Coal combustion wastes have numerous aliases…. According to the American Coal Ash Association, EPA started using the term “coal combustion products (CCPs)” in 2002 (1). In the past (and still on occasion), EPA used the terms “fossil fuel combustion wastes (FFCW)”, “coal combustion byproducts (CCBs), and the broader “special” and “Bevill wastes”. <See EPA’s fossil fuel combustion waste website at http://www.epa.gov/epaoswer/other/fossil/index.htm>.
DOE’s National Energy Technology Laboratory calls these byproducts “coal utilization byproducts (CUBs), preferring the term “utilization” over “combustion” because “it accounts for gasification, which also produces solid by-products which must be managed” (2). EPA’s Office of Research and Development studies hazards of coal combustion wastes and calls them “coal combustion residues (CCRs)”. DOI’s Office of Surface Mining Reclamation and Enforcement uses “coal combustion byproducts”, as defined in 42 U.S.C. 13364(a), to describe coal combustion wastes in their recently published proposal for placement of coal combustion wastes in active and abandoned coal mines (3).
The above list of aliases used by various federal government agencies doesn’t include the more specific terms used to describe the different categories of coal burning waste such as fly ash, FGD sludge, bottom ash, etc., or even the list of acronyms (PFA, etc.) that can be found in use internationally. This can make it difficult for concerned communities to find relevant information on how these wastes are being used, regulated, managed, or what the potential health and environmental consequences may be from those various management or disposal schemes.
People concerned about the (mis)management of coal combustion wastes might do well to try to keep up with all these changes… otherwise, little changes in terminology here and there, department by department and agency by agency, can gradually change the landscape of regulation and public acceptance before it’s even realized.
Efforts to change perception seem to be relentless, even creating seeming internal inconsistencies between project start and final report. A recent report by the National Research Council, partly authored by the Committee on Mine Placement of Coal Combustion Wastes, and published by the National Academies Press, uses the term CCRs, stating that “although the term CCWs was used in the statement of task, after much discussion the committee chose to use the term CCR for the purposes of this report.” (Summary p. 3, <http://books.nap.edu/openbook.php?isbn=0309100496>)
The term “CCRs” is getting closer to what industry wants, but it’s still not as preferred as “CCPs”….
In fact, the industry has written whole papers on terms that are encouraged or discouraged for their apparent bias <www.mcrcc.osmre.gov/PDF/Forums/CCB3/2-1.pdf>. According to a January 2007 presentation to EPA by David Goss of the American Coal Ash Association, “although ash and CCPs are terms often used interchangeably, CCPs is the industry preferred terminology” (4).
Oh, so you mean that we should assume all coal combustion byproducts should be reused, no matter how it’s done or where they go, and that EPA should help you promote your waste material as a product so your industry can profit by avoiding disposal costs of this enormously high volume dangerous byproduct? I’m a supporter of recycling and reuse – when it’s safe – as much as the next person. I also strongly believe in avoidance of making the waste in the first place. Just because you recycle something – anything- it doesn’t mean that its original production was good for the environment, or that it’s original raw material mining or manufacture didn’t lead to its own waste. If I recycle X number of pounds of something per year, I haven’t done as much for the environment as if I had just not consumed those materials in the first place. Reusing coal combustion waste doesn’t make coal “clean” – it doesn’t retroactively reverse the impacts of mountaintop removal mining, it doesn’t stop the coal-cleaning waste, it doesn’t change the emissions from transporting the coal or the ccw to use, and it certainly doesn’t make the combustion process any cleaner.
Let’s watch to see what the final rule on placement of CCBs in coal mines terms these wastes — will DOI in the end change their terminology and use the industry-preferred term (CCPs)? (As an aside — throwing CCWs away in active or abandoned coal mines seems to me to be about as close to disposal vs. use as you can get.)
The industry has encouraged use of the term “product” with the hopes of alleviating public and government concern and negative associations with recycling “wastes” or “byproducts” into roads and buildings and consumer products. People who care about clean water and a clean environment can watch industry actions on this one — and take action. Write letters to the editor to clarify what these wastes are when articles appear touting supposed “beneficial use of coal combustion products”. Submit comments on proposed federal regulations or at hearings, and call the agencies out for their own industry-sensitive bias when you see it.
Coal combustion and coal gasification processes produce byproducts — high volumes of extremely variable wastes that vary by combustion process, flue gas treatment type, feed coal content or mix, pollution control mechanisms, etc. Regulations are needed to improve health and safety of this industry’s waste. Calling these byproducts “products” and selling them to roadbuilders, agricultural, or other use doesn’t change what they are… waste.
Notes
1. American Coal Ash Association (ACAA) website includes a discussion of EPA’s transition to the industry-preferred terminology on these wastes: http://www.acaa-usa.org/FAQ.htm
2. DOE Topical Report 24, “Clean Coal Technology: Coal Utilization By-Products”, August 2006, p.6 http://www.netl.doe.gov/technologies/coalpower/cctc/topicalreports/pdfs/Topical24.pdf
3. DOI OSMRE, Proposed Rule: Placement of Coal Combustion Byproducts in Active and Abandoned Coal Mines, March 14, 2007, Federal Register Vol.72, no.49, p.12025
4. Coal Combustion Products Basics: Presentation to EPA OSW, January 23, 2007, by David Goss (ACAA) www.epa.gov/epaoswer/non-hw/imr/irc-meet/05-coal.pdf
(Update: If EPA web server not properly working, click here to see text only version of above presentation. This presentation was part of a series of presentations to EPA by the Industrial Resources Council.)
