harry Chapel, Division of
Land and Noise Pollution Control, Environmental Protection Agency, January
5, 1987. USWAG Survey, p. 18.
Vest Virginia
West Virginia Solid Waste Regulations. USWAG Survey, p. 69.
Michigan
Michigan Solid Waste Management Regulations. Interview with Karen Kligman,
Resource Recovery Division, Department of Natural Resources, January 6,
1987. USWAG Survey, p. 32.
-------
-2-
North Carolina
North Carolina Solid Waste Management Regulations. USWAG Survey. p. 49.
Georgia
Georgia solid Waste Management Rules. Interview with fiurt Langley, Land
Protection Branch, Division of Environmental Protection, Department of
Natural Resources, January 2, 1987. USWAG Survey. p. 15.
Florida
Florida Resource Recovery and Management Regulations.
Missouri
Missouri Solid Waste Rules and Regulations. Missouri Water Quality
Standards. Interviews with Suzanne Renard, Missouri Waste Management
Program, and with Bob Hengtes, Missouri Clean Water Commission, January 23,
1987. USWAG Survey, p. 36.
Alabaaa
Solid Waste Management Regulations. USWAG Survey. p. 1.
Tennessee
Tennessee Hazardous Waste Management Rules. Tennessee Solid Waste
Regulations. Interview with Dwight Hinch, Regulations and Legislative
Office, December 31, 1986. USWAG Survey, p. 61.
Nevada
Nevada Solid Waste Management Regulations. USWAG Survey. p. 41.
South Carolina
South Carolina Industrial Solid Waste Disposal Site Regulations, South
Carolina Guidelines for Waste Disposal Permits. USWAG Survey. p. 58.
ViscousIn
Wisconsin Solid Waste Management Regulations. USWAG Survey. p. 70.
-------
WASTE FLUID. STUDIES
This appendix presents the results of studies on the waste fluids in coal
combustion waste landfills and impoundments. Waste fluids are not ingested,
but the constituents in the waste fluids have the potential to affect the
quality of surrounding ground water or surface water. These studies are also
useful for illustrating some of the characteristics of coal combustion wastes.
Tennessee Valley Authority Power Plants
A report by R.J. Ruane and others summarized Tennessee Valley Authority
(TVA) research on wet ash disposal and wet limestone scrubber-sludge.^ The
study on ash disposal involved 12 TVA coal-fired plants, including a
description of the effects of ash disposal at a typical 1000-MW plant, which
produces approximately 700 tons of fly and bottom ash per day. The ash is
either disposed of in a dry form or sluiced to the ash containment ponds. The
wet limestone scrubber-sludge examined in the study was from a 550-MW plant at
the Widows Creek Steam Plant.
Several constituents in subsurface leachates from the ash ponds exceeded
the primary and secondary drinking water standards. Constituents found in
concentrations that exceeded the primary or secondary criteria included
cadmium, chromium, iron, manganese, lead, sulfate, pH, and TDS. Some of the
ash pond leachates were quite acidic with measured pH values as low as 2.0.
The operation of the wet limestone scrubber and the transfer of scrubber
-------
D-2
blowdown to the ash ponds caused statistically significant increases in the
concentrations of calcium, magnesium, chloride, sulfate, selenium, IDS and
conductivity in the ash pond discharges.
In addition to monitoring ash pond effluents, the TVA also conducted
toxicity studies on ash pond effluents from four distinct waste disposal
sites. The toxicity studies were performed in the spring and fall. The fall
studies showed no significant effects on the tested species (Daphnia pulex and
Pimephales promelas) while the spring studies revealed significant effects on
the survival and reproduction of Daphnia pulex.
In summary, several of the fly ash leachates had constituent
concentrations that exceeded drinking water standards. These constituents
included cadmium, chromium, iron, manganese, and lead. Higher concentrations
of potential contaminants were associated with extreme pH values. Some of the
fly ash leachates had pH values as low as 2.0. Some of the fly ash effluents
demonstrated the potential to affect the biological environment.
Turner Study of Arsenic in Coal Ash Leachate
R.R. Turner (1981) collected ash disposal pond effluents at 12 coal-fired
utilities and pond influent samples at three utilities. At one of the sites,
two wells were drilled into an older ash basin and used to collect
interstitial water from the middle and bottom of the basin. All samples
collected, including influents, effluents, and well samples, were analyzed for
total dissolved arsenic (TDA) and for arsenic (III).
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D-3
The effluents from the ponds located at the 11 largest utilities had IDA
measurements ranging from 0.5 to 130 A»g/l- The arsenic (III) to IDA ratio was
always 0.40 or smaller at these 11 plants. Arsenic concentrations in the pond
at the smallest of the 12 plants were between 116 and 460 /*g/l in the pond
influent and varied from 118 to 150 /ig/1 in the pond effluent. The
interstitial fluid drawn from the wells located in the middle and bottom of
the older fly ash disposal site had arsenic concentrations that reached 550
/ig/1 in the middle well and 1590 Mg/1 in the well placed at the bottom of the
fly ash. Arsenic (V), the less toxic state of arsenic, was the predominant
arsenic species in all of these samples.
There was a wide variability in arsenic concentrations in all of the
samples collected from the field as well as in the effluents from column
leaching studies that were conducted concurrently with the field studies.
This demonstrates the inherent variability of the fly ashes and the
environments in which they are located, and thus the difficulty of trying to
determine generic conditions for fly ash disposal. Arsenic (V) concentrations
appeared to be controlled either by adsorption onto amorphous iron
oxyhydroxidas in the neutral to slightly acidic pH range or by slightly
soluble metal arsenates. Mechanisms controlling arsenic (111) concentrations
were not determined by this study.
The study results suggest that the use of iron oxyhydroxides in limiting
the migration of trace elements may be beneficial at selected sites.
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D-4
Savannah River Project, Aiken, South Carolina
In a series of papers, Cherry, Guthrie, and co-workers studied the
drainage system for an ash basin serving a coal-fired power plant at the
Savannah River Project in Aiken, South Carolina. To provide data for these
papers, surface water samples were collected from the influent to and effluent
from several large ash basins. Also, samples were taken at several points
within the drainage system downstream from the ash disposal ponds. These
samples were analyzed to determine the concentrations of constituents.
Plants, invertebrates, and vertebrates were also monitored. These studies
took place over a period of more than eight years from mid-1973 to January
1982. During this time, selected water quality parameters were monitored on a
monthly, bimonthly, or quarterly basis. By studying the various sinks for the
constituents in the effluents from the ash disposal ponds, conclusions were
reached as to the dissipation mode of constituents in the surface waters of
the drainage system. Differences in constituent concentrations accumulated in
the various components of the system were tested by a two-tailed analysis of
variance.
The biotic components of the drainage system tended to contain higher
concentrations of potentially toxic constituents (titanium, manganese, copper,
chromium, zinc, arsenic, selenium, cobalt, cadmium, and mercury) than the
surface water components inhabited by the biota. The highest concentrations
of constituents occurred in the benthic sediments; the settling of sediments
represented the mechanism for the greatest removal of constituents from the
-------
D-5
system. Certain constituents, calcium and zinc, were concentrated in
invertebrates and fish at a higher level than that found in the sediments.
Two constituents, cadmium and selenium, were present in the effluents from the
ash ponds in concentrations that exceeded the primary drinking water
standards. Though concentrated by invertebrates, the invertebrate
concentration of these constituents did not exceed the concentration found in
the sediments. At near neutral pH values (pH 6.5), mean concentrations of
arsenic, cadmium, chromium, copper, selenium, and zinc in the effluent
drainage system were higher than either the maximum and/or 24 hour average
allowable for these parameters in the U.S. EPA Water Quality Criteria.^ The
mean elemental concentrations of four of these constituents (cadmium,
chromium, copper, and zinc) were from one to two orders of magnitude higher
than the allowable 24 hour average.
When the ash disposal system was properly managed, there appeared to be a
minimal effect on the aquatic system. However, when an ash pond overflowed
into the effluent drainage system without adequate time for settling of the
sediments to occur, major impacts upon the effluent drainage system were
observed. Heavy sediment concentrations and low pH conditions (the extreme
effluent pH observed was 3.5) caused by the overflow resulted in severe
reductions of most invertebrate fauna. The invertebrate population densities
eventually returned to pre-overflow levels when the problem was corrected.
The bioconcentration of potentially toxic constituents will, undoubtedly, have
an effect on the biota. It is impossible to ascertain the effect of
constituent accumulation from the ash ponds, however, because the constituent
concentrations prior to initiation of this study are not known. Several trace
-------
D-6
metals have concentrations in ash pond effluents that exceed the primary
drinking water standards.
Bull Run Steaa Plant, Oak Ridge, Tennessee
In cooperation with personnel from the TVA, Coutant and others^
investigated the chemistry and biological hazard of seepage from an ash pond
at the TVA's 900-MW Bull Run Steam Plant near Oak Ridge, Tennessee. Ash from
the Bull Run Steam Plant is slurried to three ash ponds connected in a series.
The ash stream consists of fly ash, bottom ash and pieces of pyrite that were
separated from coal prior to combustion. The three ponds act as settling
ponds to allow ash particles to drop out of solution. At the end of the third
pond is a weir over which effluent flows into the Clinch River. Monitoring at
the discharge weir has been regularly conducted since 1967. During this time,
analyses have been performed for a variety of constituents including
alkalinity, conductivity, TDS, calcium, magnesium, chloride, sodium, total
iron, total manganese, sulfate, and silicon dioxide.
In addition to the flow through the ash ponds and over the weir, there is
another flow that was previously uncharacterized. This flow was in a drainage
ditch that ran parallel to one of the ash ponds. The drainage ditch ends at a
culvert that flows into the Clinch River. The sediments at the bottom of the
drainage ditch, the water in the ditch and vegetation that had blown into the
ditch were all colored a reddish hue. The objective of this study was both to
characterize and understand the mechanism responsible for the reddish hue and
to check for biological hazard by exposing fish to the drainage discharge at
-------
D-7
its confluence with the Clinch River. Samples were taken so as to follow the
flow in the drainage ditch from its uppermost point to its point of discharge
at the river.
The reddish precipitate contained over 40 percent iron and was determined,
by x-ray diffraction, to be mainly FeOOH. The formation of the precipitate
was consistent with the chemical data which revealed that iron concentrations
in the drainage liquor continuously decreased along the flow path. Total
dissolved iron concentration was 927 mg/1 at the beginning of the ditch, and
fell to 320 mg/1 by the time the liquor reached the culvert that discharged
into the Clinch River. Concomitant with the drop in total dissolved iron,
ferrous iron concentrations fell and ferric iron concentrations rose along the
same flow path. Most of the iron leaving the ash ponds went through the
drainage ditch and not over the weir at the end of the ash ponds. The liquor
in the ditch became more acidic as flow progressed towards the Clinch River.
Initial pH values in the flow were 3.2, while the pH fell to 2.9 at the
culvert. The total iron discharged from the ditch per unit time was
approximately 44 times the iron discharged over the weir, even though the
volume of the flow over the weir was roughly 20 times the flow in the ditch.
As might be expected, the discharge from the ditch posed a biological
hazard. All fish placed in the ditch at the entrance to the culvert or in the
Clinch River at the culvert discharge point died within three days. A control
group of fish, placed in an unaffected part of the Clinch River, survived
during the time frame of the experiment (2 weeks).
-------
D-8
Liquor in the drainage ditch from the ash pond leachate poses a biological
threat. This threat is limited because of dilution by the significantly
greater flow of the Clinch River. The acidification encountered in this study
probably is a result of the oxidation of the pyritic ore that was discharged
to the ash ponds. Oxidation of pyrite produces hydronium and sulfate ions.
Lower pH values, besides posing a threat to the environment because of the
acidity, can mobilize many trace constituents found in the ash. Analyses were
not performed for trace constituents in this study.
-------
APPENDIX D
NOTES
Ruane, R.J., J.D. Milligan, R.C. Young, T.Y.J. Chu and H. Olem. "Aquatic
Effects of Wet Ash Disposal and Wet Limestone Scrubber Systems." In
International Conference on Coal Fired Power Plants and the Aquatic
Environment. Supplement to Proceedings. CONF-8208123, Hoersholm,
Denmark, Water Quality Institute, pp. 669-673, 1982.
Turner, R.R. "Oxidation State or Arsenic in Coal Ash Leachate."
Environmental Science Technology. Vol. 15, No. 9, pp. 1062-1066, 1981.
Cherry, D.S., and R.K. Guthrie. "Mode of Elemental Dissipation from Ash
Basin Effluent." Water. Air. Soil. Pollution. Vol. 9, pp. 403-412, 1978.
Cherry, D.S., R.K. Guthrie, E.M. Davis and R.S. Harvey. "Coal Ash Basin
Effects (Particulates, Metals, Acidic pH) upon Aquatic Biota: An Eight-
Year Evaluation." Water Resource Bulletin. Vol. 20, No. 4, pp. 535-544,
1984.
Coutant, C.C., C.S. Wasserman, M.S. Chung, D.B. Rubin and M. Manning.
"Chemistry and Biological Hazard of a Coal Ash Seepage Stream." Journal
of Water Pollution Control Federation. Vol. 50, pp. 747-753, 1978.
-------
ARTHUR D. LITTLE STUDY OF
HASTE DISPOSAL AT COAL-FIRED POWER PLANTS
Arthur D. Little, Inc. (ADL) conducted a 3-year study for EPA's Office of
Research and Development on coal ash and flue gas desulfurization waste
disposal practices at coal-fired power plants. The study involved
characterizing wastes generated at coal-fired power plants and gathering data
to assess the environmental effects and engineering costs associated with the
disposal of combustion wastes.
Results of the study were intended to be used: (1) as a technical basis to
help EPA determine the degree, if any, to which disposal of these wastes should
be managed to protect human health and the environment; and (2) to provide
useful information on environmentally sound disposal of coal ash and FGD wastes
to utility planners and state and local permitting officials.
To accomplish these goals, in-depth evaluations of six waste disposal sites
around the country were undertaken. The study approach is discussed below.
E.I SITE SELECTION PROCESS
To characterize the different types of waste generated at coal-fired
utility power plants, individual assessments of impacts were conducted at
specific waste disposal sites. Only six sites were actually investigated,
although the original intent of the study was to examine a larger number of
utility disposal sites. The process by which these six sites were selected is
briefly discussed below.
-------
E-2
The 48 contiguous states were divided into 14 physiographic regions,^ and
coal-fired power plants for which data^ was available were identified in each
of these regions.^ Sites were then screened to identify those for which a
reasonable assessment of data obtained from one year of environmental
monitoring would be possible. Screening criteria were based on
engineering/technology-related, hydrologic, and other site-selection factors
(e.g., site age, generating capacity, technological or hydrogeologic
complexity, waste types generated, disposal methods, site location, etc.)^
As a result of this process about 26 "candidate sites" were chosen. The
"candidate sites" were then subjected to further evaluation to assess their
suitability. This included:
contact with the facility to determine its willingness
and ability to cooperate in the study.
a visit to the power plant and disposal sites; and
review of the available data on the hydrogeologic and
environmental setting of the area and site.
On the basis of these evaluations, a final number of six sites were selected.
These six sites were the Dave Johnston Plant in Wyoming, the Sherburne County
Plant in Minnesota, the Powerton Plant in Illinois, the Elrama Plant in
Pennsylvania, the Allen Plant in North Carolina, and the Smith Plant in Florida.
Factors that were considered to be important in the selection of each site for
of the study are discussed in subsequent sections.
-------
E-3
E.2 SITE IHFOBMAT10H
Exhibit E-l shows the general locations of the six sites of the ADL study.
Exhibit E-2 provides information from each site, including generating capacity,
operating dates, and waste type and disposal method.
E.3 STUDY APPROACH
Investigations carried out at the six sites included physical and chemical
sampling of the wastes, soils, ground water, and surface water at the site,
subsurface explorations utilizing boring and wells, soil and rock classification
and mapping, and water balance studies. Results were used to make individual
environmental assessments of each site (i.e., assessing the effects of waste
disposal on ground-water and surface-water quality). Findings from the six
sites were also used to try to make generic projections of industry-wide
implications of coal ash and FGD Waste Disposal.
The six sites are discussed individually in the following sections, E.4-E.9.
A brief description is given of each site's disposal activities, hydrogeology,
and reasons for it's selection by ADL for study. Also presented are the results
of testing done at the site and discussion of these results. An analysis of the
testing results at the six sites for QA/QC is presented in Section E.10. A
summary of findings at each site and a discussion of conclusions that can be
drawn from the ADL study in regard to the environmental impacts that may occur
due to waste disposal practices at coal-fired power plants is presented in
Chapter 5.
-------
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EXHIBIT E-1
LOCATIONS OF SITES SELECTED FOR ADL STUDY
DAVE JOHNSTON SHEKBURNE COUNTY (SHERCO)
ELRAtM
ALLEN
-------
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EXHIBIT E-2
INFORMATION ON SITES OF ADL STUDY
it
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f
H-
ft
00
Ln
Plant
Allen Duke Power
Elraawt Duuuesne
Light0
Dave Pacific Power
Jolmaton & Light
Sherburne Northern
County State! Power
Power ton CoHsonwealth
Edison
Location
city (MM)
Startup Date Waste Site Under Study
Ss.lt h
Gulf Power
PA Washington
WY
MN
IL
Converse
Sherburne
Tazewell
FL Bay
Naacplate
Generating
1155
510
750
1458
1786
3AO
FCD tao/yr)
Unit On Plant FGD
-/57
510 6/52 10/75
-/57
1458 5/76 5/76
-/72
6/65
Waste Type
Combined fly
and bottosi
Ash
StabllUed
FGD waste
Combined fly
and botto*
ash
Fly Ash
Fly ash/FCD
Combined fly
and bottosi
ash
Combined fly
and bottosi
ash
Disposal
Method*
Pond (UL)
Landfill
(OL,
offsite)
Landfill
(UL)
Landfill
(UL)
Pond (AL)
Landfill
(AL)
Pond (UL)
High Priority Issues
Under Study
ISpToySent
of a
Ground- Surface- Potentially
water water Mltlgatlve
Quality Quality Practice
pi
i
Notcu:
"UL - UnllneU
AL - Artificially Lined
^Disposal site operatcil by Conversion Systems, Inc.
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E-6
E.4 ALLEN PLANT
Plant Allen of Duke Power Company is located in Gaston County, North
Carolina, four miles southeast of the town of Belmont. The plant began
operations in 1957. The plant site is adjacent to the west bank of Lake Wylie,
an impoundment that is part of the Catawba River Development. At the time of
the study, there were five units at the plant. Electrostatic precipitators were
added to all units between 1965 and 1970. The Appalachian bituminous coal used
for fuel had about one percent sulfur and 12 to 15 percent ash.
The coal ash disposal site at the Allen Plant consisted of two separate,
major units (Exhibit E-3). One unit was the operating or active ash pond, 146
acres in size, which was unlined and dates back to 1973. Combined fly ash and
bottom ash were wet-sluiced to the pond (using waters from Lake Wylie). In
addition, the pond received two types of low-volume wastes: surface runoff from
the power plant (including coal pile runoff) and boiler cleaning wastes.
Significant amounts of copper, nickel, and zinc were added to the disposal pond
during boiler cleaning events. The liquid supernatant from the pond was
discharged untreated into Lake Wylie.^
A second retired ash disposal pond was located immediately north of and
adjacent to the active pond. This 127 acre facility was used from 1957 to 1973
for disposal of fly ash and bottom ash. Part of this pond had been graded,
covered with soil, and seeded.
The igneous bedrock at the site slopes toward the lake and has been intruded
with permeable dikes and sills. These dikes and sills tended to create
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EXHIBIT E-3
DISPOSAL PONDS AND SAMPLING LOCATIONS AT ALLEN SITE
N
ALLEN DISPOSAL SITE
GASTON COUNTY. NORTH CAROLINA
AOL WELLS
SCALE
ACTIVE I
ASH POND I
1197310 Pr*xnt)
RECLAIMED
ASH POND
(I957-IB73I
LAKE WYLIE
0 27S 550
FEET
-------
E-8
drainage paths. Overlying the bedrock was a thick soil layer formed from the
underlying bedrock. This "residual" soil layer ranged from 10 to more than 40
feet in thickness at the site, and was composed chiefly of sand and silt.
Beneath some portions of the site, there were alluvial deposits filled with
loose and permeable material.
The Allen site received an average of 43 inches of precipitation a year.
The net ground-water recharge from precipitation was about 12 inches per year.
In addition, a large amount of ash sluice water entered the pond (approximately
30 times as much water as the total direct precipitation on the active pond).
There were indications that plant discharges into the disposal ponds had created
ground-water mounding in their immediate vicinity and had saturated the vadose
zone. The residual soil and alluvium comprised the aquifer in the vicinity of
the Allen site. Upgradient from the pond, the water table was approximately 30
feet beneath the land surface. Immediately downgradient, it was continuous with
the surface of Lake Wylie. Local surface and ground-water flow was easterly
towards Lake Wylie.
Factors that were considered to be important in the selection of the
combined fly ash/bottom ash disposal operation at the Allen Plant for study
included the following:
The site was located in the Piedmont Region, which
contained significant coal-fired generating capacity;
The practice of pond disposal of combined fly ash and
bottom ash was the most common disposal practice for
these wastes in the United States and virtually the only
disposal practice in the Piedmont Region;
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E-9
The environmental conditions (the amount of
precipitation and the mix of residual and alluvial
soils) were considered typical of many other locations
in the eastern half of the U.S. and are particularly
representative of the Piedmont Region; and
Co-disposal of intermittent, contaminant-rich waste
streams (i.e., boiler cleaning wastes and coal pile
run-off) in ash ponds occurred at Allen Plant and was
also widely practiced at other utility sites.
E.4.1 Sapling Approach
Samples of wastes and soils were collected for physical and chemical
testing. Samples of ground water, waste fluids (or liquors), and ash pond
discharge samples were collected for chemical testing. A series of attenuation
tests were executed using ash pond liquors and local site soils.
AOL installed 18 monitoring wells at the site, of which four were drilled
close together but to different depths. Three wells were intended to be
background (upgradient) ground-water wells, however, two (Wells 3-4 and 3-4A)
were inundated more than once when the pond elevation rose. Thus only one well
yielded representative background ground-water data (Well 3-4B). One
downgradient ground-water well (Well 3-5) was drilled on the south side of the
active pond dike. The other 10 downgradient ground-water wells were located
between the active pond and Lake Wylie. Seven of these downgradient wells were
drilled into the residual soils (Wells 3-5, 3-6, 3-6C, 3-7A, 3-8, 3-9, and
3-9A), one was drilled into alluvium (Well 3-6A), and two were drilled into what
is identified as "fill" (it is unclear what this material is). Four of the
downgradient wells were considered to be "representative" of the site -- Wells
3-6, 3-9, 3-7A, and 3-8.
-------
E-10
One monitoring well was located within the retired ash pond (3-1) and
appears to have sampled waters in and under the older waste. Three monitoring
wells were drilled within the active ash pond. One sampled fluids within the
ash solids (pond liquors, Well 3-2A), one sampled water within the alluvium
under the ash and within the ash (Well 3-2), and one sampled water in the
residual soils under the ash and within the ash (Well 3-3). Fluids from the ash
pond that are discharged into Lake Wylie were also examined (Well 3-13).
Locations of site wells are shown on Exhibit E-3. Wells were sampled for
contaminant concentrations on three dates. The values of and trends in sampling
and analysis results for the site, and comparison of ground-water concentrations
with relevant EPA standards for drinking water are discussed below.
E.4.2 Results
Exhibit E-4 presents the results of chemical sampling at the Allen site.
This includes samples from the downgradient and upgradient ground-water wells,
samples from wells placed within the wastes to collect interstitial waters or
fluids, and water samples obtained from materials beneath the wastes.
Waste Solids. Fly ash and bottom ash wastes in the abandoned pond were
found to be segregated due to different discharge locations. The bottom ash was
found to have a greater permeability than the finer fly ash. No distinct zones
of fly ash and bottom ash were found in the active pond. A range in
-4 -3
permeability of 2 x 10 cm/sec to 4 x 10 cm/sec was found.
-------
EXHIBIT E-4
CHEMICAL SAMPLING RESULTS FOR ALLEN SITE
MIEN SITE
(no Surfict Uitrr diti)
Units > ppi I
POU5
Orinkinj
Contai. Uater
Standard
Arsenic 0.05
Bariui 1
Cadciui ll/ 0.01
Chratiin 0.05
(Cr Ul)
Fluoride 4.0
Lead 0.05
Mercury 0.002
Nitratt 13/ 45
SeltniiM 0.01
(I.,.)
Silver 0.05
SOUS
Chloride 250
Copper 1
Iron 0.3
Hanjanese 0.05
Sultatc 750
Zinc 5
pH Lab U/ <*i.5
>=8.5
pH Field U/ <=4.5
>=8.5
Ground nater
I/
Total Oowfriditiit
(11 Mill)
11 11
Total Exceed. Dai.
Saiplts Saiples Exceed.
12 0
31 0
31 0
31 0
34 0
31 0
0
34 0
5 0
31 0
34 0
31 D
31 7 87
31 11 107
34 0
31 D
1 10 ID 4.7
1
1 10 0
1
1 28 71 4.4
1 28 0
71
Representative' Donntjrad.
(4 nils)
?/ a/
Total Exceed. Mai.
Sawles Saiplcs Eiceed.
7 0
12 0
12 0
12 0
14 0
12 0
0
14 0
4 0
12 0
14 0
12 0
12 3 48
12 5 54
14 0
17 0
4 4 k I
4 D
10 4 S.I
10 D
3/
Upjradient
(1 Hell)
7/ 8/
Total Eiceed. Max.
Samples Samples Eiceed.
2 0
3 0
3 0
3 0
4 0
3 0
0
4 0
2 0
3 0
4 0
3 0
3 0
3 1 1.4
3 D
3 0
1 1 S.V
1 0
3 2 k 7
3 0
Uater In and Under Uaste
4/
Uater Under Active Pond
(2 Dells)
7/ 8/
Total Eiceed. Max.
Saiples Saioles Exceed.
4 0
b 2 1.3
k 0
k 0
7 0
k 0
0
7 0
2 0
k 0
7 0
6 0
k 3 89.7
k k 260
7 0
k 0
2 2 fc.3
7 0
k 7 4.4
k 0
5/
Uater Under Retired Pond
II m")
11 fl/
Total Eiceed. lax
Saiples Saiples E«r«»<<.
2 2 I.I
3 0
3 0
3 0
3 0
3 0
o
3 a
I 0
3 a
3 0
3 D
3 D
3 D
3 0
3 0
1 D
1 1 10.2
3 0
3 3 11.4
Uaste
&/
Pond Liquors
(8 stations)
11 I0/ 8/
Sa.pl fs Ave. Hai.
)Detect. Cone. Exceed.
5 0.55 30. 5
7 0.23
I 0.053 5.3
4 0.014
7 0.7?
0
12/
NS
8 1.4
3 0.0047
0
fl 1
4 0.02&
7 0.02
7 D.l
8 137
1 0.03
12/
NS
12/
MS
I2/
NS
I2/
NS
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EXHIBIT E-4 (Continued)
CHEMICAL SAMPLING RESULTS FOR ALLEN SITE
!/ ilcHs 3-5 (this *e I s saMiSit je-ip^rai t: ?ond). 3-4, 3-4C, 3-7A, 38. 3-9, 3-»A,
3-4A, 3-48. 3-8A, and 3-7.
II Uells 3-9, 3-7Ai 3-t. and 3-B. 'hen Ml s »*r» chosen by ATX as being representative
ol the ddingradient groundMttr
3/ Uell 3-4B.
4/ Wells 3-? till.) and 3-3 Ires.). TKe Hu'di collected at these it I Is arf Iroi beneath the
active ash pond
S/ Uell 3-1. The fluids Iroi thij Mil are tro« beneath tKe retired ash pond.
4/ Stations 3-2 (14-18 It), 3-2 120-22 tt), 3-2 (24-24 It), 3-2 (38-40 It).
3-2* (?4 5-24.4 It), 3-3 (10-12 It), 3-3 (22-24 It), and 3-3 (24-24 It).
'pond liquors' are fluids collected Iroi nitkiri the landlilltd
II The nuiber ol taiplti «itK reported concentration* above the drinking Mter standard
Hi«. Exceed, is the concentration ol the greatest reported enceedance dit/ii
by the drintinj natcr standard lor that particular contaiinant. The only
61 Hi«. Exceed, is the concentration ol the greatest reported enceedance divided I
tiception is lor pH, there Ha>. Enceed. is the actual Masureient.
9/ The nuiber ol "pond liquor* samples »ith reported concentrations above the reported
detection lints. An entry ol "0" indicates that no saiple had a detectable contaiinant
concentration, not that no saiples wre taken (see footnote 13).
10V Ave. Cone, is the averaje ol the reported concentrations ol all "pond liquor"
saiplts taken that showed a contaminant concentration above the detection lint.
The reported pH icasureients ol the "pond liquors" are also averaged.
ll/ Uhere the reported detection I'i't lor cadnui vas greater than the drinking
ater standard and the saiplt contained less contaiinant than the reported detection
lint. th» tuple is tabulated as being be,on thr drinking Mter standard.
For son later saiplts collected Iroi total and 'representative* doingradient groundiater,
upgradient groundnaten and under the active and retired ash ponds, the reported detection
lint ol 0.1 ias greater than the POUS lor cadiiui.
12/ The solubility ol llounde in uater is tarkedly allected by teiperature 01 the teiperature
ranges and corresponding lamiui alloiable contaiinant levels reported for llouride in the NIPUOS,
the range shoin in this table (24 3-32 5 C) corresponds to the tost stringent allowable
a>iiui contaiinant concentration
'3/ MS = not saipled
U/ As indicated in lootnote 8, the Ml» Eiceed. to u»n lor reported pK oeasureients
is a tabulation of the actuai i^asureients, net the lamiui exceedance divided by
the drinking vater standard.
-------
E-13
Waste Fluids. Results from fluid samples collected from wells implanted
within the waste indicate that these fluids or pond liquors, when compared to
Primary Drinking Water Standards, exhibit elevated concentrations of arsenic (up
to 31 times the PDWS) and chromium (up to 2 times the PDWS). Although waste
fluids are not directly ingested, comparison to the drinking water standards are
shown to indicate the potential for contamination at the site.
Observed levels of arsenic in the pond liquors were up to 31 times the PDVS.
Although interpretations to EP (extraction procedure) test results cannot be
readily made, it should be noted that the results of EPA Extraction Procedure
(EP) tests on waste samples from this site indicated much lower levels (about
two orders of magnitude) of arsenic than the elevated concentrations of arsenic
measured in waters from within the ash.
Water samples obtained from in and under the closed ash pond exhibited a
slight exceedance of the PDWS for arsenic. The pH of these samples (as high as
11.4) indicated alkalinity. Water samples obtained from in and under the
active ash pond exhibited a slight exceedance of the PDWS for barium (1.4 times
the PDWS). These samples also exhibited elevated concentrations of iron (up to
90 times the SDWS), elevated concentrations of manganese (up to 280 times the
PDWS), and slight acidity (pH as low as 6.3).
Ground water. Estimates were made of seepage velocities at the site.
Results from these calculations appeared to indicate that there had been enough
time for waste leachate constituents in the eastern (downgradient) portion of
the disposal pond to have reached downgradient wells and Lake Wylie.
-------
E-14
No exceedances of Primary Drinking Water Standards were found in the ground
water of the downgradient wells or the ground water of the upgradient wells.
Secondary Drinking Vater Standards were found to be exceeded in the downgradient
ground water for iron (up to 82 times the SDWS) and manganese (up to 102 times
the SDWS). These contaminants were not observed in the pond liquor samples, but
were the same as those observed in water samples collected in and under the
wastes of the active pond. Downgradient ground water was found to be slightly
acidic (pH as low as 4.4). Secondary Drinking Water Standards were also found
to be exceeded in the upgradient ground water for manganese (up to 1.4 times the
SDWS). The pH also indicated slight acidity (pH as low as 5.9) in the
upgradient ground water.
Surface Water. No surface water samples were collected at this site.
Attenuation Tests. The results of attenuation tests with pond liquor
solutions and site soils indicated that the local soil attenuation capacity for
arsenic was very high (10 micrograms/gram of soil). It appears likely that
arsenic was chemically attenuated by iron and/or manganese oxides which were
found to be present in high levels in the soils under and around the ash pond.
The degree of attenuation was also determined to be high for selenium. The
estimated chemical attenuation of strontium and sulfate was found to be
moderate.
Ash Pond Discharge. Ash pond discharges are discharged directly into Lake
Wylie. Results from sampling are presented in Exhibit E-5. Arsenic was found
to exceed the FDWS (up to 1.25 times the PDWS) in the discharge samples and
manganese was found to exceed the SDWS (up to 1.8 times the SDWS). These
-------
E-15
EXHIBIT E-5
ASH POND DISCHARGE RESULTS FOR ALLEN SITE
ALLEN SITE
(Direct ash Bond discharge into Lake Uylie)
Units >
POUS
>P* ILake Uyl
1
Or i nk i ng
Con tn. Water
Standard
Arsenic
(liq.)
Bar i UP
Cad. i UP
Chroiiui
(Cr VI)
Fluoride
Lead
"ercury
Nitrate 4/
Seleniim
(Im.)
Silver
0.05
1
0.01
0.05
i.O
0.05
0.002
45
0.01
0.05
SOUS
Chloride
Copper
[on
Manganese
Sulfate
Zinc
nH Lab 5/
pH Field 5/
250
1
0.3
0.05
250
5
Total
Sanies
1
2
2
2
2
2
0
2
1
2
2
2
2
2
2
<«».SI 0
1
>*6.5I 0
1
<«4.5I 2
1
>*8.SI 2
1
ie Discharge 1
Discharge
[1 station
21
Exceed.
Sanies
1
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
1
I/ 1
1
1
1
3/1
flax. 1
Exceed. 1
i
1.2 1
1
1
1
1
1
1
1
1
1
i
1
1
|
1
1
1
1
1
1
1
i
1
i
1
1
1
1
I
1.3 1
1
1
1
1
i
1
1
1
1
1
1
8.? 1
1
I/ Station 3-13.
21 TKe nupoer of samlts »ith reported concentrations above the dnninn^ nater stancar
3/ Max. Exceed. 'S the concentration of tSe greatest reported t»ceeoa"c» divided
by the drinking niter standard for that particular contaminant, 'he only
exception is tor oH, htrc lai. Exceed, is the actual leasureient.
kl The POUS for nitrate naiured as N is 10 ppt.
5/ As indicated in footnote 3> the Max. Exceed, coluin for reported prl eeasureients
is a tabulation of the actual Masurnentsi not the laxnue fxceedance divided by
the drinking nater standard.
-------
E-16
samples were also found to be alkaline and in exceedance of Secondary Drinking
Water Standard for pH (pH up to 8.9).
E.4.3. Discussion and Conclusions
At all ground-water sampling locations at the Plant Allen site, levels of
contaminants did not exceed Primary Drinking Water Standards. Some exceedances
of Secondary Drinking Water Standards were noted, including iron at downgradient
wells and manganese at downgradient and upgradient wells. Samples at both
upgradient and downgradient ground-water wells were also found to be slightly to
moderately acidic, with a seeming increase in acidity in downgradient well
samples. In fluids obtained from the pond wastes (pond liquors), highly
elevated concentration levels of arsenic were detected.
It is not clear to what extent migration of waste leachate to downgradient
ground water had occurred. Examination of concentrations for ash solutes such
as sulfate, boron, chloride, calcium, magnesium, strontium, and sodium in
upgradient versus downgradient wells and in pond liquors indicated that these
constituents are present in higher concentrations in pond liquors and in
ground-water wells downgradient from both active and retired ponds than in
upgradient or background ground water. Consequently, this indicates that some
leaching and migration of ash wastes had occurred to the extent that solutes
have reached the downgradient wells. At the time of the study, no serious
degradation of water quality due to ash leaching had occurred. Whether this has
changed or may change in future years is discussed below.
The surrounding soils in the immediate vicinity of the ponds appeared to
-------
E-17
have been able to attenuate the contaminants arsenic and boron, thereby limiting
their downgradient movement. The results of the attenuation tests were
evaluated along with the water balance, geological profile, mass balance and
physical testing data to estimate the potential for long-term leaching of
arsenic from the ash ponds to Lake Wylie. It was estimated that the attenuation
capacity of the surrounding soils would be sufficient to prevent passage of
arsenic leachate with concentrations in exceedance of drinking water standards
into Lake Wylie for longer than the estimated 15 year operating life of the
active pond.
As mentioned previously, it was likely that at the time of the study only
leachate generated in the downgradient (eastern) portions of the ash ponds had
begun to reach downgradient ground-water veil locations, and that leachate
from the upgradient (western) portions had not yet reached downgradient
ground-water wells. This suggests that the downgradient ground water had not
yet reached steady state conditions (or concentrations) with respect to the
movement and admixing of leachate generated by the ponds, since steady state
conditions (i.e., all potential flow paths carrying leachate) would not be
achieved until the whole pond contributes leachate to downgradient locations.
This means that concentrations of contaminants present in leachate of the waste
(pond liquors) could be expected to increase in downgradient ground water over
the next several years. While a precise estimate of future ground-water quality
at the site cannot be made, steady state concentrations may range between
existing concentrations and concentrations typical of ash leachate.
Since Primary Drinking Water Standards contaminants appeared to be either
attenuated by soil at the site or were not present at elevated concentrations in
-------
E-18
Che pond liquors, ground-water degradation by these constituents may not be
expected in the future. If arsenic had not been attenuated by soils at the
site, future concentrations of arsenic in downgradient ground water could have
been as high as 31 times the Primary Drinking Water Standard (the concentration
in pond liquors). Additionally, since the Secondary Drinking Water Standard's
contaminants were not observed to exceed standards in either the pond liquors or
the downgradient wells, significant degradation of the ground-water quality due
to future increases in downgradient concentrations (incremental leachate
impacts) of these contaminants would not be expected.
It has been suggested that the lack of elevated concentrations observed in
the ash pond liquors of elements added to wastes from boiler cleaning wastes
(copper, nickel, zinc) was due to their precipitation upon mixing with pond liquors.
In summary, Allen Plant in North Carolina disposed of a mixture of fly ash
and bottom ash in two onlined disposal ponds, one retired and one in active use.
Intermittent waste streams, such as boiler wastes and coal pile runoff, were
also disposed of in the ponds. While comparisons of concentrations of
waste-related constituents in upgradient and downgradient ground water and in
waste fluids indicated that leachate migration had occurred, exceedances of the
Primary Drinking Water Standards were not found to occur in ground-water samples
(i.e., no significant degradation of ground-water quality). Elevated
concentrations of arsenic (up to 31 times the PDWS) were found in fluids within
the active ash pond. Attenuation tests indicated that these concentrations of
arsenic were chemically attenuated by iron and manganese in the soils beneath
and surrounding the site. Ground-water contamination, particularly from
arsenic, could have resulted if these attenuating soils had not been present.
-------
E-19
Secondary Drinking Water Standards were found to be exceeded in both the
upgradient and downgradient ground water for manganese and in the downgradient
ground water for iron. This was attributed to high concentrations of these
elements present in the soils of the site. ADL calculations of seepage
velocities at the site suggested that it was possible that steady-state
conditions had not been achieved. Increases in downgradient ground-water
concentrations of non-attenuated waste leachate species may be expected in the
future.
E.5 ELRAMA PLANT
The Elrama Power Plant is located in Washington County, Pennsylvania,
approximately 20 miles south of Pittsburgh. At the time of the AOL study, it
had four units and burned Appalachian coal having 2-2.5 percent sulfur and 19
percent ash. Waste disposal methods consisted of wet sluicing bottom ash and
occasionally fly ash to an on-site interim pond. The dewatered contents of the
pond were subsequently excavated and removed to a landfill disposal site. In
1975, limestone scrubbers were added to remove sulfur dioxide from the flue gas.
The FGD scrubber sludge was mixed with dry fly ash and lime to form Poz-0-Tec"
at a processing facility on the power plant site. This fixation step was a
proprietary process. The fixated sludge was then trucked approximately 12 miles
east to the disposal site, in Elizabeth Township, Allegheny County, where it was
placed in a landfill. The plant and disposal site locations are shown in
Exhibit E-6. Disposal of scrubbing wastes at the disposal site began in 1979.
-------
E-20
EXHIBIT E.-6
LOCATION OF THE ELRAMA POWER PLANT AND DISPOSAL SITE
N
P*nn*ylv*n
OSITE
Seil«
024
Mltot
Source: Tetra Tech
-------
E-21
Bottom ash and sludge from a coal pile runoff treatment pond were also disposed
at the landfill. At the time of the study, approximately 1500 tons of waste
were placed in the facility each day.
The disposal site was on a hillside overlooking the Youghiogheny River in
Allegheny County, Pennsylvania. The area of the fill at the time of sampling
was 22 acres. The waste was being disposed on top of coal strip-mine spoils,
and was implanted in a series of terraced lifts. At completion, the outer part
of each Poz-0-Tec lift was covered with about 2 feet of soil and seeded. A
vertical profile through the disposal site is shown in Exhibit E-7. Unlined
sedimentation ponds at the foot of the landfill collected surface runoff from
the waste fill. The westernmost pond had an overflow discharge to the river.
The bench that the landfill was located on was created by mining of the
Pittsburgh coal seam. Beneath this bench, the sedimentary bedrock was overlain
by floodplain deposits of aluminum (silts and sands) up to 40 feet thick. Under
much of the waste, the bedrock was covered by a five to ten feet thick layer of
soil and weathered rock ("residual soil"). In the westernmost part of the
landfill, alne spoil materials left from previous strip coal mining operations
underlay the Poz-0-Tec wastes. The spoil material was an unconsolidated mix of
soil, coal wastes, and bedrock fragments. Leachate from the mine spoils was
noted by the site operators as being acidic.
The average annual precipitation at the Elrama site was 38 inches. The
water table at the Elrama site sloped steeply from southeast to northwest,
-------
EXHIBIT E-7
en
o
l-l
o
(0
VERTICAL PROFILE THROUGH LANDFILLED WASTES
AT ELRAMA DISPOSAL SITE
(FROM THE SOUTHEAST TO THE NORTHWEST)
H
»
r»
-J
0>
H
»
O
900
700
200
400 600 800 1OOO
HORIZONTAL DISTANCE (feat)
120O 1400
-------
E-23
roughly parallel to the ground surface. Most of the mine spoil material was
saturated during the period of the ADL study. The saturated zone extended up
into the lower portions of the Poz-0-Tec fill. Ground-water levels varied
considerably with the site topography, being relatively deep in the bedrock at
the higher site elevations and varying from 20 to 30 feet below ground surface
in the low lying alluvial deposits. All surface and ground-water flow was
northwesterly to the adjacent Youghiogheny River (Exhibit E-8).
Factors that were considered important in the selection for study of the
fixated FGD waste landfill operation at the Elrama disposal site included:
Fixated FGD waste landfilling was available for study at
very few sites in 1980; however, this disposal option
was planned for many other locations in the United
States. The type of fixation practiced at Elrama was
based on controlled mixing of FGD combustion waste from
a thick slurry to a highly alkaline, soil-like material.
This process makes landfill disposal a practical
alternative to pond disposal.
Landfill disposal of FGD wastes in abandoned strip mines
was also a growing practice at the time of the study.
The Elrama landfill site occupied an abandoned coal
mining area that exhibited acid mine drainage. This
situation represented an opportunity to fill a
significant data gap on highly alkaline waste disposal
in a typical acid mine drainage setting.
Climatic conditions (average rainfall, temperature range
and typical frost penetration) was considered
representative of the Appalachian Region.
There was generally good ground-water flow expected in
this setting.
Alluvium underlying the disposal area was anticipated to
provide a good monitoring medium.
-------
E-24
EXHIBIT E-8
GROUND-WATER FLOW DIRECTIONS AT ELRAMA
DISPOSAL SITE
N
INFERRED FLOW DIRECTIONS
EST. HORIZONTAL SEEPAGE VEL. 5/25/81
SCALE
0 200 400
FET
K ft/day
2.2
2.2
I ft/ft
27/272
4/336
P
0.3
0.3
V5 ft/yr
265
30
Under landfill
Between landfill
and river
Source: Tetra Tech 1985.
-------
E-25
The landfill was in close proximity to surface water (Youghiogheny
River), although it was separated from the river by runoff
collection ponds.
E.5.1 Sapling Approach
Samples of wastes and soils were collected for physical and chemical
testing. Samples of ground water, waste fluids (or liquors), and surface water
samples were collected for chemical testing. A series of attenuation tests were
performed using local site soils and pond liquor solutions (spiked with trace
elements).
Sixteen monitoring wells and three lysimeters were installed at the site.
One upgradient ground-water well (Well 1-14) was installed in the alluvial
floodplain for background monitoring purposes, and one upgradient ground-water
well (Well 1-2) was installed within the mine spoil debris. Following site
development and the sampling visit, fixated FGD waste was disposed adjacent to
and upgradient of well 1-2. Five downgradient observation wells (1-11, 1-8,
1-10, 1-4, and 1-5) were installed in the alluvial flood plain deposits of the
Youghiogheny River. Observation wells (1-6, 1-13, 1-12, 1-15, 1-9, 1-3, 1-6A
and 1-15A) and lysimeters (1-6, 1-13A, and 1-12A) were installed in the lower
benches of the compacted waste fill to sample waters from beneath and within
the wastes. The lysimeters were installed in the unsaturated vadose zone
beneath the waste fill deposit to provide interstitial water samples which had
not been in contact with any mine spoil leachate. In addition, surface water
samples were collected from five sampling stations in Youghiogheny River - -
four downgradient (downstream) and one upgradient.
-------
E-26
Locations of site wells and surface water sampling locations are shown on
Exhibit E-9. Sampling at the site was conducted on three occasions.
E.S.2 Results
Exhibit E-10 presents the results of chemical sampling at the Elrama site.
This includes samples from the downgradient and upgradient ground-water wells,
samples from the well and lysimeters implanted within the waste to collect
interstitial fluids, water samples obtained from beneath the waste, and surface
water samples. Results are discussed below.
Waste solids. Fly ash and bottom ash were found to occur in layers within
the waste. Coefficients of permeability ranged from 7 x 10" cm/sec to 1 x
10 cm/sec.
All three wastes disposed at the site, fixated (with lime and fly ash) FGD
waste, bottom ash, and mine spoil, were chemically analyzed. Calcium was found
to be present at much greater levels in the fixated waste than in the mine
spoil. Sulfate and aluminum concentrations were found to be high in the mine
spoil and the FGD waste. However, sulfate was noticeably higher in the FGD
waste. Arsenic was detected at significantly higher concentrations in the FGD
waste than in the other materials. Additionally, the FGD waste was found to be
highly alkaline and the mine spoil acidic.
Fluids In and Beneath Waste. Fluid samples collected from the
on-site waste may represent leachate from these wastes, so that examination of
-------
E-27
EXHIBIT K-9
SAMPLING LOCATIONS AT ELRAMA DISPOSAL SITE
UPPER BENCH
AT TIME OF
AOL SAMPLING
MARCH 1M1
UNOERORAIN
FROM MINE SPOILS
9010
AOL WELLS
O UTILITY WELLS
» SURFACE WATER SAMPLING STATIONS
I""! EMBANKMENT
EXTENT OF LAST
BENCH WHEN
SITE FILLED
SCALE
200 400
FEET
Source: Tetra Tech 1985.
-------
EXHIBIT E-10
CHEMICAL SAMPLING DATA FOR ELRAMA DISPOSAL SITE
EIRNM SITE
(no Pond Liquor data)
Units - PP«
POUS
Orinkini
Contai. Uater
Standard
Arsenic O.OS
(In >
BariiM 1
Cadaiue f/ 0.01
Chroiiiw O.OS
(Cr VI)
Fluoride 4.0
Ltid 0.05
Mercury 0.002
Nilritf 10/ 45
Seleniui 0.01
(liq.)
Silver O.OS
SOUS
_ .
Chloride 250
Copper 1
Iron D.3
Manganese O.OS
SuHitt 250
Zinc S
pH lib \\l <=o.S
>>B.5
PH field ll/ (=4.5
>=8.5
Ground Mter
I/
Domijradient
(S Mils)
11 fl/
Toul Exceed. Hai.
Saiplei SUP lei E>ceed.
1 0
If 0
If 3 20
\1 1 1.2
21 0
IT 0
D
20 0
1 0
1? 0
21 0
\1 0
If 0
If 11 454
If f 4.7
If 0
0
1 0
1 14 f 5.2
14 0
2/
Upjradient
(1 Mil)
11 61
lotal Eiceed. Man.
Suples Sacples Exceed.
2 0
4 0
4 0
4 0
4 0
4 0
0
4 0
2 0
4 D
4 0
4 0
4 1 1.6
4 4 If?
4 3 I.S
4 0
0
0
2 2 4.5
2 0
In and Under Uaste
3/
Uater In and Under Uaste
(11 Mils)
11 61
Total Eiceed. Mai.
Sae.pl es Saiples Exceed.
13 2 5.3
33 0
33 f 20
33 0
32 0
33 0
0
32 0
13 0
33 0
31 11 2.3
33 0
33 7 221
33 22 444
33 33 B.I
33 0
D
0
17 10 5.f
17 3 f.f
4/
Uater in (line Spoils
(I Mil)
11 61
Total Eiceed. Ibi.
Suples Sacples Eiceed.
2 0
4 0
4 2 20
4 1 14
4 0
4 0
0
3 0
2 0
4 0
4 0
4 0
4 3 570
4 4 fc80
4 4 f.3
4 a
0
0
3 2 5.1
3 0
Surface Uater ( rough logheny
S/
Ooiingradient
(4 stations)
11 61
Total Eiceed. Hai.
Saiples Suples E
OO
-------
EXHIBIT E-10 (Continued)
CHEMICAL SAMPLING DATA FOR ELRAMA DISPOSAL SITE
I/ Uells l-ll. 1-8 in It), l-fl (iO It). 1-10 (34 It). 1-10 (37 It). 1-4 (B It), 1-i 128 It).
1-4 111 It), and 1-5.
21 Utll 1-14.
31 Uells 1-3. 1-15*. 1-13*. 1-12*. 1-7. 1-4 (SI It), 1-4 (52 It). 1-4 (55 It). 1-13. 1-12, 1-15.
1-f, 1-4* (52 It), and 1-4* (50-55 It). lysittteri wre used t drinkin* «attr ttandard lor that particular contaiinant. The only
nctption ii lor pH, nh(r( Ha>. Eicftd. it tht actual naturncnt.
?/ Uktrt tkt riporttd dcttction liiit lor cadtiui nat jrtattr than tK« drinkint Cn
attr standard and tht sa*plt containtd lets contaiinant than th* rtporttd detection jV,
liiit. the satplt is tabulated as bfinj beln tKe drinkinj natrr standard. ^
For so»e yater saiples collected Iron dovniridient and upqradient iroundMter. the
reported detection lint ol 0.1 «as jreater than the POUS lor cadiiui.
IO/ The solubility of llouride in later is Mrkedly allected by tenperature. 01 the teiperature
ranje> and corresponding Hiiiu* aMoMble contaiinant levels reported for fouride in the NIPOUS.
the ran»e shoin on this table (24.3-32.5 C) corresponds to the lost stringent alloiable
aiiiin contaiinant concentration.
w
\\l As indicated in iootnote 7, the Ho. Enceed. coluin lor reported pH nasureients
is a tabulation of the actual leasureients. not the laiiiui eiceedance divided by
the drinkinj nater standard
-------
E-30
results from chemical analysis of these samples can yield information on the
potential for ground-water contamination.
Waters collected from materials beneath and within the wastes (utilizing
monitoring wells and lysimeters) exhibited an exceedance of the Primary
Drinking Water Standards for arsenic (up to 5 times the PDWS), cadmium (up to
20 times the PDWS). Exceedances of Secondary Drinking Water Standards were
noted for chloride (up to 2 times the SDWS), iron (up to 221 times the SWDS),
manganese (up to 466 times the SDWS), and sulfate (up to 8 times the SDWS).
Exceedances were also noted for pH (as low as 5.9 and as high as 9.9).
Waters collected from within mine spoil debris beneath the waste exhibited
exceedances of the Primary Drinking Water Standards for cadmium (up to 20 times
the PDWS) and chromium (up to 2 times the PDWS). These samples exhibited
exceedances of the Secondary Drinking Water Standards for iron (up to 570 times
the SDWS), manganese (up to 680 times the SDWS), and sulfate (up to 9 times the
SDWS). Values for pH indicated acidity (as low as 5.1).
The fluids collected from within and beneath the waste are not ingested;
comparison to drinking water standards were done to indicate the potential for
contamination at the site.
Ground water. Because of runoff transport, contaminants were expected to
migrate from the wastes to the downgradient alluvium and eventually to the
river relatively quickly by the runoff and seepage directed to the ponds and
subsequent recharge to the alluvium. Ground-water travel times from the
landfill to downgradient well locations were uncertain, but appeared to range
-------
E-31
from one to five years for near downgradient locations and from five to ten
years for far downgradient locations. Travel time from the runoff collection
ponds to far downgradient locations were in the one to five year range. Thus
it would appear that there had been enough time for constituents in waste
leachate to have reached downgradient wells and the Youghiogheny River.
However, there had also probably been ample time and opportunity for acid
drainage from earlier mining operations to have infiltrated the site's ground
water. Because the fixated waste had been at the site for only about 2 years
at the time of sampling, solutes in leachate from the waste may not have
reached wells furthest downgradient.
Primary Drinking Water Standards were found to be exceeded in the ground
water of the downgradient wells for cadmium (up to 20 times the PDWS) and for
chromium (up to 1.2 times the PDWS). There were no upgradient exceedances in
ground water of the Primary Drinking Water Standards.
Secondary Drinking Water Standards were found to be exceeded in the
downgradient ground-water wells for manganese (up to 456 times the SDWS) and
sulfate (up to 5 times the SDWS). Exceedances for these contaminants were also
found in upgradient ground water -- manganese at up to 197 times the SDWS and
sulfate at up to 1.5 times the SDWS. Additionally, iron was found to exceed
the Secondary Drinking Water Standards (1.8 times the SDWS) in the upgradient
well. Both the upgradient and downgradient ground-water wells were found to
exhibit pH's below the lower limit (6.5) for Secondary Drinking Water
Standards. The pH of the upgradient samples were found to be as low as 4.5,
and those of the downgradient samples as low as 5.2.
-------
E-32
Surface Water. Primary Drinking Water Standards were not found to be
exceeded for any contaminants in both the upgradient and downgradient surface
water (river) samples. Secondary Drinking Water Standards were found to be
exceeded for manganese in both the downgradient (7 times the SDWS) and
upgradient (4 times the SDWS) surface water samples. Both the downgradient and
upgradient surface water samples exhibited pH values below the lower limit of
Secondary Drinking Water Standards (as low as 6.0).
Attenuation Tests. Attenuation tests using various pond liquor solutions
and the soils obtained from the Elrama site indicated that these soils
generally had moderate capacities to attenuate trace metals.
E.5.3 Discussion and Conclusions
Cadmium (up to 20 times) and chromium (up to 1.2 times) were found to
exceed the Primary Drinking Water Standards in downgradient ground water.
Manganese and sulfate were observed to exceed Secondary Drinking Water
Standards in downgradient and upgradient ground water. Exceedances for iron
were also observed in upgradient ground water. Elevated concentrations of
arsenic, cadmium, chromium, and fluoride were observed in waters obtained from
within and beneath the landfilled FGD wastes. Chloride, iron, manganese, and
sulfate were observed at elevated concentrations in waters in and under the
waste.
These results and their implications to FGD waste disposal and ground water
quality at the Elrama disposal site are difficult to interpret due to the coal
mining activities that had taken place -- and subsequent acid mine drainage
-------
E-33
that was occurring --at the site. Interpretations of the results that can be
made are discussed below.
Based on sampling results, differences in concentrations between background
or upgradient ground water, mine spoil leachate and FGD waste leachate, were
observed to occur. Background waters were typically neutral or acidic or
alkaline (alkalinity up to 5 meq/1), and had low to moderate levels of iron and
manganese and low levels of total salts. Mine spoil leachate was neutral to
acidic and had high levels of iron and manganese relative to background
concentrations. Samples taken from fluids within the Poz-0-Tec FGD waste were
found to be different from both of these two types of samples. It was neutral
to alkaline, high in dissolved solids (or solutes), but low in iron and
manganese, and arsenic and selenium were found to be concentrated in
interstitial waters. Boron mean levels were higher in both types of waste
interstitial waters than in the background samples.
All wells at the site, except the lysimeters screened in the FGD wastes,
were potentially affected by both leachate from the FGD wastes and from the
mine spoil. Both water quality and the water table configuration indicated
that the upgradient background well (1-14) was influenced by mine spoil
leachate or coal seam seepage. High pH (7.9 to 9.9) characterized ground water
samples directly associated with the alkaline fixated FGD waste. As mentioned
previously, neutral to low pH (4.5) characterized the background ground-water
samples. Low pH was also found to characterize some of the downgradient
ground-water samples. For both the background (upgradient) and downgradient
samples this was very likely the result of acid mine drainage in the area. The
western portion of the site exhibited the highest downgradient solute
-------
E-34
concentrations. This observation was consistent with the higher permeabilities
measured in the area, plus the fact that the disposal area of FGD wastes and
mine spoils was closer to the downgradient wells here than in areas to the
north.
The high levels of arsenic observed within the interstitial water or
leachate of the FGD waste were not observed in downgradient ground water.
Thus, it appeared that arsenic was being attenuated by the surrounding soils.
High levels of arsenic were not evident in waters attributable to mine spoil
leachate.
Iron and manganese concentrations were elevated at many locations. The
iron concentration was especially high in ground-water samples affected by
FGD-related wastes, while manganese levels seemed highest in samples more
affected by mine drainage. Nonetheless, even the least contaminated ground-
water samples showed levels of these constituents that exceeded the Secondary
Drinking Water Standards. This may suggest that the concentrations of these
constituents were characteristically high in ground water in the area, and both
mining and FGD wastes are likely contributing to incremental elevations.
Concentrations of some major FGD waste constituents (e.g., sulfates)
appeared generally elevated at this site, prior to its use for utility waste
disposal, as a result of acid mine drainage. This is illustrated by the
similar concentrations evident in lysimeters and wells downgradient of the
landfill and within ground water downgradient of mine drainage.
The data did not indicate a measurable effect of the landfill on the water
-------
E-35
quality of the Youghiogheny River. Surface water results indicated that the
river was diluting migrating leachate.
The trends in contaminant concentrations over the sampling period indicated
that ground water at several downgradient locations had not yet reached
steady-state concentration and was only beginning to be affected by the
landfill. The effects can be expected to increase over time. Even in the
future, there may be little basis for qualitative distinction between the
ground water affected by the fixated FGD waste and acid mine drainage at the
site, and the influence of projected steady-state ground-water concentrations
for many contaminants may be small in magnitude in an already contaminated
situation. However, results from sampling at the Elrama site indicated that
the FGD wastes had been, and may have continued to be, a source of
contamination for some constituents at the site This may be especially true
for the observed cadmium contamination, since the source for this trace metal
was probably less likely to be the mine spoils (overburden) than the utility
wastes.
In summary, the Elrama Plant in Western Pennsylvania disposed of fixated
FGD sludge-fly ash mixture (known as Poz-0-Tec) along with small volumes of
bottom ash and sludge from coal pile runoff treatment ponds, in an abandoned
coal-mining area twelve miles from the plant. Part of the landfill was
underlain by acid-producing spoils from the strip mining of coal. Cadmium was
found to exceed the Primary Drinking Water Standards in downgradient ground
water by as much as 20 times, especially in the well closest to the landfill.
Steady-state conditions did not appear to have been achieved at the site, so
that effects of leachate from the landfill may have increased with time.
-------
E-36
Certain Secondary Drinking Water Standards (for pH, manganese, sulfate, and
iron) were found to be exceeded in both upgradient and downgradient ground
water at the site. These exceedances probably occurred because of
characteristics of the disposal area and because ground water was already
contaminated from acid mine drainage. Results did not indicate a measurable
effect by the landfill on the water quality of the Youghiogheny River.
Among the trace metal species, arsenic, in water collected from the waste
deposit, was often detected at levels three to five times the Primary Drinking
Water Standards, but appeared to be attenuated by site soils. Arsenic could be
of concern if it were not attenuated by surrounding soils or diluted before
reaching drinking water.
Results from sampling at the Elrama disposal site indicated that the fixated
FGD wastes had been a contamination source at the site. Due to the
contamination of the water by acid mine drainage, the FGD leachate may have had
a small incremental impact on water quality.
E.6 DAVE JOHNSTON VLART
The D«ve Johnston Power Plant of Pacific Power and Light Company is located
approximately 30 miles east of Casper, Wyoming. The plant and its ash disposal
facility are located on the north bank of the North Platte River. The plant has
been in operation since 1959. At the time of the study, the subbituminous coal
burned was from the Powder River Basin of Wyoming and had about 0.45 percent
sulfur and 9 to 11 percent ash. Three of the generating units were equipped
with electrostatic precipitators, and fly ash from these units was transported
-------
E-37
in dry form to several landfills. The fourth unit had a wet ash scrubber, and
fly ash from it was disposed in ponds north of the power plant.
There were a number of disposal areas at this site (Exhibit E-ll). The ADL
study only investigated a site east of Sand Creek. Two major ash disposal
areas, reflecting different times and methods of placement, were assessed. One
was the existing and operational dry fly ash disposal site and municipal
landfill. The other, to the southeast, was an unlined, abandoned, and reclaimed
ash disposal site. The operational fly ash disposal area was excavated into the
natural sand deposits. No liner was placed in the excavation which was in close
proximity to the ground-water table. There were several other closed ash
landfills at this site, which were estimated to be 10 to 20 years old.
The Dave Johnston Plant was selected for study primarily because it provided
the opportunity to evaluate landfill disposal of dry fly ash. Other factors
that were considered to be in the selection and evaluation of the landfilling
operations at the Dave Johnston Plant included the following:
The environmental setting combined significant net
evaporation with a flood-plain location that would be
expected to illustrate contaminant migration in
identifiable patterns, while exemplifying arid western
conditions.
Active and inactive landfills were available for study in
the selected portion of the site. These landfills have
been developed over about a 20-year period.
-------
E-38
EXHIBIT E-ll
LOCATION OF DISPOSAL AREAS AT DAVE JOHNSTON SITE
RETIRED ASH
DISPOSAL SITE
UNIT 4
ASH PONDS
SAND CREEK
(Dry WMh)
ADDITIONAL RETIRED ASH
DISPOSAL SITES
SITE UNDER
NORTH
PLATTE
RIVER
BOTTOM
ASH PONDS
RETIRED ASH
DISPOSAL SITES
ACTIVE ASH DISPOSAL
SITE
PLANT
WATER SUPPLY
RESERVOIR
Source: Tetra Tech 1985.
-------
E-39
The disposal operation was considered to be representative of
existing and future operations at many western locations. At
the active landfill studied, dry fly ash was disposed of along
with small amounts of miscellaneous plant trash, a practice
characteristic of western plants.
The environmental assessment carried out at this plant focused on the effect of
fly ash landfill disposal on downgradient ground-water quality in an arid
floodplain environment.
The Dave Johnston site was located in an arid area. The mean annual
precipitation in the site vicinity was only 12 inches. The majority of the
precipitation was lost through evaporation. Nearly all recharge to the ground-
water system occurred during spring runoff. The area was underlain by bedrock
of shales with interbedded sandstones and thin coal units. The bedrock was
overlain by sand and gravel river terrace deposits and alluvial sediments. Sand
dunes were common throughout the site area. Ground water was found within the
site area in two different and separate hydrogeological environments -- in a
deeper bedrock aquifer and in the near-surface unconsolidated fluvial deposits.
The ground water flowed generally southeast across the active disposal site and
south under the retired landfill (see Exhibit E-12) towards the adjacent North
Platte River. At the closed landfill, located to the southeast of the active
landfill, the distance between the base of the ash and the water table was about
10 feet. The active landfill was excavated to within a foot or less of the
water table.
-------
E-40
E.6.1 Sampling Approach
Samples of wastes and soils were collected for physical and chemical
testing. Samples of ground water and fluids from within the waste (pond
liquors) and beneath the waste were collected for chemical testing.
Twelve monitoring wells were installed at the site. Their locations are
shown in Exhibit E-13. Two were installed to sample upgradient ground water
(7-5 and 7-11), three were installed to sample ground water peripheral to the
disposal areas, three were installed to sample downgradient ground water (7-4,
7-6, and 7-9), and one was installed to sample ground water between the active
and inactive ash landfills (7-12). One monitoring well was emplaced in each of
the ash landfills to sample water from beneath these wastes (7-2 and 7-3) and
one was emplaced within the active ash landfill to sample interstitial waste
fluids (pond liquors -- 7-2A).
E.6.2 Results
Exhibit E-14 presents the results of chemical sampling at the Dave Johnston
site. This includes samples from the downgradient and upgradient ground-water
wells, fluids samples from within the wastes, and water samples obtained from
beneath the waste. Results are discussed below.
Waste Solids. Fly ash was found to be layered with bottom ash in the active
ash landfill. Permeability of the waste was found to range between 2 x 10 to
6 x 10" cm/sec.
-------
E-41
EXHIBIT E-12
GROUND WATER FLOW DIRECTIONS AT DAVE JOHNSTON SITE
INFERRED FLOW DIRECTIONS 5/TO/81
EST. HORIZONTAL SEEPAGE VEL. V, -
KH/MC
6.8J10-*
&««-«
6JXM-*
I H/ft
9/WOO
a/i3oo
9/1375
Vfeft/yr
OJS
0.2S
OJS
Source: Tetra Tech 1985.
-------
E-42
EXHIBIT E-13
DISPOSAL AREAS AND SAMPLING LOCATIONS AT DAVE JOHNSTON SITE
DAVE JOHNSTON DISPOSAL SITE
CONVERSE COUNTY. WYOMING
A
.'. \
SAMPLING STATION
£/J ASH DISPOSAL AREA UNOf R
'-* CONSTRUCTION
IP ACTIVE ASH DISPOSAL AREA
GD RECLAIMED ASH DISPOSAL AREA
BOUNDARY OF
EXCAVATED AREA
0 250 SOO
FEET
Source: Tetra Tech 1985.
-------
EXHIBIT E-14
CHEMICAL SAMPLING RESULTS FOR DAVE JOHNSTON SITE
OAVE JOHNSTON SITE
(no Surllcl Uattr data)
Unit* ppi
POUS
Or ink in)
Contu. Uattr
Standard
jrltnic 0.05
(lil.)
Bar ill* 1
CadtiiM 0.01
CHroiiui O.OS
(Cr VI)
Fluoridi 4.0
Liid O.OS
her cur x 0.002
Hitratt ll/ 4S
Stltnim 0.01
His.)
SiUtr O.OS
SOUS
CMoridt 2SO
Copptr 1
Iron 0.3
flantantst O.OS
Sullatt 2SO
Zinc S
pH Lab 12/ <«6.5
>=B.S
pH Fuld 12/ <*t.S
>=fl.S
Ground (Mttr
I/
Dmnjraditnt
(3 Milt)
kl 11
Total Encttd. Nan.
Saiplts Saiplts Excttd.
2 0
V 0
9 6 3
1 0
12 0
9 0
0
12 0
2 0
V 0
12 D
9 0
9 0
1 I 3.2
12 12 S.6
1 0
1 0
0
1
1 1 0
1
9 D
21
Upjr'ditnt
(2 Ml It)
kl 11
Total Excttd. Hat.
Saw It* Saiplts Eicnd.
3 0
k 0
6 3 3
& 0
B 0
B 0
0
B 0
3 0
9 0
a o
k 0
k 0
6 1 4.B
6 4 S.I
k 0
0
0
6 0
b D
3/
Bin. Act ivtl Inactive Arta
(1 Mil)
kl 11
Total Eicnd. Na>.
Saipltt Saipln Excttd.
0
3 0
3 2 3
3 0
4 0
3 0
0
4 0
0
3 0
4 0
3 0
3 0
3 0
4 4 S.I
3 D
0
D
3 0
.
3 0
Undtr Uaiti
4/
Uattr Undtr Uaitf
(2 Mils)
kl 11
Total Eutcd. Han.
Saipltt Saiplcf Excttd.
4 0
k 0
4 4 3
& 0
B 0
6 0
0
B 0
4 0
k 0
B 0
4 D
k 0
k 3 B.4
B B k.2
6 D
D
0
6 0
A 0
Uaite
5/
Pond Liquors
(2 stations)
B/ 11 11
Saiplrf Avt. Hat.
>D(ttct. Cone. Excttd.
NS ll/
1 0
2 2 S
0
1 1
0
ID/
NS
0
ID/
NS
0
2 D
1 0
2 0
2 1 1
2 2 9.B
2 0
10/
NS
10/
NS
10/
NS
1Q/
NS
tn
i
u>
-------
EXHIBIT E-14 (Continued)
CHEMICAL SAMPLING RESULTS FOR DAVE JOHNSTON SITE
I/ Uells 7-4, 7-4, jno 7-9.
21 Uells 7-5 and 7-11.
3/ Uell 7-17. This tell 14 located between tht active and inactive ash landfills.
*/ Veils 7-2 and 7-3, but not 7-2A. The fluidt collected Iroi these tells ire groundiater
troi beneath the vaste.
S/ These "pond liquors* are lluidt collected fro* iiitKin and on top ol the landlilled Mites
at station 7-2A
hi The nutber o< tuples >ith reported concent ration above the drinking vater ttandard.
// IUi. Enceed. is the concentration ol the (reatest reported oceedance divided
bx the drinking Mter standard lor that particular contaiinant. The only
eiception is (or pH, nhere Nai. Eicced. is the actual Matureunt.
8/ Tie nuibrr ol "pond liquor' saiples nith reported concentrations above the reported
detection Inns An entry ol "0" indicates that no saiple had a detectable contuinant
concentration) not that no saiples nere taken (see footnote 10).
II Ave. Cone, is the average ol the reported concentrations ol all "pond liquor* ,
saiples taken that shooed a contaiinant concentration above the detection I int. £*
The reported pH leasureients ol the "pond liquors" are also averaged.
10/ NS - not saipled.
ll/ The solubility ol llouridr in nater is urkedly affected by teiperature. 01 the teiperature
ranges and corresponding uniiui allovable contaiinant levels reported for llouride in the NIPOUSi
the range shewn on this table (76.3-37.5 C) corresponds to the iost stringent allonable
oiiui contaiinant concentration.
I?/ As indicated in footnote t> the Hai. Eiceed. coluin for reported pH ieasur»ents
is a tabulation of the actual leasureientsi not the ia>iiui exceedance divided by
the drinking later standard.
-------
E-45
Waste From In and Under Wastes. Results from fluid samples collected from
wells emplaced within the waste indicated that these fluids or "pond liquors,"
when compared to Primary Drinking Water Standards, exhibited elevated
concentrations of cadmium (up to 5 times the PDWS). Comparison of pond liquors
to Secondary Drinking Water Standards showed elevated levels of manganese (up to
1 times the SWDS), and sulfate (up to 10 times the SWDS). No analyses were
conducted for arsenic.
Water samples obtained from under the waste showed exceedances of the
Primary Drinking Water Standards for cadmium (up to 3 times the PDWS). These
samples also exhibited elevated concentrations of manganese (up to 8 times the
SDWS), and sulfate (up to 6 times the SDWS).
Ground Water. Seepage velocities at the site were estimated to be only five
to eight feet per year, due to the arid climate . This suggests that because
the landfills had been in operation for less than 10 years, there may not have
been enough time for waste leachate to have reached the downgradient wells.
However, the active landfill was constructed in an excavation that may have
intersected the underlying water table. This may have allowed contaminant
migration via direct contact between the bottom of the fill and the ground
water.
Primary Drinking Water Standards were found to be exceeded in the ground
water of the downgradient wells for cadmium (up to 3 times the PDWS). Cadmium
was also found to exceed the PDWS in the waste fluids and in waters from beneath
the waste. Upgradient exceedances of the Primary Drinking Water Standards in
ground-water samples were also found for cadmium (up to 3 times the PDWS).
-------
E-46
Secondary Drinking Water Standards were found to be exceeded in downgradient
ground water for manganese (up to 3 times the SOWS) and sulfate (up to 6 times
the SDWS). These are the same contaminants observed at concentrations greater
than Secondary Drinking Water Standards in the pond liquors and waters from
beneath the waste. Upgradient exceedances of the Secondary Drinking Water
Standards in ground-water samples were also observed for manganese (up to 4.6
times the SDWS) and sulfate (up to 5 times the SDWS). The ground-water well
installed between the active and inactive waste landfills was observed to
exhibit exceedances of drinking water standards for the same constituents
observed in upgradient and downgradient ground water wells and at similar
concentrations -- cadmium (up to 3 times the PDWS), and sulfate (5 times the
SDWS) -- with the exception that no exceedance was observed of manganese.
Surface Water. No surface water samples were collected at the site.
Attenuation Tests. Attenuation tests conducted using background soils at
the site showed the soil to have low attenuative capacities for a variety of
trace metals, especially arsenic.
E.6.3 Discussion and Conclusion
All ground-water sampling conducted at the Dave Johnston site (both
upgradient and downgradient) indicated levels of cadmium in exceedance of
Primary Drinking Water Standards. Cadmium was also observed at elevated
concentrations within and beneath the wastes. Secondary Drinking Water
Standards were exceeded for manganese and sulfate in both upgradient and
-------
E-47
downgradient ground water, and in fluids obtained from within and beneath the
wastes of the disposal areas.
These results did not indicate whether migration of waste leachate to
downgradient ground water had occurred, or whether the observed contamination
was caused by a source other than the ash wastes. Other site information that
can aid in interpretation of results at site are discussed below.
The estimation that leachate from the active waste area may not have reached
downgradient wells by the time of sampling would suggest that there may have
been other contamination sources besides the active disposal area. However, it
may be possible that wastes had been in direct contact with the ground water,
allowing for a considerable increase in the velocity of contaminant migration.
Outside of exceedances of drinking water standards, there did appear to be a
general increase downgradient in ground-water concentrations of major ash
constituents (e.g., chlorine, magnesium, sodium, silicon, and sulfate). These
increases may be attributable to natural mineral weathering (as discussed
below), or may be due to the effects of ash disposal.
Weathering of the mineralized soils at the site, in conjunction with the low
ground-water velocities in this area, may have allowed natural solute pickup as
ground water moved across the site toward the North Flatte River. This pickup
added to the difficulty of distinguishing the effects of waste leachate from the
natural increases in downgradient solute concentrations. However, in wells
screened below the disposal areas, it appeared that waste leachate had caused
increases in solute concentrations (e.g., chlorine, sulfate, etc.). In wells
-------
E-48
further downgradient from the disposal areas the effect of waste leachate were
difficult to distinguish.
Interpretation of results from the Dave Johnston site was difficult due to
its complex hydrogeologic regime and the many waste disposal locations of
varying ages at the disposal site, including the two disposal areas studied.
The actual location of the closed ash disposal sites was uncertain. These old
disposal areas were probably located upgradient from the retired ash pond and
may have also been upgradient of the active ash pond. Thus, leachate from past
disposal activities, instead of weathering of soils, may have been the cause of
upgradient contamination of ground water.
Leachate from the wastes may have eventually reached downgradient ground
water and the North Platte River. If the ground-water contamination observed at
the site was attributable to waste disposal, this contamination can be expected
to increase as leachate reaches steady-state concentrations. It is also
probable that, at least for the observed contamination by cadmium, the
ground-water contamination may have been due to the ash wastes areas, active or
closed, present at the site.
It should be noted that arsenic, which was found in elevated concentrations
within waste fluids from the other ADL sites, was not tested for at this site.
This information on arsenic would have been useful to contrast its concentration
in the waste fluids with the low chemical attenuation observed for the soils of
this site.
In summary, the Dave Johnston plant in Wyoming was located in an arid region
-------
E-49
with little ground-water recharge. The plant was relatively old and burned low
sulfur western coal. There were a number of disposal areas at the site. The
AOL study investigated two landfills southeast of the site, an active one and a
closed one. These landfills were unlined and used for fly ash disposal.
Exceedances of the Primary Drinking Water Standards were found in ground water
upgradient and downgradient of the site for cadmium (up to 5 times the FDWS).
These were the same contaminants found at elevated concentrations in waters
within and beneath the wastes. Exceedances of Secondary Drinking Water
Standards were observed in downgradient and upgradient ground water for
manganese and sulfate. Both of these contaminants, along with boron, were found
in elevated concentrations in waters beneath and within the waste. No samples
were analyzed for arsenic in the waste fluids. Chemical attenuation by soils of
the site were found to be low for trace metals such as arsenic.
Interpretations of the sampling results were difficult to make due to the
occurrence of other potential contamination sources, in the form of older waste
disposal areas at the site (the location and ages of which are uncertain);
potential pickup of major ash constituents from mineralized soil solutes; and
uncertainties in whether, and to what degree, leachate from the two landfills
had reached the downgradient wells. Contamination from the two landfills could
have increased until steady-state concentrations were reached. It appeared that
at least some of the contamination observed, especially for contaminants such as
cadmium, was due to leaching from the many ash deposits at the site.
-------
E-50
E.7 SHERBURHE COORTY PLANT
The Sherburne County Plant in Minnesota was located approximately 30 miles
northwest of Minneapolis. The plant site was adjacent to the northeast bank of
the Mississippi River, and consisted of two units, each equipped with fly ash
alkali FGD scrubbers that used limestone. The plant used subbituminous coal
from Montana and Wyoming with a sulfur content of 0.8 percent and an ash content
of about nine percent.
Combined fly ash/FGD waste effluent was thickened and disposed of in a
clay-lined pond which covered 62 acres and lay just southeast of the power plant
(Exhibit E-15). Bottom ash was disposed of in a separate, adjacent, 18-acre
clay-lined pond immediately north of the FGD sludge/fly ash pond. Overflow from
these disposal ponds was directed into a clay-lined basin to the west of the
bottom ash pond, effluents from which were recycled as a scrubber medium or for
waste sluicing. The disposal ponds had been in use since 1976.
The Sherburne Plant was underlain by granite at a depth varying from 50 to
150 feet. Soils throughout the site area consisted of glacial drift (sands and
gravels). Discontinuous lenses and layers of glacial till (dense mixtures of
silt, sand, and clay) also occurred within the drift deposits. Ground water
was in the unconsolidated glacial outwash (drift) sands and gravels. The water
table was approximately 30 to 40 feet below the land surface. Ground-water flow
was generally southwesterly towards the Mississippi River (Exhibit E-16). In
general, there was no surface runoff in the site area with all precipitation
infiltrating rapidly through the soils to the ground-water table. Annual
precipitation was about 28 inches.
-------
E-51
EXHIBIT E-15
DISPOSAL PONDS AND SAMPLING LOCATIONS AT
SHERBDRNE COUNTY SITE
P59O
PMO
1*1*"
POWER
PLANT
P570 OP56 OP93
5-5
»-»!-
S-S
5-9
N
SHEHCO DISPOSAL SITE
SHCMUMNC COUNTY. MINNESOTA
AOL WELLS
A AOL IN-WASTE BORINGS
O UTILITY WELLS
SUPERNATANT SAMPLING STATIONS
0 250 500
FEET
Source: Tetra Tech 1985.
-------
E-52
EXHIBIT E-16
GKOOHD-HATER FLOW DIRECTIONS AT SHERBUKHE COUNTY SITE
EST. HORIZONTAL SEEPAGE VEL
928.2
K ft/sec I ft/ft P V ft/yr
3.2x10 " 5/3625 0.3 170
N
»»239
SCALE
0 250 500
FEET
Source: Tetra Tech 1985.
-------
E-53
Factors that were considered to be important in the selection of this site's
ponding operations for study included:
Fly ash and sulfur oxides from the plant were
removed simultaneously using external forced
oxidation. This produced a waste that was
sulfate-rich and easy to dewater and handle. Few
other plants practice forced oxidation, but it had
been identified as a potentially mitigative measure
for FGD waste management and its use was expected to
grow in the future.
Pond lining and recycling operations were in use at
very few other plants and were considered to be
potentially mitigative features at future sites.
The site afforded an opportunity to study linear
performance in the ponding of wastes.
Western coal was employed at the Sherburne County
Plant. Generating capacity using western coal with
FGD systems was expected to grow.
The high-quality ground water and modest
precipitation at this site and its isolation from
other sources of potential contamination was
expected to facilitate the identification of any
waste-related ground-water contamination.
K.7.1 Stapling Approach
Two upgradient and six downgradient ground-water monitoring wells were
installed and sampled to determine the presence of any leachate in the ground
water. Sa*ples were also taken of wastes from the two ponds, liner materials,
soils, waste "liquors" (waters) from the ponds (including FGD waste interstitial
water and FGD pond supematants), liquids from within the clay liner of the fly
ash/FGD pond, and liquids from soils beneath the liner.
Locations of the waste ponds, recycling pond, monitoring wells, and other
sampling locations are shown in Exhibit E-15. Wells were sampled for
-------
E-54
contaminant concentrations on three dates. Soil attenuation tests and a site
water balance were also conducted. Earlier results from ground-water monitoring
conducted at the site since 1977 were also available for review. The value of
and trends in sampling and analysis results for the site, and comparison of
ground-water concentrations with relevant EPA standards, are discussed below.
E.7.2 Results
Exhibit E-17 presents the results of chemical sampling at the Sherburne
County (Sherco) site. This includes samples from the downgradient and
upgradient ground-water wells, and fluid samples collected from within
(interstitial water) and beneath the wastes. Results are discussed below.
Waste and Liner Solids. No significant stratification of the FGD waste was
observed and, therefore, the permeability of the waste was observed to be fairly
uniform throughout the deposit, ranging from 7 x 10 to 5 x 10" cm/sec
(indicating low permeability). The earthfill pond liner was tested for
permeability and was found to range from 5 x 10* to 1 x 10 cm/sec.
Waste Fluids. Results from fluid samples collected from wells placed within
the FGD sludge/fly ash waste and from pond supernatant indicated that these
fluids or "pond liquors," when compared to Primary Drinking Water Standards,
exhibited elevated concentrations of cadmium (up to 30 times the PDWS), chromium
(up to 16 times the PDWS), fluoride (up to 4.5 times the PDWS), lead (up to 28
times the SDWS), nitrate (up to 7 times the PDWS), and selenium (up to 25 times
the PDWS). Comparison of pond liquors to Secondary Drinking Water Standards
showed elevated levels of chloride (up to 2 times the SDWS), iron (up to 6 times
-------
EXHIBIT E-17
CHEMICAL SAMPLING RESULTS FOR SHERBURNE COUNTY SITE
9CHUMC COUITY SITE
'8.5
fH Field IB/ (4.5
>*B.5
iroiind Mter
I/
OMM/tditM
(3 Milt)
S/ i/
Total Exceed. Hen.
Saiplct Smplet Eicitd.
3 0
12 0
12 2 2
12 1 1.2
12 0
12 0
0
12 2 1.1
3 0
12 0
_..».____ _ _ » --
12 0
12 0
12 0
12 2 22
12 0
12 0
1 0
1
1 0
1
1 B 0
1 6 0
1
21
Upjradient
(2 Milt)
5/ hi
Total Enctrd. Hai.
Saw let Siipltt Eicnd.
3 0
B 0
B 2 2
8 0
B 0
B 0
0
B 2 ' 27
3 0
B 0
B 0
6 0
B 1 1.9
B 1 1.4
B 0
B 0
0
0
6 0
i 0
Under U»tr
31 1
Uattrt Under Liner
(3 wilt)
S/ o/
Total Enceed. Max.
Saw let Saiplet Exceed.
4 1 l.B
B 0
8 4 132
8 3 7.6
822
B 2 103
0
4 4 f.&
4 0
1 0
8 1 2.7
B 5 24
8 8 84
B 1 7BB
8 7 114
B 3 17
0
0
I?/
NR
I?/
NR
Uatte
4/
Pond Liquor!
(13 stations)
11 81 kl
Saiplet Ave. Max.
>Detect. Cone. Exceed.
4 0.028
5 0 043
14 0.073 30
3 0.35 14
9 9.5 45
1 1.4 2B
U/
NS
9 108 48
7 0.04 25
0
-_......_ __-__
12 183 1.9
13 D.054
13 0.46 4.1
11 5. B 314
12 4BBO 42
7 0.31
14/
NS
I4/
NS
0
0
I
In
In
-------
EXHIBIT E-17 (Continued)
CHEMICAL SAMPLING RESULTS FOR SHERBURNE COUNTY SITE
)/ Ufllt 5-4, 5-4. and 5-9. I7/ As indicated in footnote 4, the "a. exceed coluin 'or reported tK ofasurments
it 1 tabulation o* the ac'.uai eaS'J">«i>,'tsi not tie M«'iuu e-:eeojore 4>' cy
2/ Utlls 5-5 and 5-11 the drinking niter standard
3/ Uells 5-1. S-2> and 5-3. The fluid* tollecttd at these tells are groundtater fro* IB/ HI - not reported.
beneath the Mitt.
4/ Stations 5-1 S3, 5-1 54, 5-1 U3, 5-2 Ul, 5-2 52, 5-3 (2D ft), 5-3 59, 5-3 Ui, 5-12, 5-13A
5-14. 5-15, and S-U. These 'pood liters' art fluids collected froi tith.n and on
top of the landfilled tastes.
5/ The nuiber of saiples tith reported concentrations abovt the drinking wter standard.
4/ Hai. Eiceed. is the concentration of the greatest reported ticttdanct divided
bx the drinking tater standard for that particular contannant. The only
eiception is for pH, there Nan. Exceed, is the actual Masurtitnt.
" The nuiber of 'pond liquor" saiplts Kith reported concentrations above the reported
detection Ii«its An entry of *0* indicates that no saiplt had a detectable contaminant
concentration, not that no saipltt vert taken (set footnote 14).
8/ Avt. Cone, is the average of the reported concentrations of all 'pond liquor"
saiplet taken that shoved a contaiinant concentration above the detection liiit.
The reported pH Masurtitnts of the "pond liquors" art also avtragtd. pi
I
L/l
[Coaient on footnotes 9-15- O
Uhere the reported detection liiit for a conlaiinant us greater than the drinking
inter standard and the saiplt containtd less contaiinant than the reported detection
liiit, the saipit is tabulated as being be I on the drinking niter standard.]
9/ For soie Mttr saiples collected Im* kite- under the taste, the reported detection liiit
of 0.074 «{( greater than the PDUS for arsenic
!Q/ For soie tattr saiples collected froi tater under the tast>, the reported detection lint
ol 1.5 MS greater than the ?9U5 for cadmui.
ll/ For soie tater saiplts collerted trm tater under the taste, the reported detection liiit
of 1.5 MS greater than the POUS tor chronui.
I2/ For soie tattr saiples collected froi tater under the taste, the reported detection I lull
ol 24 t MS greater than the POUS for flour dt
Tht solubility of touride in tater is urktdly affected by teiperature. Of the teiperature
rangts and corresponding MHIIUI allotabie cortaiinant levels reported for flounde in the NIPDUS,
the rangt shotn on this tablt (2&.3-32.S C) corresponds to the iost stringent allotable
laniui contaiinant concent rat'n»
13/ For soie tater saiples collected froi tater under the taste, the reported detection liiit
ol 7.5 MS grtattr than the PDUS for lead.
I4/ NS * not saipltd.
IS/ For sou tater saiples collected froi tater under the taste, the reported detection liiit
of 0.123 tas greater than the POUS lo' seleniui
It/ For soie tater saiples collected Iroi tater under the MSte> the reported detection liiit
Of 1 S MJ* ar»l>r Ihln lh» ff»K In, .>«.>..,.
-------
E-57
the SDWS), manganese (up to 316 times the.SUDS), and sulfate (up to 42 times the
SDWS). Concentrations measured in the pond supernatant were generally higher
than those measured in the interstitial waters of the wastes (e.g., 10,000 ppm
sulfate in pond surface liquids and 2000 ppm in waste fluids). Pond liquors
obtained from the smaller bottom ash pond also exhibited elevated concentrations
of cadmium (up to 50 times the PDWS), and manganese (up to 9 times the SDWS).
Because these fluids are not ingested, comparison to the drinking water
standards is shown only to indicate the potential for contamination at the site.
Misc. Fluids. Results obtained from chemical analyses of the clay liner
pore water showed concentrations of cadmium, chromium, iron, sulfate, and
manganese that were above drinking water standards. Fluid samples obtained from
under the liner showed elevated concentrations for most of the contaminants
tested for, including arsenic, cadmium, chromium, fluoride, lead, selenium,
nitrate, boron, sulfate, chloride, copper, iron, zinc, and manganese. It is
unclear as to what these samples represented, and the method used to collect the
liquid samples from the unsaturated soils beneath the clay liner may have
resulted in these observed to be above drinking water standards values being
greater than the trace below-liner concentrations. Concentrations of cadmium,
boron, and manganese were observed in fluids obtained from the recycling basin.
Ground Water. Estimates were made of seepage velocities at the site.
Results from these calculations indicated that enough time had elapsed for some
constituents in the waste leachate to have reached the nearer downgradient wells
(Wells 5-4 and 5-6). However, steady-state conditions had probably not been
reached at the site (i.e., chemical equilibrium between the waste, leachate, and
downgradient ground water had not occurred).
-------
E-58
Primary Drinking Water Standards were found to be exceeded in the ground
water of the downgradient wells for cadmium (up to 2 times the PDWS) chromium
(up to 1.2 times the PDWS), and nitrate (up to 1.1 times the PDWS). Upgradient
exceedances of the Primary Drinking Water Standards in ground-water samples were
also found for cadmium (up to 2 times the PDWS) and nitrate (up to 27 times the
PDWS). Secondary Drinking Water Standards were found to be exceeded in
downgradient ground water for manganese (up to 22 times the SDWS). Upgradient
exceedances of the Secondary Drinking Water Standards in ground-water samples
were observed for iron (up to 1.9 times the SDWS) and manganese (up to 1.4 times
the SDWS). It should be noted that concentration measurements for arsenic and
selenium in the ground water were sparse.
Surface Water. No surface water samples were collected at the Sherburne
County site.
Attenuation tests. Attenuation tests conducted with site soils and pond
liquor solutions (spiked with trace elements) from the Sherburne County and
Allen sites indicated that the sandy soils that prevailed over much of the site
had a relatively low capacity to chemically attenuate trace metals. Tests of
the clay liiwr soil indicated these materials had a somewhat better attenuative
capacity.
K.7.3 Discussion and Conclusions
Exceedances of the Primary Drinking Water Standards for cadmium (up to 2
times the PDWS) and nitrate (up to 27 times the PDWS Upgradient and up to 1.1
-------
E-59
times the PDWS downgradient) were observed in both the upgradient and
downgradient ground water at the Sherburne County disposal site. There were
manganese exceedances in both upgradient wells (up to 1.4 times the SDWS) and
downgradient wells (up to 22 times the SDWS).
Wastes fluids from the FGD sludge/fly ash pond exhibited high
concentrations of several constituents; cadmium (up to 30 times the PDWS),
chromium (up to 16 times the PDWS), fluoride (up to 4.5 times the PDWS),
nitrate (up to 7 times the PDWS), lead (up to 28 times the PDWS), and selenium
(up to 25 times the PDWS). Elevated concentrations were also observed for
chloride (up to 2 times the SDWS), iron (up to 6 times the PDWS), manganese (up
to 316 times the SDWS), and sulfate (up to 42 times the PDWS).
Although the wastes and fluids exhibited high concentrations of
contaminants, leachate from these wastes did not appear to have migrated into
or mixed with the ground water to any great extent. There were indications
that some waste-related solutes had migrated to downgradient wells from the FGD
sludge/fly ash pond. Concentrations profiles of sulfate were greater
downgradient than upgradient in the closer well, 5-4. Higher than background
concentrations of solutes at downgradient well 5-6 may not have been associated
with the disposal ponds, but may have reflected leakage that was reported to
have occurred from holding ponds at the site. Possible explanations of results
and future expectations are discussed below.
Nitrate exceedances of the Primary Drinking Water Standards were widespread
at various locations at the site (including background), but seemed to be
unrelated to disposal operations.
-------
E-60
Observed solute concentrations (e.g., sulfate, boron) suggested that the
clay liner had reduced the rate of release of leachate from the disposal pond.
However, concentrations of waste-related contaminants in downgradient ground
water may eventually increase, since leachate was not currently leaking out of
the landfill at a maximum, or steady-state, concentration, and only a portion
may have reached the downgradient wells at the time of sampling. In other
words, only a small quantity of leachate had, at the time of sampling, mixed
with the larger amounts of uncontaminated ground water. If the landfill had
not contained a liner, estimates of leachate movement indicated that
steady-state concentrations of leachate would have reached downgradient-wells
several years prior to the study.
Two other factors that could contribute to the observed lack of
contamination in downgradient ground water include:
Leachate that originally permeated the liner may have been
less contaminated than the leachate currently found in the
FGD wastes (leachate may not have yet been in equilibrium
with the wastes, and early plant operations did not involve
recycling plant water); and
Most of ADL's wells were screened over a depth interval of 20
feet or greater, thereby yielding composite ground-water
samples that may have exhibited lower contaminant
concentrations than if the wells were screened only at a
level and length commensurate with the expected migration of
leachate.
The waste-related contaminant selenium may be of concern at this site since
the surrounding soils may not chemically attenuate selenium, and its
concentration in ground water could be higher than indicated once steady-state
concentrations were achieved.
-------
E-61
In summary, the Sherburne County Plant in Central Minnesota disposed of
combined fly ash and FGD waste in one clay-lined pond and bottom ash in an
adjacent clay-lined pond. Exceedances of the Primary Drinking Water Standards
were observed in both upgradient and downgradient ground water for cadmium (up
to 2 times the PDWS for both) and for nitrate (up to 27 times the PDWS
upgradient and up to 1.1 times the PDWS downgradient), and in downgradient
ground water for chromium (up to 1.2 times the PDWS). Waters from the pond
wastes were found to exhibit high concentrations (relative to Drinking Water
Standards) of several constituents including cadmium (up to 30 times the PDWS),
chromium (up to 16 times the PDWS), fluoride (up to 4.5 times the PDWS at 26-33
°C), nitrate (up to 7 times the PDWS), lead (up to 28 times the PDWS), and
selenium (up to 25 times the PDWS).
While the waste fluids exhibited high concentrations of contaminants,
leachate from these wastes did not appear to have migrated into and mixed with
ground water to a great extent. Ground-water samples collected at the site do
seem to indicate that a few waste-related species (sulfate and boron) have
migrated from the wastes. The clay liner appeared to have significantly
reduced the rate of release of leachate from the disposal ponds, precluding the
development of elevated trace metal contaminant concentrations at downgradient
wells. Over time, downgradient wells may increase the level of contamination,
since steady-state conditions have not been achieved between leachate from the
landfill and the ground water. Without the clay liner, the leachate seepage
rate would have been much greater, leading to greater contamination of ground
water. Since the surrounding soils may not chemically attenuate it, the
waste-related contaminant selenium may be of concern at this site once
-------
E-62
steady-state concentrations in ground water are reached.
E.8 POVERTQR PLANT
The Powerton Power Plant is located in Tazewell County, Illinois,
approximately 10 miles south of Peoria. The site is located one mile south of
the Illinois River, and the disposal area is another mile south of the plant.
The existing facility began operation in 1972, although a smaller plant had
previously operated at the site. Originally, bituminous coal with four percent
sulfur was burned. In 1976, the plant began burning Montana subbituminous coal
with 0.6 percent sulfur and six percent .ash. At the time of the study,-the
Powerton wastes consisted of boiler slag that was dewatered and trucked to the
disposal area, and fly ash which was collected from an electrostatic
precipitator, stored, and then transported dry to the disposal area.
The disposal area consisted of two adjacent landfill areas which border
Lost Creek (Exhibit E-18). The large portion of the disposal area was used
from 1972 until 1978, and had since been reclaimed. The smaller area west of
this section was operated from 1978 until 1982. The newer portion of the
landfill occupies an abandoned borrow pit in which fly ash and slag were
intermixed. In the older portion of the landfill, there were distinct layers
of slag and fly ash. The newer landfill, and part of the older one, were
underlain by a liner of Poz-0-Pac,' which consisted of a chemically stabilized
mixture of fly ash, lime, and bottom ash. The liner was reported to be five
feet thick beneath the newer part of the landfill and only eight inches thick
-------
E-63
EXHIBIT E-18
LANDFILL AREAS AND SAMPLING LOCATIONS AT THE POWERTON SITE
N
/* "~\"~" "^
EMBANKMENT
AOL WELLS
O UTILITY WELLS
SURFACE WATER SAMPLING STATIONS
SCALE
0 200 400
FEET
Source: Tetra Tech 1985.
-------
E-64
beneath the older area. The surface area of the entire landfill was
approximately 438 acres.
The following factors were considered to be important for selecting the
Powerton landfill operation for study:
The collection, handling, and landfill disposal of ash as
practiced at Powerton was one of the prevalent practices
nationwide in the utility industry.
The interior climatic and hydrogeologic setting (relatively
permeable soils and moderate, regular precipitation) were
considered to be typical and allowed effects of landfill
disposal of coal ash generated from western coal to be
studied.
While artificial lining of managed coal ash landfills was not
a prevalent practice nationwide at the time of the study, this
site was considered a useful opportunity to study a
potentially mitigative practice.
The retired landfill was bordered by a small stream (Lost
Creek). Because there were no major point source discharges
to Lost Creek, this was considered a good opportunity to study
potential impacts of coal ash disposal on a small surface
water body.
In the Powerton area, the bedrock consisted of limestone, sandstones, and
shales. These were overlain by thick deposits of glacial outwash (sands and
gravels). The older portion of the landfill was underlain by sand and silt
deposits, within which are a number of clay lenses. The site receives an
average of 36 inches of precipitation per year. The glacial outwash deposits
made up the principal aquifer (water-bearing units) underlying the landfill.
This aquifer discharged to Lost Creek. At the upgradient edge of the landfill
(the western edge), the water table was approximately 35 feet below the fill.
Along the downgradient edge (that bordering Lost Creek), the water table was
within a few feet of the ash and occasionally intercepted the ash fill. All
surface and ground-water flow was northeasterly towards Lost Creek, which
-------
E-65
subsequently flowed to the Illinois River (Exhibit E-19).
E.8.1 Sampling Approach
At the Powerton landfill, three upgradient (one background, two peripheral)
ground-water monitoring wells and three downgradient ground-water monitoring
wells were installed (Exhibit E-18). Additionally, one well was drilled through
the ash and slag wastes of the older landfill to sample waters directly beneath
the fill. These wells were installed to determine (via chemical testing) the
presence and vertical extent of any leachate. Additionally, chemical analyses
were performed on surface water samples at the site. Samples were collected
from six surface water stations in Lost Creek. Three of these stations were
located upstream (6-13, 6-14 and 6-16), two were located in the middle of the
site, and one was located downstream (6-10). No samples were collected of
interstitial waters or liquors from within the wastes.
E.8.2 Results
Exhibit E-20 presents the results of chemical sampling at the Powerton site.
This includes samples from the downgradient and upgradient ground-water wells,
samples from the surface water stations, and water samples obtained from
materials beneath the wastes. Results are discussed below.
Waste Solids. Permeability of the landfilled wastes ranged from a high of 3
-2 -4
x 10 cm/sec for the slag to a low of 1 x 10 cm/sec for the fly ash. In the
-------
E-66
EXHIBIT E-19
GROUND-HATER FLOW DIRECTIONS AT THE POWERTON SITE
Well 6-6
Well 6-5
Well 6-8
INFERRED FLOW DIRECTIONS I2/M/81
EST HORIZONTAL SEEPAGE VEL.% 2 "
K ft/day
13
1.3
13
I ft/ft
2/800
2/800
4/1150
P
0.3
03
0.3
W|K/yr
4
4
J
SCALE
0 200 400
FEET
Source: Tetra Tech 1985.
-------
EXHIBIT E-20
CHEMICAL SAMPLING RESULTS FOR POWERTON SITE
POUERTON STATION SITE
(no Pond Liquor data)
Units * ppi
POUS
Orinkin)
Contai. Uater
Standard
Arsenic 0.05
Bariui 1
Cadnui 0.01
ChrOllul 0.05
(Cr VI)
Fluoride 4.0
Lead 0.05
Mercury 0.002
Nitrate B/ 45
Seleniui 0.01
(liq.)
Silver O.OS
SOUS
CMoride 250
Copper 1
Iron 0.3
Manganese 0.05
Sullate 250
Zinc 5
pH Lab 9/ <=A 5
>=fl.S
pH Field 11 (-A.5
>=fl.5
Ground Hater
I/
Doxntradieiit
(3 Mils)
A/ 11
Total Eiceed. Rax.
Saiples Saiples Exceed.
8 0
9 0
983
9 0
9 0
9 1 4
0
9 0
a o
9 0
9 0
9 D
9 4 42
9 9 194
9 A 2.7
9 0
1 0
1
1 0
9 1 A
1
9 0
21
Upjradient
(1 Mil)
A/ 11
Total Exceed. Max.
Saiples Samples Exceed.
2 0
4 0
4 2 1
4 0
4 0
4 0
0
4 2 1.1
2 0
4 0
4 0
4 0
4 D
4 2 11
4 0
4 0
0
0
3 D
3 0
Under Waste
3/
Uater Under Uaste
(1 oell)
A/ 11
Total Exceed. (lax.
Samples Saiples Exceed.
3 0
3 0
3 3 2
3 0
3 0
3 0
a
3 1 1.7
3 0
3 0
_
3 0
3 0
3 0
3 3 A
3 3 3. A
3 0
0
0
2 0
2 0
Surface Uater (Lost Creek)
4/
(loung-adie-it
(1 station)
A/ 11
Total Exceed. Max.
Saiples Sanoliis Rxceed.
1 0
3 0
3 2 2
3 0
3 0
3 0
0
3 1 1.1
1 0
3 0
3 0
3 0
3 0
3 2 2.2
3 D
3 0
0
0
3 0
3 1 8.5
5/
Upsradient
(3 stations)
A/ 11
Total Eiceed. flax.
Siiples Sdiples f«c»»rf
2 0
B 0
8 5 2
B G
8 0
8 0
Q
7 3 12
2 0
8 0
B 0
B 0
B 0
B 2 1
B 0
8 Q
0
0
8 0
8 2 8.5
m
Ol
-si
-------
EXHIBIT E-20 (Continued)
CHEMICAL SAMPLING RESULTS FOR POWERTON SITE
:/ Del Is 4-t. 4-7, and 4-8.
21 Uell 4-4
3/ Utll 4-9. The fluids collected at tl»s Mil are (roundiater Iroi beneath the vaste.
*/ Station 4-10.
S/ Stations 4-13, 4-U, and 4-14
4/ the nuiber ol saipies Kith reported concentrations above the drinking later standard.
'/ Max. Exceed is the concentration ol the greatest reported enceedance divided
by the drinking niter standard lor that particular contaiinant. The only
eiception is lor pH> ihere Nai. Eicted. is the actual nasureunt.
8/ The solubility of llouride in Mter is urkedlx atlected by teiperature. 01 the teiperature
ranjes and corresponding xiiiui allo*able tontaiinant levels reported lor llouride in the NIPOUS.
the range shoin on this table (24.3-32 S C) corresponds to the lost stringent allovable
annul contaiinant concentration.
II As indicated in footnote 7, the 1a«. Exceed, coluin lor the reported pH leasureients
is i tabulation ol the actual icasureientsi not the uxiiui exceedance divided by
tKe drinking later standard. pi
i
O>
CO
-------
E-69
more recent section of the ash landfill, where slag and fly ash were mixed, the
-4
permeability of the waste was approximately 5 x 10 cm/sec.
Waste Fluids. No samples were collected of waters from within the
landfilled wastes (waste liquors). Results from water samples collected from
beneath the waste indicated that these waters, when compared to Primary Drinking
Water Standards, exhibited elevated concentrations of cadmium (up to 2 times the
POWS), and nitrate (up to 1.8 times the PDWS). Comparison of these samples to
Secondary Drinking Water Standards indicated elevated levels of manganese (up to
6 times the SOWS), and sulfate (up to 3.6 times the SDWS).
Ground-Water. Estimates of seepage velocities at the site indicated that
waste leachate constituents could have reached downgradient ground-water wells
and possibly Lost Creek by the time of ADL's sampling.
Primary Drinking Water Standards were found to be exceeded in the ground
water of the downgradient wells for cadmium (up to 3 times the PDWS) and lead
(up to 4 times the PDWS). Slight exceedances in upgradient ground water of
the Primary Drinking Water Standards were found for cadmium (up to 1 times the
PDWS). Note that the one upgradient well (6-6) bordered the landfilled wastes.
Occasional exceedances of the Primary Drinking Water Standard for cadmium were
observed in the two ground water wells peripherally located to the wastes.
Surface Water. The Primary Drinking Water Standard for cadmium was found to
be exceeded occasionally at all surface water stations at the site. Cadmium was
observed at up to 2 times the Primary Drinking Water Standard at the upgradient
(upstream) stations and at the downgradient stations. Nitrate exceeded the
-------
E-70
Primary Drinking Water Standards in both upgradient (up to 12.3 times the PDWS)
and downgradient (up to 11.6 times the FDVS) surface water locations. Secondary
Drinking Water Standards were found to be exceeded in both upgradient (1 times
the SOWS) and downgradient (up to 2.2 times the SDWS) surface water locations
for manganese.
Attenuation Tests. Attenuation tests conducted using pond liquor solutions
(spiked with trace elements) from the Allen and Sherburne County sites and soils
obtained from the Powerton site indicated that these soils generally had
intermediate capacities to attenuate trace metals such as arsenic.
E.8.3 Discussion and Conclusions
The assessment of sampling results from the site focused on the effects of
ash landfill leachate on downgradient ground-water quality, and the effects of
ash landfill leachate on Lost Creek surface-water quality. Emphasis on
analyzing the effectiveness of the Poz-0-Pac liner under the landfill was
discontinued after a general absence of the liner under the older, larger,
disposal area was discovered.
Cadmium was observed to exceed the Primary Drinking Water Standard in the
downgradient ground-water wells (up to 3 times the PDWS). Cadmium was also
observed at the Primary Drinking Water Standard on one occasion in the
upgradient ground-water well. Since the upgradient well is located very close
to the landfill border, the slightly elevated concentration of cadmium observed
in this well's samples may have been from the leaching of cadmium. However, if
must be noted that cadmium exceedances in surface water were observed upstream
-------
E-71
as well as downstream (up to 2 times the PDWS), potentially indicating that the
utility waste was not the source.
One exceedance of the Primary Drinking Water Standard for lead was observed
at a downgradient ground-water well (up to 4 times the PDWS). However, the
usefulness of this information was limited since lead was only reported to be
detectable on one occasion and, in other samples, lead was not detectable at
all. Elevated nitrate concentrations observed in ground water from various
sampling locations could possibly be attributed to local agriculture activities.
Trace elements such as arsenic and selenium were found to be similar to
background concentrations and were below drinking water standards. These trace
elements may not have leached from the landfill, or may have been chemically
attenuated by the soil.
Chemical sampling results at the Powerton site indicated that leaching and
migration of ash wastes had occurred since solutes had reached the downgradient
wells. Major ash constituents that are observed to exceed Secondary Drinking
Water Standards in the downgradient ground water at the site were sulfate (up to
3 times the PDWS), iron (up to 4 times the PDWS), and manganese (up to 194 times
the PDWS). Of these contaminants, the elevated levels of sulfate might have
been due to leaching from the waste. Only manganese was observed to exceed
Secondary Drinking Water Standards at the upgradient well (up to 11 times the
PDWS).
The ground-water concentrations of the major waste constituents indicated
that leachate migration from the landfill might have reached approximately
steady-state conditions with respect to the concentrations of these species in
-------
E-72
the waste and downgradient wells. If this had occurred, further increases in
the concentrations of such species would not be expected. Additionally, levels
of trace metals in the ground water suggested that a combination of dilution and
chemical attenuation was preventing the buildup of significant concentrations of
these constituents at downgradient locations. Given these ground-water results,
the Powerton site might have had some effect on ground-water quality, but
increased degradation should not be expected.
The consistently elevated concentrations of boron observed in downstream
surface water of Lost Creek would seem to indicate some leaching of this waste
constituent since it is being detected in the surface waters of Lost Creek.
This body of water may be substantially diluting the waste constituents;
however, the small number of sampling stations do not allow further data
analysis.
In summary, the Powerton Plant disposed of fly ash, bottom ash, and slag in
an older landfill approximately one mile south of the site. More recent
disposal operations consisted of disposing of intermixed fly ash and slag in a
newer portion of the landfill. The newer landfill and part of the older one
were underlain by a liner consisting of ash and lime (Poz-0-Pac). The
downgradient ground-water wells exhibited levels of cadmium up to three times
the Primary Drinking Water Standard and levels of lead at up to four times the
Primary Drinking Water Standard. An upgradient well, located on the border of
the landfill wastes, also exhibited an elevated concentration of cadmium at the
level of the Primary Drinking Water Standard. Secondary Drinking Water
Standards were exceeded in downgradient wells for iron, manganese, and sulfate,
and in the upgradient well for manganese (but at a lower level of exceedance
-------
E-73
compared to the downgradient measurement).
Results indicate that leaching and migration of ash wastes had occurred at
the site, but it is difficult to determine how significant an impact the
leachate has had, or will have, on ground-water quality. Dilution and chemical
attenuation may have prevented the development of significant concentrations of
trace metals such as arsenic and selenium at downgradient locations. The degree
to which Lost Creek was diluting the waste constituents that may reach it may
have been significant, but could not be determined from the available
information.
E.9 LANSING SMITH PLANT
The Lansing Smith power plant is located on a coastal plain approximately
eight miles north of Panama City, Florida. The power plant lies approximately
one-half mile inland from the shore of North Bay (within the St. Andrews Bay
System) at the tip of Alligator Bayou. At the time of the ADL study, the two
units at the site were equipped with electrostatic precipitators. The coal used
was primarily low sulfur bituminous coal.
Fly ash, bottom ash, mill rejects,and coal pile runoff were sluiced to an
unlined ash disposal pond which covers approximately 200 acres and lies
generally between the power plant and the shore of North Bay (Exhibit E-21).
The disposal pond has been in continuous use sine 1965. The landfill was
contained by dikes through the exterior slopes of which seepage had been
-------
E-74
«M
H
H
s
03
9
Source: Tetra Tech 1985.
-------
E-75
visually observed. Standing water in the disposal pond was channelled through a
recycling canal and pumped back to the plant for reuse as sluicing water.
The plant was located on low-lying, almost level, marine terraces, which are
drained by bayous and small creeks. The site experienced heavy precipitation
(approximately 58 inches/year) and the low elevations of the site area had
experienced flooding from both the river basin and coastal storms. Part of the
land underlying the ash pond was once a swamp.
Surface deposits at the site consisted of thin topsoil and shallow organic
deposits. Limestone of the confined Floridan Aquifer lay at a depth of*
approximately 90 feet, and was the principal water supply aquifer of the county.
A thick layer of unconsolidated permeable silts and sands was between the
Floridan Aquifer and the surface deposits. Due to saltwater intrusion, ground
water in these deposits was not considered potable (and was not used as a
drinking water supply at the time of the study). The water table at the site
was close to the ground surface, resulting in swampy conditions. Ground
water was in contact with the disposed ash materials. Regional ground-water
flow was southeasterly towards North Bay (Exhibit E-22), however, flow patterns
were multi-directional in the plant vicinity.
Surface water in the plant vicinity consisted of the ash disposal pond, the
sluice water recycle canal, various drainage ditches and tidal creeks around the
ash disposal pond, Alligator Bayou, and a cooling-water outlet canal, some of
which contained seawater.
-------
E-76
M
M
OJ H
Source: Tetra Tech 1985.
-------
E-77
Factors for including the Lansing Smith Plant in the ADL study were:
The disposal method employed at the plant -- that of
combined disposal of fly ash and bottom ash in an
unlined pond -- was the most prevalent utility waste
disposal practice in the nation.
The disposal operation had been in existence
for more than 15 years, allowing sufficient
time for measurable leachate to reach the
surrounding environment.
The site was a coastal area and would
allow the study of a situation where ash
pond leachate and seawater would mix.
The site experienced heavy precipitation
in a setting of permeable soils and was
expected to illustrate a maximal extent of
leachate formation and transport in a pond
disposal setting.
Increases were anticipated in coal
conversion of coastal oil-fired power
plants, and there was a paucity of data
and previous studies of coastal disposal
operations.
E.9.1 Sampling Approach
Samples of wastes and soils were collected for physical and chemical
testing. Samples of ground water, waste fluids (or pond liquors), and surface
water samples were collected for chemical testing. A series of attenuation
tests were performed using local site soils and pond liquor solutions (spiked
with trace elements) obtained from the Allen and Sherburne County sites.
Twenty-four monitoring wells were installed throughout the site area
(Exhibit E-21). There were three upgradient ground-water wells (9-4, 9-5, and
9-13A) and five true downgradient ground-water wells (9-3, 9-3A, 9-7, 9-7A, and
9-9). Eleven monitoring wells were drilled within the ash pond or through the
dike (9-1, 9-1A, 9-2, 9-2A, 9-6, 9-6A, 9-8, 9-8A, 9-10, 9-10A, and 9-12B). Two
-------
E-78
of these wells were used Co sample water from under the waste. An additional
five wells were located along the perimeter of the dike. In addition, 18
surface water sampling stations were established. Locations of site wells and
surface water sampling locations were shown in Exhibit E-21.
E.9.2 Results
Exhibit E-23 presents the results of chemical sampling at the Lansing Smith
site. This includes samples from the downgradient and upgradient ground-water
wells, samples from wells emplaced within the waste to collect interstitial
water or fluids (includes supernatant fluids), water samples obtained from
beneath the waste, and surface water samples. Results are discussed below.
Waste Solids. The waste was generally found to be segregated into lenses of
-4
coarser and finer grained ash. A permeability of 9 x 10 cm/sec was measured
for the coarser ash, and 3 x 10 cm/sec for the finer fly ash.
Waste Fluids. Results from fluid samples collected from wells emplaced
within the waste indicate that these fluids or "pond liquors", when compared to
Primary Drinking Water Standards, exhibit elevated concentrations of cadmium (up
to 6 times the PDWS), chromium (up to 21 times the PDWS), and fluoride (up to 10
times the PDWS). Comparison of pond liquors to Secondary Drinking Water
Standards showed elevated levels chloride (up to 61 times the SDWS), manganese
(up to 7 times the SWDS) ,and sulfate (up to 6 times the SDWS). These fluids
were also fairly alkaline (up to a pH of 11). Since these fluids are not
ingested, comparison to the drinking water standards is shown to demonstrate the
potential for contamination at the site.
-------
EXHIBIT E-23
CHEMICAL SAMPLING RESULTS FOR LANSING SMITH SITE
LANSING SKIIH STEM* PLANT
Units * ppi IGround nater
Hinder Uaste
iSurface \intr (Alligator Bayoui Nortn Bayi and > streai on the east side)
lUaste
PDU5
Or i nl i nj
Contai. Uater
Standard
Arsenic 0.05
(liq.)
Bariui 1
Cadi i in 0.01
Chroeiui O.OS
(Cr VI)
Fluoride 121 4.0
Lead I3/ O.OS
Mercury 0.002
Nitrate IS/ 45
Selenium 0.01
(ho.)
Silver O.OS
SOUS
Chloride 250
Copper 1
Iron 0.3
Manganese O.DS
Sultate 750
Zinc S
pH Lao 14/ <*4.S
>=8.5
pH Field Itl <=4.5
>=8.5
I/
Donngradient
IS Milt)
8/ 11
Total Exceed. (tax.
Samples Saiples E>cted.
S 0
li 0
14 10 S
14 1 4
14 S 13.S
14 0
0
0
S 0
14 0
14 14 22.4
14 0
14 u us
U 13 17.2
14 6 6.4
14 0
It 4 4.4
1
1 4 0
1
1 13 10 2.9
1
1 13 0
21
Upjradient
(3 Milt)
61 11
Totil Exceed. Nai.
Saw lei Sacplts Exceed.
4 0
4 0
4 2 2
4 0
4 0
4 0
0
0
4 0
6 0
---- -
4 0
4 0
4 t 37
4 2 1.4
t 0
i 0
2 1 4.5
2 0
444
4 0
3/
Water Under baste
(2 Mils)
8/ 11
Total Exceed. Max.
San>les Saiples Exceed.
3 0
4 0
4 4 4
4 1 2
3 1 2.2
4 0
0
C
3 0
4 G
4 4 49
4 0
4 0
4 1 5.2
4 4 9.8
4 D
1 0
1 1 9.5
3 0
3 3 9.5
4/
Oovngradient
(4 stations)
a/ 11
Total Excess Max.
Saiples Saiples Exceed.
2 0
13 0
13 10 S
13 0
13 S 4.S
13 0
0
0
2 0
13 0
13 13 11.9
13 0
13 11 370
13 11 44
13 12 7.S
13 0
4 5 3.3
4 0
10 S 4.1
10 0
S/
Peripheral
(3 stations)
61 11
Total Exceed. Max.
Saiples Saiples Exceed.
1 0
8 0
844
a o
8 2 2
8 0
0
0
1 0
a o
a s 10
8 0
8 4 34
B 4 4.8
B 4 3.4
8 0
3 2 3.8
3 0
7 4 3.4
7 0
4/
Dourer ad lent - Saline
(2 stations)
8/ 11
Total Exceed. Nan.
Saiples Saiples Exceed.
3 0
S 0
5 S 4
S 1 1.2
5 2 20
5 0
0
0
3 0
5 0
S 5 57.B
S 0
5 0
S 0
5 5 1.1
5 0
I 0
1 0
S 0
S 0
7/ :
Pond Liquors
(1 stations)
10/ 1U 11
Saiples Ave. Na>.
>0etect. Cone. Exceed.
8 0.0053
18 0.24
14 0.029 4
8 0.14 214
3 20 10
0
14/
MS
147
NS
a o.oou
a
18 3790 41
10 0.11
12 0.12
8 0.17 7.4
18 844 4.4
9 0.12
4 9.3
4 9.3 11
12 9.1 4
12 9.1 11
PI
I
-------
EXHIBIT E-23 (Continued)
CHEMICAL SAMPLING RESULTS FOR LANSING SMITH SITE
\l Jells 9-3 (deep, south), 9-3 (loo tide), 9-3* (shalloi, south) 9-3A (Ion tide), 9-7A.
9-7, and 9-9
71 Uells 9-4, 9-5, and 9-13A.
3/ Uells 9-2 and 9-1. The fluids collected at these Mils are niters troi
beneith the Mste.
4/ Stitions 9-18, 9-20, 9-21, 9-24, 9-34, 9-25, but not station 9-34 (dissolved solids).
5/ Stitions 9-27, 9-23, ind 9-22.
»/ Stitions 9-15, 9-34.
II Stitions 9-1*, 9-1 (screen at inter lice), 9-1 (4-8 ft), 9-2 (0-2 ft), 9-2 (4-6 ft),
9-14, 9-30, 9-29, ind 9-24. These 'pond liquors" are fluids collected troi iiithin ind
on top of the landfilled MStes.
61 The nuiber of tuples kith reported concentritions ibove the drinking Mter stlndird.
9/ Hi>. Exceed is the concentrition ol the greatest reported exceedance divided
by the drinking Mter Standard lor that particular contaiinant. The only
exception is lor pH, vhere Max. Exceed, is the actual uasureient.
10/ The nuiber of "pond liquor" tuples nith reported concentrations above the reported
detection lints. An entry of "0" indicates that no saiple hid i detectible contaiinant
concentration, not that no saiples »ere taken (tee footnote 14).
I]/ Ave. Cone, is the average of the reported concentrations of all "pond liquor"
tuples taken that shotted a contaiinant concentration above the detection liiit
The reported pH uasureients of the 'pond liquors* are also averaged.
[Coiient on footnotes 12-13-
Uhere the reported detection liiit for a contaiinant MS greater than the drinking
ater standard and the saiple contained less contaiinant thin the reported detection
lint, the tuple is tabulated in this table as being fadon the drinking Mter standard.]
12/ For soie Mter saiples collected troi donngradient groundniten donnjradient surface Mter,
and "pond liquors,* the reported detection liiit of 25 MS greater than the POUS
of llouride. For soie Mter sup let collected troi donngradient siline turfice Mter ind Mter
under the Mtte, the reported detection liiit ol 50 MS aiso greater than the PDUS
tor tlouride. Finally, for sou Mler tuples collected troi peripheral surface Mter, the reported
detection liiit of 5 MS greater than the POUS for flouride.
The solubility of flouride in Mter is Mrkedly aftected by teiperature. 01 the teiperature
ranges and corresponding lamui alloMble contaiinant levels reported for tlouride in the NI PDUS,
the range shonn on this table (26.3-32.5 C) corresponds to the lost stringent alloMble
axiiui contaiinant concentration.
13/ For sou vater saiples collected troi dovngradient groundMten Mter under the Mtte, dovngradient
surface Mter, peripheral surface Mter, dcwngridient saline Surface Mter, and "pond liquort,"
the reported detection liiit ol 0.1 MS greater thin the PDUS for lead.
14/ NS - not tup led
IS/ As indicated in footnote 9, the Max Exceed, coluin for the reported pH icasureients
is a tabulation ol the actual leasureientti not the laxiiui eiceedince divided by
-------
E-81
Water samples obtained from under the waste showed exceedances of the
Primary Drinking Water Standards for the same constituents with high
concentration levels in the waste fluids; cadmium (up to 4 times the PDWS),
chromium (up to 2 times the PDWS), and fluoride (up to 2.2 times the PDWS).
These samples also exhibited elevated concentrations of boron (up to 8 times the
SOWS), chloride (up to 49 times the SOWS), manganese (up to 5 times the SDWS),
and sulfate (up to 10 times the SDWS). The pH of these samples (up to 9.5) also
indicated alkalinity.
Ground Water. Estimates were made of seepage velocities at the site.
Results from these calculations appeared to indicate that there has been enough
time for constituents in waste leachate to have reached downgradient wells and
North Bay.
Primary Drinking Water Standards were found to be exceeded in the ground
water of the downgradient wells for cadmium (up to 5 times the PDWS), chromium
(up to 4 times the PDWS), and fluoride (up to 13.5 times the PDWS). These were
the same contaminants found to exceed the standards in the waste fluids.
Upgradient exceedances of the PDWS in ground-water samples were also found for
cadmium (up to 2 times the PDWS). However, this exceedance was less common and
at lower levels than the downgradient samples. Arsenic and selenium were found
to be below the Primary Drinking Water Standards in the ground-water (and waste
fluid) samples at this site.
Secondary Drinking Water Standards were found to be exceeded in downgradient
ground water for chloride (up to 22 times the SDWS), iron (up to 118 times the
SDWS), manganese (up to 17 times the SDWS), and sulfate (up to 8 times the
-------
E-82
SOWS). Except for iron, these were the same contaminants observed at
concentrations greater than Secondary Drinking Water Standards in the pond
liquors. Samples were found to be acidic (maximum low pH of 2.9). This
differed from the alkalinity exhibited by the pond liquors.
Upgradient exceedances of the Secondary Drinking Water Standards in
ground-water samples were observed for iron (up to 37 times the SDWS) and
manganese (up to 1.4 times the SDWS). The Secondary Drinking Water Standards
contaminants found at elevated concentrations in the pond liquors and in the
downgradient ground water wells were not found to be elevated in upgradient
ground water.
Surface Water. Primary Drinking Water Standards were exceeded in
downgradient surface water samples for cadmium (up to 5 times the FDWS) and
fluoride (up to 6.5 times the PDWS). In downgradient saline surface water
samples, exceedances were observed for cadmium (up to 4 times the PDWS),
chromium (up to 1.2 times the PDWS), and fluoride (up to 20 times the PDWS). In
surface water samples collected peripheral to the ash disposal pond (east side),
exceedances were found for cadmium (up to 4 times the PDWS) and fluoride (up to
2 times the PDWS).
Secondary Drinking Water Standards were exceeded in downgradient surface
water samples for chloride (up to 12 times the SDWS), iron (up to 370 times the
SDWS), manganese (up to 64 times the SDWS). These were the same contaminants
found to exceed the Secondary Drinking Water Standards in peripheral surface
water samples, although the levels of exceedance were lower. Both the
downgradient and peripheral surface water samples were below the Secondary
-------
E-83
Drinking Water Standards for pH (as low as 3.4). Saline surface water samples
collected downgradient were found to exceed Secondary Drinking Water Standards
for chloride (58 times the SDWS), and sulfate (10 times the SDWS). No true
upgradient surface water samples were collected.
E.9.3 Discussion and Conclusions
Cadmium, chromium, and fluoride were observed to exceed the Primary Drinking
Water Standards in downgradient ground water in a greater proportion of samples
and at higher levels than upgradient ground water. Elevated concentrations of
these same contaminants were observed in the interstitial waters of the "wastes
(pond liquors) and in waters from under the waste. Sulfate, chloride, iron, and
manganese were observed to exceed Secondary Drinking Water Standards in
downgradient ground water. These same contaminants, with the exception of iron
and manganese", were not observed at elevated concentrations at upgradient
ground water wells. Sulfate, chloride, and manganese were observed at elevated
concentrations in waters in and under the waste. These results, in conjunction
with the fact that leachate migration from the waste was predicted to have
reached downgradient wells, strongly suggest that degradation of the
ground-water quality in excess of the drinking water standards at the site had
occurred due to leaching of some contaminant from the ash wastes. At this site,
the ground water was not used as a drinking water source. Sampling of the deep
underlying aquifer showed no evidence of contamination by ash pond leachate (or
by seawater).
Constituent concentrations observed at the site indicated that leachate
migration from the ponded wastes had probably reached steady-state conditions
-------
E-84
with respect to the concentrations of these species in the waste and
downgradient wells. In this case, further increases in the concentrations of
waste species in the downgradient ground water would not be expected.
Findings at the site are somewhat difficult to interpret due to the site's
estuarine setting and consequent intrusion and infiltration of seawater.
Difficulties in interpretations also arise from the use of saline bay waters for
ash-sluice make-up water. This is discussed below.
While the exceedance of Primary Drinking Water Standards for the trace
metals chromium and cadmium in the downgradient ground water appeared to be
directly related to the leaching of constituents in the ash, this may not have
been the case for ash-related constituents that were found to naturally occur in
seawater. For example, the use of bay water as sluice make-up and its presence
in adjacent downgradient areas may have masked the potential for significant
impact from the ash constituents sulfate, and chloride (which are observed in
elevated concentrations in downgradient ground water). These constituents were
found at similarly elevated concentrations in the bay waters, indicating that
concentrations of these constituents were probably influenced by seawater..
These seawater-related species were of concern only as Secondary Drinking Water
Standards.
The use of bay waters as ash sluice make-up water may have diluted and
reduced the availability of trace metals that might have otherwise been readily
leachable from the surface layers of the ash. This could have resulted in lower
concentrations of trace metals observed in downgradient ground (and surface)
water than if seawater were not used.
-------
E-85
A scrap metal disposal area located on the west side of the ash disposal
pond at the Lansing Smith site may have been a contributor to the large
exceedances of the Secondary Drinking Water Standards observed in the ground
and surface waters. Attenuation studies conducted at the site indicated that
chemical attenuation may be occurring in soils surrounding the disposal pond for
arsenic, strontium, and calcium.
Since no upgradient surface water samples were collected at the site, few
interpretations could be made of the available surface water data. On-site
flooding and pond seepage which had occurred at the site may have contributed to
the transport of leachate away form the disposal pond and into the surface
water. As with ground-water samples, seawater would influence concentrations of
seawater-related species in surface water samples. The elevated concentrations
of fluoride observed in the saline, downgradient, surface-water samples -- and
not in non-saline downgradient surface-water samples -- indicated that the
concentrations of fluoride observed in the downgradient ground water at the site
may have been influenced by, or even the result of, the use of seawater in site
operations and its intrusion (by flooding) downgradient of the wastes.
In suonary, the Lansing Smith plant in southern Florida disposed of a
mixture of fly ash and bottom ash in an onlined disposal pond located in a
coastal area. Concentrations greater than the Primary Drinking Water Standards
were observed for cadmium (up to five times the PDWS), chromium (up to four
times the PDWS), and fluoride (up to 13.5 times the PDWS) in the downgradient
ground water at the site and, with the possible exception of fluoride, appear to
be due largely to these contaminants leaching from the ponded ash wastes.
-------
E-86
Exceedances of Secondary Drinking Water Standards for several species (sulfate,
chloride, manganese, and iron) were also observed in downgradient ground water.
However, most of these species were seawater-related and their reported
concentrations appeared to be influenced by the use in plant operations and
infiltration of estuarine (saline) water at the site. Generated leachate
migrates to a shallow, unused, tidal aquifer.
Ash disposal from utility operations at this site has had a measurable
impact on ground-water quality. However, human health risks at this particular
site were probably minimal since the ground and surface water were not used for
drinking purposes.
E.10 QA/QC OF ADL TESTING DATA
As part of its study approach, ADL collected QA/QC samples at the six study
sites. These included field replicates, laboratory splits, and field blanks.
Standard solution and spiked solutions were also measured in the laboratory.
Analysis of data produced by this QA/QC program included that:
The variability introduced by the sampling and
analytical procedures utilized in the study was less
than the field variability. Thus the analytical methods
used should have been capable of detecting concentration
differences attributable to the field conditions.
Analytical precision, as measured by the relative
standard deviation, varied among constituents. For
major ions (e.g., Mg, Cl, and S04), precision was high
(RSD less than 10 percent); for the trace metals above
detection, plus N03 and F3, precision was lower (RSD
greater than 20 percent).
-------
E-87
Examination of Che ADL field data indicates that:
Most concentrations of Ag, Ba, Be, Br, Cu, Cr, Pb, P04,
Sr, Th, Ti, and Zn were below detection limits.
Reported detection limits for constituents were variable
upon occasion, spanning two orders of magnitude for some
constituents. Occasionally, the reported detection
limits were above the drinking water standards.
Overall, approximately 1.5 percent of the ADL chemical
data may be outliers.
In general, QA/QC results do not indicate large shortcomings in the chemical
data. However, caution must be used in interpreting the data using rigorous
deterministic methods. Some of the constituents (e.g., cadmium) for which
variations in detection limits were observed are of possible concern in 'regard
to human health and coal combustion waste disposal practices. However, it is
unclear from the available analysis information how significant these variations
might be in regard to assessing the environmental impact of coal combustion
wastes. It is possible that some of the constituents for which detection limits
were reported to be in excess of drinking water standards, may be of greater
concern than the data indicate.
-------
NOTES
1 Each physiographic region has a distinctive climate, particular vegetative
types, characteristic soils, a particular water regime, and differences in
principal natural resources.
2 Data sources included precursor U.S. EPA study -- Versar, Inc., Selection
of A Representative Coal Ash and Coal Ash/FGD Waste Disposal Sites for Future
Evaluations. 1979 (Research Triangle Park, North Carolina. EPA-IERL, 2771, 1979)
and a data base resulting from work by EPA, EPRI, TV A, DOE, and others.
' At the time of the ADL study there were more than 350 steam-electric plants
in the U.S. Of this number 340 had greater than 25 megawatts capacity and
utilized coal for more than 80 percent of their power production. Approximately
55 percent of these plants were located in the physiographic regions that cover
the Appalachian and Midwest areas of the country.
^ Sites with a generating capacity of less than 200 megawatts, very complex
sites (both technological or hydrogeological), plants which sell greater than 50
percent of their ash output, and plants with disposal sites less than two years
old, sites were eliminated from further consideration.
5 The Arthur D. Little report does not indicate if the discharges from the
Allen Plant pond (or from the Elrama Plant pond described below) are permitted
under NPDES. According to Section 402 of the Clean Water Act all discharges of
pollutants to surface waters from point sources must be permitted. The effluent
limitation guidelines for steam electric power generators are given in 40 CFR
Part 423.
6 A Registered Trademark.
7 Registered Trademark.
8 Note that this exceedance was slight--only 1.4 times the SDWS in upgradient
ground water--but was 17 times the SDWS in downgradient ground water.
^ Seawater could also influence concentrations of sodium; magnesium, and
selenium were not found to exceed drinking water standards.
-------
DATA ON SAMPLE OF COAL-FIRED
COMBUSTION WASTE DISPOSAL SITES
PLANT NAME
MCUILLIAMS
INDEPENDENCE
CORONADO
MAVAJO
SPRINGERVILLE 1*3
SPRINGERVILLE 2
CHEROKEE
off-tit* landfill
CRAIG
off-sits landfill
NUCLA
off-sitt landfill
VALMONT
DEERHAVEN
FJ GANNON
LANSING SMITH
MCINTOSH
SEMIMOLE (FL)
ARKWRIGHT
BOWEN
SCHERER
COUNCIL BLUFFS
IQUA FALLS
LANSING
LOUISA
PRAIRIE CREEK
off-sitt landfill
STREETER
CRAWFORD
off-sitt landfill
PEARL
off-»ita landfill
WAUKEGAN
off-sitt landfill
BAILLT
off-sitt landfill
CAYUGA
CLIFTY CREEK
EU STOUT
HT PRITCHARO
MEROM
MICHIGAN CITY
WHITEWATER VALLEY
NEARMAN CREEK
HENDERSON ONE
HENDERSON TWO
off-sitt landfill
NANTICOKE
ADVANCE
off-sitt landfill
COLDUATER
off-sitt landfill
JH CAMPBELL
JH WARDEN
ALLEN S KING
off-sitt landfill
NIBBING
off-sitt landfill
LITCHFIELO
NORTHEAST
RED WING
VIRGINIA
off-sitt landfill
POPULATION WITHIN FIVE CONCENTRIC RINGS (KM)
NUMBER OF TOTAL
ST GEN.UNITS 0-1 1-2 2-3 3-4 4-5 POPULATION
AL
AR
AZ
AZ
AZ
AZ
CO
CO
CO
CO
FL
FL
FL
FL
FL
GA
GA
GA
IA
IA
IA
IA
IA
IA
IL
IL
IL
IN
IN
IN
IN
IN
IN
IN
IN
KS
KY
KY
MD
MD
MI
MI
MI
MI
NN
MN
NN
3
2
3
3
2
2
3
3
3
1
1
6
2
1
2
4
4
4
3
1
4
1
4
2
2
1
2
2
2
7
3
4
2
3
2
2
2
2
2
1
3
3
3
1
1
3
1
1
2
3
314
0
0
0
0
0
626
49
480
0
0
0
0
0
0
2176
0
0
0
0
0
3141
0
0
0
448
3708
300
0
2107
0
0
0
0
0
0
0
3423
0
2403
0
0
300
0
0
0
1529
374
0
1065
21
0
0
0
0
0
0
0
0
522
4894
0
0
0
1644
6
74
0
0
0
' 0
0
0
141
3030
0
0
2696
5722
6099
10862
0
10278
0
0
0
678
0
360
6605
5361
0
5512
0
0
0
0
1020
0
971
0
0
3381
3522
1446
100
0
0
0
0
190
190
7645
22366
0
0
0
0
110
658
0
1125
1280
1903
740
0
0
1424
0
0
7116
17827
2781
27883
0
6938
2570
0
OOOO
6604
0
0
6617
7558
383
4936
0
0
0
540
4157
2206
0
0
0
6028
2368
1797
11
0
818
0
1016
0
0
17558
29981
0
1872
0
8393
1306
4528
0
9099
0
657
0
0
1744
0
0
4
12854
16720
12251
29225
0
5353
1290
1457
5629
14770
0
0
11564
14346
12069
8271
0
1189
766
313
5263
0
697
0
0
3842
0
8704
913
1748
370
0
10
0
0
37735
40235
0
3670
1027
19020
353
7818
1669
21917
0
5356
158
0
441
0
419
544
16078
15600
20675
54890
170
6210
8073
0
2688
22169
1630
0
8107
9374
14912
369
3032
2367
0
0
0
0
358
0
88
3028
810
11600
895
2062
1188
0
1026
190
190
64086
97525
480
5542
1027
29057
1775
13078
1669
34317
1280
7916
898
0
2326
7595
419
548
38744
56317
45514
123160
170
30886
11933
1457
15003
44221
1630
360
32893
40062
27364
21491
3032
3556
1066
853
10440
2206
3555
374
88
17344
6721
23547
1919
1129
3351
5182
7650
17312
-------
PLANT NAME
MCWILLIAMS
INDEPENDENCE
CORONADO
NAVAJO
SPRINGERVILLE 143
SPRINGERVILLE 2
CHEROKEE
off-sit* landfill
CRAIG
off-sit* landfill
NUCLA
off-sit* landfill
VALMONT
DEERHAVEN
FJ GANNON
LANSING SMITH
MCINTOSH
SEMI MOLE (FL)
ARKURIGHT
BOUEN
SCHERER
COUNCIL BLUFFS
I QUA FALLS
LANSING
LOUISA
PRAIRIE CREEK
off-sit* landfill
STREETER
CRAWFORD
off-sit* landfill
PEARL
off-sit* landfill
UAUKEGAN
off-sit* landfill
BAILLY
off-sit* landfill
CAYUGA
CLIFTY CREEK
EW STOUT
HT PRITCHARO
MEROM
MICHIGAN CITY
WHITEWATER VALLEY
NEARNAN CREEK
HENDERSON ONE
HENDERSON TWO
MORGANTOWN
off-sit* landfill
NANTICOKE
ADVANCE
off-sit* landfill
COLDWATER
off-sit* landfill
JH CAMPBELL
JH WARDEN
ALLEN S KING
off-sit* landfill
NIBBING
off-sit* landfill
LITCHFIELD
NORTHEAST
RED WING
VIRGINIA
off-sit* landfill
DRASTIC VELOCITY DEPTH TO HYDRAULIC NET GROUND -WATER
ST CODE OF AQUIFER GROUND WATER CONDUCTIVITY PERMEABILITY RECHARGE HARDNESS
AL
AR
AZ
AZ
AZ
AZ
CO
CO
CO
CO
FL
FL
FL
FL
FL
GA
GA
GA
IA
IA
IA
IA
IA
IA
IL
IL
IL
IN
IN
IN
IN
IN
IN
IN
IN
KS
KY
KY
MD
MO
MI
MI
MI
MI
MN
MN
MN
MN
MN
MN
10Ab
6Fa
48
48
2D
20
6Fb
6Fb
4A
4A
48
6Db
11C
110
11D
11C
118
86
6Fb
8E
TEa
TEb
TEa
TEb
TEb
7G
TEb
TEb
TAa
TC
TF
TEa
TEa
TEb
TEa
TAc
TH
TAc
TEa
6Fb
6Da
10Ab
1Mb
TBa
TAc
TF
TH
TBb
9Da
90a
TAa
TEb
TEa
90a
-130
100
1485
1485
220
-220
100
100
T5-T500
T5-T500
1485
T42.5
300*
3TO-500
370-500
300*
-30
500
100
500
30
30
30
30
-1500
-30
30
-1500
400
-300
30
30
30
30
-3250
100
3250
30
100
T42.5
130
100-200
500-1000
-3250
300
100
T50*
T42.5
T42.5
1500
30
30
T42.5
(F**t)
5-15
15-30
50- T5
50-T5
30-50
30-50
5-15
5-15
T5-100
T5-100
50-T5
10
0-5
5-15
5-15
0-5
5-15
5-15
5-15
5-15
5-15
5-15
5-15
15-30
5-15
15-30
5-15
5-15
30-50
15-30
15-30
15-30
5-15
5-15
10-20
30-50
0-5
30-50
5-15
5-15
15-30
5-15
0-5
5-15
30-50
15-30
0-5
0-5
15-30
5-15
10-20
5-15
10-20
15-30
(Gal/day/sq.ft)(Gal/day/sq.ft)240
>240
120-180
180-240
>240
80-120
80-120
120-180
180-240
>240
>240
. >240
>240
>240
>240
>240
180-240
>240
>240
>240
>240
>240
>240
>240
>240
>240
180-240
120-180
80-120
<80
<80
180-240
>240
>240
120-180
>240
180-240
180-240
>240
>240
>240
180-240
-------
PLANT NAME
ASBURY
BLUE VALLEY
CHAMOIS
HENDERSON (MS)
BELEWS CREEK
CAPE FEAR
CLIFFSIOE
HESKETT
OLIVER COUNTY
off-tit* landfill
NEBRASKA CITY
BL ENGLAND
RATON
ACME
off-ait* landfill
ASHTABULA
off-ait* landfill
JM STUART
PI QUA
POSTON
RE BURGER
off-ait* landfill
WC BECKJORD
off-ait* landfill
UN SAMNIS
atrip nin* diapoaal
HUGO
HOLTWOOO
off-ait* landfill
HOMER CITY
MITCHELL (PA)
off-aita landfill
SEUARD
CROSS
UROUHART
FOREST GROVE
GIBBONS CREEK
off-ait* a)in*ftll
JT DEELY
SAN MIGUEL
SANDOU
BQHAHZA
CHESTERFIELD
POTOMAC RIVER
off-aita landfill
CENTRALIA
off-ait* landfill
COLUMBIA
GENOA
HARRISON
KANAWHA RIVER
MITCHELL
MOUNTAINEER
PHILIP SPORN
NAUGHTON
POPULATION WITHIN FIVE CONCENTRIC RINGS (KM)
NUMBER OF TOTAL
ST GEN.UNITS 0-1 1-2 2-3 3-4 4-5 POPULATION
MO
MO
MO
MS
NC
NC
NC
NO
NO
NE
NJ
MM
OH
OH
OH
OH
OH
OH
OH
OH
OK
PA
PA
PA
PA
SC
sc
TX
TX
TX
TX
TX
UT
VA
VA
WA
WI
WI
WV
WV
WV
WV
WV
WY
1
3
2
2
2
4
1
2
1
1
2
2
3
5
4
4
4
5
6
7
1
1
3
1
2
4
3
1
1
2
2
1
2
4
5
2
2
3
3
1
2
1
5
3
0
0
0
0
0
0
0
0
0
0
0
1447
4762
530
198
0
1927
0
0
0
429
0
0
0
0
0
675
0
0
0
0
0
492
0
0
0
0
1940
1216
0
0
0
724
0
0
0
0
0
0
0
0
1009
0
982
0
0
0
2473
3267
22356
4424
939
0
7682
0
0
429
0
0
439
0
0
0
4358
675
0
1489
0
0
0
0
0
0
716
9266
2151
0
283
1237
1786
0
697
908
0
0
560
0
0
0
190
0
0
0
0
595
3511
29567
17427
3940
0
6147
373
991
0
0
0
0
1584
1584
0
1485
0
0
0
0
0
0
97
0
0
204
19344
3811
0
0
2269
2986
0
211
0
0
0
11234
0
809
0
1047
0
3115
0
0
3685
0
47606
24150
2494
1657
5523
2383
0
2266
3274
4045
0
797
797
2772
9391
0
0
662
503
0
1059
0
0
0
2277
24307
6096
1215
0
2091
2572
2181
4880
960
0
0
5225
683
1329
0
0
1412
4166
0
0
14370
0
31578
38884
3732
1283
1302
1065
0
1785
5779
2443
0
0
0
2544
6509
4222
488
6348
1221
0
938
0
0
0
4349
35048
4642
0
787
2946
3152
1970
255
2974
0
0
17019
683
2138
1009
1237
2394
7281
0
0
21123
8225
135869
85415
11303
2940
22581
3821
991
4480
9482
6488
439
2381
2381
5316
22418
4897
488
8499
1724
0
2489
97
0
0
7546
89905
17916
1215
1070
8543
11220
4151
6043
4842
0
-------
PLANT NAME
ASBURY
BLUE VALLEY
CHAMOIS
HENDERSON (MS)
BELEWS CREEK
CAPE FEAR
CLIFFSIDE
HESKETT
OLIVER COUNTY
off-sit* landfill
NEBRASKA CITY
BL ENGLAND
RATON
ACME
off-sit* landfill
ASHTABULA
off-site landfill
JM STUART
PI QUA
POSTON
RE BURGER
off-sitt landfill
UC BECKJORD
off-sit* landfill
UN SAMMIS
strip mint disposal
HUGO
HOLTUOOD
off-sit* landfill
HOMER CITY
MITCHELL (PA)
off-sit* landfill
SEUARO
CROSS
URQUHART
FOREST GROVE
GIBBONS CREEK
off-sit* Mincfill
JT DEELY
SAN MIGUEL
SANOOU
BONANZA
CHESTERFIELD
POTOMAC RIVER
off-sit* landfill
CENTRAL I A
off-sit* landfill
COLUMBIA
GENOA
HARRISON
KANAUHA RIVER
MITCHELL
MOUNTAINEER
PHILIP SPORN
NAUGHTON
DRASTIC VELOCITY DEPTH TO HYDRAULIC NET GROUND-WATER
ST CODE OF AQUIFER GROUND WATER CONDUCTIVITY PERMEABILITY RECHARGE HARDNESS
MO
MO
MO
MS
NC
NC
NC
NO
ND
NE
NJ
MM
OH
OH
OH
OH
OH
OH
OH
OH
OK
PA
PA
PA
PA
SC
SC
TX
TX
TX
TX
TX
UT
VA
VA
UA
WI
WI
WV
WV
WV
WV
WV
WY
60b
TEa
TEa
10C
8C
8E
86
TEb
7A*
TEa
10C
68
TEb
TF
TF
TEb
TEb
6B
6Da
6Fb
TA*
6Da
6Fb
80
80
60a
6A
6Fb
10C
8E
10Ab
lOAb
10Ab
10Aa
60b
40
8E
80
1Eb
6Fa
6Fa
6Fb
6Fb
6Fb
6Fb
6Fb
48
-T42.5
-30
-30
100-200
-3000
-500
500
-30
T.5-T50
-30
100-200
-130
-300
-300
30
30
-130
T42.5
T.5-T50
T42.5
100
-148.5
-148.5
-T42.5
T5-T500
100
100-200
-500
-130
-130
-130
3000-
-T42.5
100-300
-500
-148.5
130
100
100
100
100
-100
-100
-100
1485
(F**t)
15-30
15-30
5-15
0-5
30-50
5-15
5-15
5-15
30-50
0-10
0-5
15-30
5-15
15-30
15-30
5-15
5-15
15-30
15-30
5-15
30-50
15-30
5-15
5-15
5-15
15-30
30-50
5-15
0-5
5-15
5-15
5-15
5-15
100*
15-30
50- T5
0-5
5-15
5-15
0-5
0-5
5-15
5-15
5-15
5-15
5-15
50-T5
(Gal/day/sq.ft)(Gal/day/sq.ft)( inches) (ppm CaC03)
1-100
700-1000
700-1000
1000-2000
100-300
1000-2000
1000-2000
TOO- 1000
1-100
700-1000
1000-2000
700-1000
700-1000
100-300
100-300
700-1000
700-1000
700-1000
1-100
1000-2000
1-100
1-100
1000-2000
1-100
1-100
1-100
1-100
1000-2000
1000-2000
1000-2000
700-1000
700-1000
700-1000
300-700
1-100
100-300
1000-2000
1-100
700-1000
1000-2000
1000-2000
1000-2000
1000-2000
1000-2000
1000-2000
1000-2000
1-100
1.0E+00
1.0E-01
1.0E-02
1.0E+04
1.0E-04
1.0C-01
1.0E-01
1.0E+04
1.0E-03
1.0E-02
1.0E+04
1.0E+01
1.06+04
1.0E*02
1.0E+02
1.0E+04
1.0E+04
1.0E+02
1.0E-03
1.0E+04
1.0E-03
1.0E-04
1.0E+04
1.0E-03
1.0E-03
1.0E-03
1.0E-03
1.0E+04
1.0E+04
1.0E-01
1.06+04
1.0E+04
1.0E+04
1.0E-02
1.0E-01
1.06+01
1.0E+02
1.0E+01
1.06+04
1.06-02
1.0E-02
1.0E+04
1.0E+04
1.06+04
1.06+04
1.0E+04
1.0E-03
4-T
4-T
4-T
10*
2-4
MO
T-10
10*
4-7
4-7
10*
4-7
10*
4-7
4-7
10*
10*
4-7
4-7
T-10
4-T
4-T
T-10
4-T
4-T
4-T
0-2
T-10
10*
T-10
10*
10*
10*
0-2
4-T
0-2
T-10
4-T
4-T
T-10
T-10
T-10
T-10
T-10
T-10
T-10
0-2
120-180
180-240
>240
<80
80-120
<80
80-120
>240
>240
180-240
<80
120-180
>240
>240
180-240
>240
>240
>240
>240
>240
>240
>240
80-120
80-120
80-120
>240
>240
120-180
<80
<80
<80
<80
120-180
120-180
<80
180-240
80-120
80-120
<80
>240
>240
180-240
180-240
>240
>240
>240
>240
-------
PLANT NAME
NCWILLIANS
INDEPENDENCE
CORONADO
NAVAJO
SPRINGERVILLE 143
SPRINGERVILLE 2
CHEROKEE
off -sit* landfill
CRAIG
off -sift landfill
NUCLA
off -sit* landfill
VALNONT
OEERHAVEN
FJ GANNON
LANSING SMITH
MCINTOSH
SEMI MOLE (FL)
ARKWRIGHT
BOUEN
SCHERER
COUNCIL BLUFFS
I QUA FALLS
LANSING
LOUISA
PRAIRIE CREEK
off -ait* landfill
STREETER
CRAWFORD
off-sita landfill
PEARL
off-sita landfill
UAUKEGAN
off-sita landfill
BAILLT
off-sita landfill
CAYUGA
CLIFTY CREEK
EW STOUT
HT PRITCHARO
HERON
MICHIGAN CITY
WHITEWATER VALLEY
NEARNAN CREEK
HENDERSON ONE
HENDERSON TWO
MORGANTOUN
off-sita landfill
NANTICOKE
ADVANCE
off-sita landfill
COLDWATER
off-sita landfill
JH CAMPBELL
JH WARDEN
ALLEN S KINO
off-sita landfill
NIBBING
off-sita landfill
LITCHFIELD
NORTHEAST
RED WING
VIRGINIA
off-sita landfill
DISTANCE
TO
STSURFACE WATER
(meters)
AL
AR
AZ
AZ
AZ
AZ
CO
CO
CO
CO
FL
FL
FL
FL
FL
GA
GA
GA
IA
IA
IA
IA
IA
IA
IL
IL
IL
IN
IN
IN
IN
IN
IN
IN
IN
KS
KY
KY
MD
MD
MI
MI
MI
MI
MN
MN
MN
MN
MN
MN
SURFACE WATER NAME MINFLOW
MAXFLOW
(ft(3)/sacond)
50
340
7900
3230
9800
9500
80
350
2600
1850
4400
12
1000
35
30
90
2200
700
200
125
170
15
200
970
180
620
1150
65
2100
4150
1200
210
265
80
240
2200
25
1300
550
80
450
3750
20
220
1130
420
100
740
950
4600
200
200
180
800
Conacuh Rivar
Whita Rivar
Carrizo Wash
Colorado Rivar
Littla Colorado Rivar
Littla Colorado Rivar
South Platta Rivar
Clear Crack
Yaapa Rivar
Yampa Rivar
San Migual Rivar
South Bouldar Creek (Valmont Ras)
Sanchaz Prairia Swamp (Turkey Cra
Hillsborough Bay (salt)
North Bay (salt)
Laka Parker
St. Johns Rivar
Ocaulgee Rivar
Etowah Rivar
Ocaulgaa Rivar
Missouri Rivar
Iowa Rivar
Mississippi Rivar
Nisssissippi Rivar
Cedar Rivar
Cedar Rivar
Cedar Rivar
Das Plains* Rivar
South Fork Mckee Creek
Laka Michigan
Deep River (Duck Creak)
Wabash Rivar
Ohio Rivar
Whita Rivar
Whit* Rivar
Wabaah River (Turtle Creek)
Laka Michigan
East Fork Whitewater River
Missouri Rivar
Ohio Rivar
Green River
PotoMC Rivar
Nanticoka River
Laka Michigan (Inwood Creak)
South Laka (Coldwater River)
Pigeon Laka (Laka Michigan)
Laka Superior
Laka Jane
Welcome Rivar
East Swan Rivar
Jawitta Creek
Cedar Rivar
Mississippi River
Pike Rivar
357
5740
0
6830
0
0
92.4
84.4
202
202
77.9
7.68
0
0
0
0
3240
1190
1480
1160
14600
126
16800
32000
964
964
964
383
62.7
0
46.4
2820
26800
583
697
3790
0
31
17500
34100
3520
7050
297
0
34
0
0
0
18
25.2
2.35
26.2
8450
3.84
1850
22600
0
41600
0
0
676
552
5270
5270
1040
256
0
0
0
0
12800
5230
3980
3970
44900
753
69000
102000
5030
5030
5030
1980
200
0
287
15900
257000
3900
4660
21100
0
269
71600
309000
31800
21600
1230
0
186
0
0
0
41.7
413
44.4
137
36300
107
PUBLIC WATER SYSTEMS
WITHIN DOWNGRADIENT
(distance in maters)
.
.
.
.
.
1700; 1900:236400
700; 5500; 6100
.
-
182500; 132600
-
.
23600; 132400; 235500;
6100
-
.
.
.
.
100
-
.
.
14 8 4400
.
286400; 488400
(PWS)
PLUME
137000
282100; 28600; 136700
386700
-
4900
.
.
.
.
-
7400
100
200
.
700
-
-
100 (prob)
184400; 185000
281400
2400
.
800
-
-------
PLANT NAME
MCUILLIAMS
INDEPENDENCE
CORONADO
NAVAJO
SPRINGERVILLE 1*3
SPRINGERVILLE 2
CHEROKEE
off -site landfill
CRAIG
off -site landfill
NUCLA
off -site landfill
VALNONT
DEERHAVEN
FJ GANNON
LANSING SMITH
MCINTOSH
SEMINOLE (FL)
ARKURIGHT
BOWEN
SCHERER
COUNCIL BLUFFS
I QUA FALLS
LANSING
LOUISA
PRAIRIE CREEK
off -site landfill
STREETER
CRAWFORD
off -site landfill
PEARL
off -site landfill
UAUXEGAN
off -site landfill
BAILLY
off -site landfill
CAYUGA
CLIFTY CREEK
EW STOUT
NT PRITCHARD
MEROM
MICHIGAN CITY
WHITEWATER VALLEY
NEARMAN CREEK
HENDERSON ONE
HENDERSON TWO
MORGANTOWN
off -site landfill
NANTICOKE
ADVANCE
off -site landfill
COLDWATER
off-site landfill
JH CAMPBELL
JH WARDEN
ALLEN S KING
off-site landfill
NIBBING
off-site landfill
LITCHFIELD
NORTHEAST
RED WING
VIRGINIA
off -site landfill
DISTANCE
STSURFACE
(meters)
AL
AR
AZ
AZ
AZ
AZ
CO
CO
CO
CO
FL
FL
FL
FL
FL
GA
GA
GA
IA
IA
IA
IA
IA
IA
IL
IL
IL
IN
IN
IN
IN
IN
IN
IN
IN
KS
KY
KY
MD
NO
MI
MI
MI
MI
MM
MM
MN
MN
MN
MN
TO
WATER
SURFACE WATER NAME
MINFLOW
MAXFLOW
(ft(3)/second)
SO
340
7900
3230
9800
9500
80
350
2600
1850
4400
12
1000
35
30
90
2200
700
200
125
170
15
200
970
180
620
1150
65
2100
4150
1200
210
265
80
240
2200
25
1300
550
80
450
3750
20
220
1130
420
100
740
950
4600
200
200
180
800
Conecuh River
White River
Carrizo Wash
Colorado River
Little Colorado River
Little Colorado River
South Platte River
Clear Creek
Yanpa River
Yampa River
San Miguel River
357
5740
0
6830
0
0
92.4
84.4
202
202
77.9
South Boulder Creek (Valmnt Res) 7.68
Sanchez Prairie Swamp (Turkey
Hillsborough Bay (salt)
North Bay (salt)
Lake Parker
St. Johns River
Ocmulgee River
Etowah River
Ocnulgee River
Missouri River
Iowa River
Mississippi River
Misssissippi River
Cedar River
Cedar River
Cedar River
Des Plaines River
South Fork Mckee Creek
Lake Michigan
Deep River (Duck Creek)
Wabash River
Ohio River
White River
White River
Wabash River (Turtle Creek)
Lake Michigan
East Fork Whitewater River
Missouri River
Ohio River
Green River
Potonec River
Nan ti coke River
Lake Michigan (Inwood Creek)
South Lake (Coldwater River)
Pigeon Lake (Lake Michigan)
Lake Superior
Lake Jane
Welcome River
East Swan River
Jewitts Creek
Cedar River
Mississippi River
Pike River
Cre 0
0
0
0
3240
1190
1480
1160
14600
126
16800
32000
964
964
964
383
62.7
0
46.4
2820
26800
583
697
3790
0
31
17500
34100
3520
7050
297
0
34
0
0
0
18
25.2
2.35
26.2
8450
3.84
1850
22600
0
41600
0
0
676
552
5270
5270
1040
256
0
0
0
0
12800
5230
3980
3970
44900
753
69000
102000
5030
5030
5030
1980
200
0
287
15900
257000
3900
4660
21100
0
269
71600
309000
31800
21600
1230
0
186
0
0
0
41.7
413
44.4
137
36300
107
PUBLIC WATER SYSTEMS
WITHIN DOWNGRADIENT
(distance in meters)
.
.
.
.
.
.
1700;1900;2a6400
700; 5500; 6100
-
-
-
-
182500; 132600
-
23600; 182400;285500;
6100
-
-
-
-
.
100
-
.
14 8 4400
-
286400; 438400
(PWS)
PLUME
187000
282100; 28600; 186700
386700
-
4900
.
-
-
-
-
7400
100
200
-
700
-
-
100 (prob)
184400; 185000
281400
2400
-
800
-------
PLANT NAME
AS8URY
BLUE VALLEY
CHAMOIS
HENDERSON (MS)
BELEWS CREEK
CAPE FEAR
CLIFFSIDE
HESKETT
OLIVER COUNTY
off-site landfill
NEBRASKA CITY
BL ENGLAND
RATON
ACME
off -sit* landfill
ASHTABULA
off -sit* landfill
JM STUART
PI QUA
POSTON
RE BURGER
off -site landfill
UC BECKJORD
off -site landfill
UH SAMMIS
strip mint disposal
HUGO
HOLTWOOD
off -sit* landfill
HOMER CITY
MITCHELL (PA)
off-sita landfill
SEWARO
CROSS
URQUHART
FOREST GROVE
GIBBONS CREEK
off-sita minefill
JT DEELY
SAN MIGUEL
SANDOU
BONANZA
CHESTERFIELD
POTOMAC RIVER
off-sita landfill
CENTRALIA
off-sita landfill
COLUMBIA
GENOA
HARRISON
KANAUHA RIVER
MITCHELL
MOUNTAINEER
PHILIP SPORN
NAUGHTON
DISTANCE
STSURFACE
(maters)
MO
MO
MO
MS
NC
NC
NC
NO
NO
NE
NJ
NM
OH
OH
OH
OH
OH
OH
OH
OH
OK
PA
PA
PA
PA
SC
SC
TX
TX
TX
TX
TX
UT
VA
VA
WA
WI
UI
UV
WV
UV
UV
UV
WY
TO
WATER SURFACE WATER NAME
4600 Spring River (Blackberry Creek)
1040 Little Blue River
40 Missouri River
1400 Yazoo River (Tchula Lake)
730 Dan River
50 Cape Fear River
50 Broad River
170 Missouri River
990 Nelson Lake (Square Butte Creek)
55 Missouri River
50 Great Egg Harbor Bay (salt)
3700 Raton Creek
20 Maumee river
50 Ottawa River
300 Lake Erie (Cowles Creek)
70 Ohio River
50 Great Miami River
250 Hocking River (Hamley Run)
1475 Pipe Creek
80 Ohio River
1350 Ohio River
1200 Ohio River (Croxton Run)
50 Red River
800 Susquehanna River
660 Susquehanna River
1770 Two Lick Creek
850 Monongahela River (Peters Creek)
10 Cone ma ugh River
340 Lake Moultrie
90 Savannah River
180 Walnut Creek
2200 Navasota River (Panther Creek)
4450 San Antonio River
1200 La Parita Creek
100 Alcoa Lake
18000 White River
40 James River
120 Holmes Run (Backlick Run)
930 Chehalis River
100 Wisconsin River
50 Mississippi River
400 West Fork River
30 Kanawha River
40 Ohio River
80 Ohio River
90 Ohio River
700 Hams Fork
PUBLIC WATER SYSTEMS (PWS)
MINFLOU MAXFLOU WITHIN OOWNGRADIENT PLUME
(ft(3)/second) (distance in meters)
472
63.4
37700
11000
323
1690
1120
14700
133
17000
0
0.579
1100
35
0
22400
157
163
7.76
23000
23000
9850
4630
19700
19700
110
3510
562
0
6670
0.12
190
303
1.24
0
250
3580
18
181
4720
15200
378
4120
10200
14400
14400
20.7
1480 -
251
114000 -
41300 1600
684 600
5690 284800
2040 -
37900 1200
345
52500 -
0 -
7.37 -
11900
498 -
0 -
215000 800; 4900
1740 8500
1610 400; 2100;5200;8500
65.6 -
207000 -
207000 -
83300 286100 '
22100 -
66400 -
66400 -
619 283700
18300 -
3500 -
0 -
14800 -
48.6 -
1290 -
786 500 (prob)
12
0 -
2350
13600 -
76.5
5190 2000 (prob)
14400 -
62300
1990 1800 (prob)
23600 182100; 186700
86200 7300
122000 -
122000 -
829 -
-------
METHODOLOGY FOR CALCULATING THE COST OF
ALTERNATIVE HASTE MANAGEMENT PRACTICES
This appendix discusses how the cost estimates presented in Chapter Six in
terms of dollar per ton of waste disposed were calculated for different types
of waste disposal. These dollar per ton cost estimates included the costs of
current waste disposal practices and the costs of various measures to mitigate
potential environmental impacts.
The cost estimates in Chapter Six were developed primarily from two
reports:
Arthur D. Little, Inc., Full-Scale Field Evaluation of Waste
Disposal From Coal-Fired Electric Generating Plants. June
1985.
Utility Solid Waste Activities Group, Edison Electric
Institute, and the National Rural Electric Cooperative
Association, Report and Technical Studies On the Disposal and
Utilization of Fossil-Fuel Combustion By-Products. October
26, 1982.
The Arthur D. Little (ADL) study was funded by the Agency under EPA contract
68-02-3167. Its purpose was to evaluate current coal-fired electric generating
plants. Specific tasks involved characterizing coal-fired utility wastes,
gathering environmental data, assessing environmental effects, and evaluating
the engineering and costs associated with these disposal practices. The
Utility Solid Waste Activities Group (USWAG) report was submitted to EPA to
assist the Agency in meeting its mandate under Section 8002(n). This report
and its supporting technical studies analyzed the environmental and health
effects of the disposal and utilization of fossil fuel combustion by-products
from electric utility power plants.
-------
G-2
In these two reports, costs were presented for various disposal practices.
However, due to differences in analytical methods between the two studies it
was often difficult to compare the various cost estimates. To circumvent this
problem all disposal cost estimates in these studies were converted to the same
basic unit -- dollar per ton of waste disposed. That is, the cost for each
type of disposal procedure was expressed in terms of the cost to dispose of
each ton of waste generated over the life of the facility. It was felt that
this cost measure would allow comparisons to be made between the cost of
current waste management practices and the cost of alternative waste management
practices.
An example should help illustrate how the dollar per ton cost estimates
were developed throughout this report. In the ADL study the total cost of
basic waste disposal (i.e., disposal in unlined ponds or landfills) was shown
to vary as a function of the size of the electric power plant (e.g., see
Exhibit G-l). To convert these costs by power plant size into costs per ton of
waste disposed, estimates were made of the amount of waste generated as the
size of the power plant varied. There are several variables that can influence
the amount and type of waste generated at a power plant, including size of the
power plant, ash content of the coal, type of boiler, efficiency of the boiler,
utilization rate, and the type of pollution control technologies employed.
Despite these many variables, assumptions can be made to estimate the
approximate amount of waste that would be generated at a "typical" power plant.
For example, the "dollar per ton of waste disposed" estimates presented in
this report generally assume a 500 Mw power plant. This size was chosen to be
-------
EXHIBIT G-1
ANNUAL COST OF FLY ASH PLACEMENT AND DISPOSAL IN AN UNLINED POND
(late 1982 dollars)
«t
9
o
CO
O
O
Z
Z
70OO
600O
5OOO
4000
~ 30OO
2000
IOOO
0
0
I
LO
I
50O
1000 1500 2000
POWER PLANT CAPACITY (MW)
25OO
3OOO
Source: Arthur D. Little, Inc., Full-Scale Field Evaluation of Waste Disposal
From Coal-Fired Electric Generating Plants, June 1985.
-------
G-4
representative of a "typical" power plant, although the size of each generating
unit and the number of units at a site do vary (see Chapter Two for further
discussion). To determine the amount and type of waste generated at a 500 Mw
power plant, the following assumptions were made:
Coal Properties -- 2% sulfur, 13% ash, 10,500 Btu/lb.
Load Factor -- 70% (6132 hours per year)
Heat Rate -- 10,250 Btu per kilowatt-hour
S02 Removal -- 90% (wet lime scrubbing)
Lime Stoichiometry -- 1.1
Fly Ash/Bottom Ash Ratio -- 80%/20%
These assumptions were taken from the ADL study (see p. 1-17, Table 1.7) and
result in the annual production of 154,000 tons of fly ash (308 tons/Mw),
38,500 tons of bottom ash (77 tons/Mw), and 132,000 tons, (264 tons/Mw), of dry
FGD waste (if the power plant is scrubbing the flue gases).
To determine the cost per ton to dispose of the wastes produced from a 500
Mw power plant using these assumptions, the next step was to obtain the total
annual costs for waste disposal from the ADL study (see pages 6-74 to 6-130 of
the ADL study). For disposal in unlined ponds these costs were approximately
$1.3 million to $2.4 million for fly ash and $275,000 to $510,000 for bottom
ash. For landfill disposal these costs were about $785,000 to $5.1 million for
fly ash and $165,000 to $310,000 for bottom ash. All of these costs were in
late 1982 dollars.
-------
G-5
The ADL cost estimates (or cost estimates from other studies when
applicable) were then converted to fourth quarter 1986 dollars. This was
necessary to ensure that all costs reported in this study were consistent with
one another. The GNP implicit price deflator was used for this purpose. For
the fourth quarter of 1986, the value of this index was 115.2 (1982 - 100; late
1982 - 101.39). The ADL costs were escalated by 13.6 percent to obtain fourth
quarter 1986 cost estimates.
In fourth quarter 1986 dollars, the total annual costs for disposal in
unlined ponds would be about $1.4 million to $2.6 million for fly ash and
$310,000 to $580,000 for bottom ash. For landfills these annual costs would be
$890,000 to $1.7 million for fly ash and $185,000 to $350,000 for bottom ash.
These annual costs were divided by the total amount of each type of waste
produced annually to determine the cost per ton of waste disposed annually at a
representative 500 Mw power plant. For ponding these costs are $9 to $17 per
ton for fly ash (e.g., assuming production of 154,000 tons of fly ash then $1.4
million t 154,000 tons - $9.09 per ton) and $8 to $15 per ton for bottom ash
(assuming production of 38,500 tons of bottom ash). For landfills these costs
are about $6 to $11 per ton for fly ash and $5 to $9 per ton for bottom ash.
For some waste control strategies, such as liner installation, the cost per
ton will depend on the size of the disposal area affected. The size of a waste
disposal area will vary depending on the amount of waste generated, the type of
facility (landfill or pond), depth of disposal, amount of liquid present, and
frequency of dredging, among other factors. Given the amount of waste assumed
-------
G-6
in this analysis to be generated at a representative 500 Mw power plant, a
landfill was assumed to occupy 45 acres at a depth of about 30 meters and to
have an average lifetime of 20 years. A wet surface impoundment was assumed to
occupy 145 acres at a depth of 10 feet, with dredging occurring every five
years.
Using these size estimates for disposal areas, the increase in cost per ton
of waste disposed for installing a liner (or for other practices related to the
size of the facility) can be calculated. For example, in the ADL study the
installed cost of clay liners ranged from $4.40 to $15.50 per cubic yard (see
Arthur D. Little, Inc., p. 6-132). For a liner 36-inches thick, these
installed costs would lead to a cost range of $21,000 to $74,000 per acre. For
a 45-acre landfill, total costs would range from $945,000 ($21,000/acre X 45
acres) to $3.3 million ($74,000/acre X 45 acres), or about $140,000 to $480,000
on an annualized basis (using a 14.5 percent capital recovery factor, e.g.,
$945,000 X 0.145 - $137,025). Since 192,500 tons of waste are produced
annually, the increase in costs to install a clay liner is $0.70 ($140,000
divided by 192,500 tons) to $2.50 ($480,000 divided by 192,500 tons) per ton of
waste disposed.
Applying this same procedure for a 145-acre wet surface impoundment, total
costs would range from $3.0 million to $10.7 million, or $440,000 to $1.6
million on an annualized basis. This corresponds to about $2.25 to $8.10 per
ton of waste disposed.
-------
G-7
This approach was used throughout Chapter Six to develop the dollar per ton
cost estimates for current waste disposal activities and potential
alternatives. The technical and economic assumptions used to develop these
cost estimates (e.g., the capital recovery factor, disposal area size, etc.)
are representative for the electric utility industry. However, actual costs
may vary as a result of various site-specific factors that are not addressed in
this study.
Chapter Six also provides estimates of the impact of waste disposal on the
cost of generating electricity (e.g., see Exhibit 6-9 or 6-10). For these
estimates, the cost to generate electricity was assumed to be 18 mills ($0.018)
per kilowatt-hour at existing coal-fired power plants based on the following
assumptions:
A 500 Mw power plant operating in the Midwest.
No capital charges are included since the capital has already
been committed (i.e., it is a sunk cost).
No flue gas desulfurization equipment is required.
Capacity factor is 70 percent.
Heat rate is 10,000 Btu per kilowatt-hour.
Coal price is $1.50 per million Btu.
Operation and maintenance costs are about 3 mills ($0.003) per
kilowatt-hour, with disposal costs ranging from less than 0.5 to
1.0 mill depending on type of disposal practice.
For future coal-fired power plants the assumed generation cost was about 47
mills ($0.047) per kilowatt-hour based on the same assumptions except:
-------
G-8
Capital costs were approximately $1,100 per kilowatt, including
FGD equipment and associated transmission hookup charges.
Operation and maintenance costs were about 8 mills ($0.008) per
kilowatt-hour. These costs are higher compared to existing power
plants due to the additional operation and maintenance costs
associated with the FGD process.
In Exhibit 6-9 costs were also presented for generating electricity with
natural gas. At an existing gas-fired power plant, total generation costs were
assumed to be about 35 mill ($0.035) per kilowatt-hour based on the following
assumptions:
No capital charges are included since capital costs are sunk.
Capacity factor is 70 percent.
Heat rate is 9000 Btu per kilowatt-hour.
Gas price is $3.75 per million Btu.
Operation and maintenance costs are about 2 to 2.5 mills per
kilowatt-hour.
Generation costs at future gas-fired power plants were assumed to be about
49 mills ($0.049) per kilowatt-hour based on the same assumptions listed above
for existing gas-fired power plants except capital costs were included at a
cost of approximately $550 per kilowatt, including associated transmission
hookup charges.
------- |