DOE classifies report that finds no advantage in touted carbon capture technology

While most posts to this site focus directly on coal combustion wastes and other industrial byproducts, occasionally a related issue comes up that is seemingly less directly related to industrial waste but, never-the-less, must be addressed. Anything to do with so-called “clean coal” technologies fits in this category; first, because clean coal doesn’t exist (see the numerous communities and web sites devoted to exposing the dirty truth behind mountaintop removal and other forms of coal mining, as well as environmental justice groups fighting dirty coal burning power plants, or communities concerned about coal combustion waste placement in their backyards), and second, because even if coal magically showed up without a dirty mining, processing, or transporting legacy at a new “clean” coal burning power plant, that power plant would still produce CO2 (a greenhouse gas) and what the department of energy calls “coal utilization byproducts”. Yep — so-called clean coal plants still pollute and still produce coal combustion waste.

Another blog shed light recently on a blatant administration attempt to squelch the bad news on the infeasibility of so-called carbon capture technologies that are so readily touted by government and industry.

A July 6 blog post by Gas Turbine World magazine described a DOE/NETL (National Energy Technology Laboratory) report that was completed in February this year but has been held up internally “pending management approval” for months. As the blog post describes it, the NETL report, “Chilled Ammonia-based Wet Scrubbing for Post-Combustion CO2 Capture”, suggests that for CO2 capture “the new technology offers no advantage over currently available amine-based absorption systems in terms of cost or performance”. <http://gasification-igcc.blogspot.com/>

This is a big deal since, as the blog post goes on to describe: “The PC (pulverised coal) sector of the industry is touting chilled ammonia as the saving technology development that will preserve the viability of coal-burning steam plants in a carbon-restrained world.” [emphasis added]

It’s also a big deal for current projects in the works to attempt to demonstrate the chilled ammonia technology for CO2 capture. Current projects are planned in a couple of states, including West Virginia. As WBOY news reported in March, AEP plans to test the Alstom technology at its Mountaineer Power Plant. WBOY.com’s March news report optimistically continued: “The chilled ammonia process may offer a solution for existing pulverized coal plants — plants that many have thought would become too expensive to operate if federal climate change legislation regulates CO2 emissions.” <http://www.wboy.com/story.cfm?func=viewstory&storyid=21919>.

A July 11 Greenwire report noted that according to NETL, the report was never intended for an external audience, and that it “would remain classified unless the agency was compelled to release it under a Freedom of Information Act request.” The Greenwire article went on to say that utility industry officials say they know of the report, but have not seen “a formal copy”. <http://www.earthportal.org/news/?p=282>

Alleged “clean coal-burning” schemes are expensive and unrealistic, in addition to doing nothing to address the irreversible environmental damage that results from coal extraction in the first place. It’s time to stop mentioning coal — any type of coal, whether it’s “clean coal”, IGCC, coal-to-liquids, etc. — in any discussion of our energy future. Coal is dirty, it creates waste, and fossil fuels like coal (no matter how much you greenwash, change perceptions, or “offset” the consumption) contribute to climate destabilization.

Additional coverage of the DOE findings on chilled ammonia, including links to the DOE report:
http://gasification-igcc.blogspot.com/
http://www.environmentalnewsstand.com/epanewsstand_spclsubj.asp?s=energy
http://www.earthportal.org/news/?p=282

“Chilled Ammonia-based Wet Scrubbing for Post-Combustion CO2 Capture” can be found at carbon control news. This is a subscription service, but you can register for a free trial and view the report. http://www.carboncontrolnews.com/ccndocs/jul07/ccn07182007_netl.pdf

EPA misleads public on foundry sand reuse risks

In my last post (Industrial wastes are really “valuable commodities”, “like newspapers”, says EPA), I noted that EPA relegated a qualifying statement on the inherent unsuitability of some foundry sands for reuse projects to a footnote on its website <http://www.epa.gov/epaoswer/osw/conserve/foundry/index.htm>. Specifically, after discussing its support for various foundry sand recycling applications, EPA adds the footnote:

Foundry sands also come from other types of foundries, such as from brass and bronze foundries, that are often characteristically hazardous and are therefore not included in this statement.

This is noteworthy to me, because EPA also has posted on its website a brochure about industrial materials recycling that states:

Foundry sand (spent sand used in metal casting) can be recycled in road embankments, flowable and structural fill, and base and sub-base for road construction.

The full color promotional brochure that the above statement is taken from includes no information or disclaimer that some foundry sands may be hazardous and unsuitable for reuse applications. Why would EPA post information that at best is misleading, and at worst is conflicting, on its website?

As EPA and its trade association partners try to encourage state and local governments to use more industrial wastes in their projects, local decisionmakers and the public will increasingly be looking to EPA for guidance on what is safe and acceptable risk, and what is just unknown. If EPA can’t be trusted to disclose all of the truth about industrial waste reuse risk, then the public health can’t afford to be the guinea pig in this experiment of increasing industrial waste recycling.

The brochure also lists a few projects that have used recycled industrial wastes, as well as EPA’s website that promotes industrial materials recycling, and several trade associations (representing the coal ash, construction and demolition debris, and spent foundry sand recycling industries). Obvious omissions from this list of supporters are independent researchers, environmental advocates, environmental justice groups, etc.

Citizen groups, independent testing centers, and health and ecological risk analysis experts need to be involved in these EPA decisions and have access to all the information that EPA is sharing with its trade association partners. Otherwise, the decisions, publications, and projects that come out of EPA public-private partnerships like this one, will be stongly biased toward industry interests and will not adequately protect human health and the environment.

Industrial wastes are really “valuable commodities”, “like newspapers”, says EPA

“But it’s our job to try to sell everything our plants produce every day. Trying to find uses for materials that don’t necessarily meet specifications is a big challenge.” – Cheri Miller, market development specialist at TVA

“NEARLY EVERY industrial process, from manufacturing consumer goods, to generating energy, produces many different types of usable materials. These industrial materials can be recycled just like newspapers—both are valuable commodities.” – EPA’s Industrial Material’s Recycling Website

Recycling or reusing some byproducts may make sense, but only when the material in question will not result in greater harm through its reuse. Industrial wastes are generated in massive quantities in the U.S. — some by large coal-fired power plants, and some by smaller businesses that produce relatively high-volume waste (like foundries). There’s no doubt that these wastes are an indication of unsustainability of our system, and that we should aim to reduce virgin material consumption through source reduction and reuse whenever we can – safely. But what about all the industrial wastes that are untested, unquantified, lack quality controls, go unlabeled, etc.? Unfortunately, in a rush to promote so-called beneficial use of these industrial byproducts, industries and regulators are skipping some important product testing and risk management and quality control stages.

Standards for some materials do exist — but these standards are mostly engineering standards, not environmental or human health risk management plans. For example, Foundry Industry Recycling Starts Today (FIRST) <http://foundryrecycling.org/> includes examples on their website of foundry sand applications in highway construction. Compaction and moisture content recommendations are given, but there is no mention of which foundry sands might be unsafe… what about leaching of contaminants from the foundry sands, or degradation through use or construction projects on the road base…. what additional precautions should be taken when handling this material versus the usual material? How will workers be advised of potential hazards from contact?

EPA’s website for industrial waste recycling includes a footnote stating that some foundry sands are often characteristically hazardous and are not included in EPA’s goals for reuse and recycling of industrial byproducts. However, EPA keeps this as a footnote on a page that otherwise is all about extolling the virtues of recycling industrial wastes. EPA needs to be more clear about the types of waste that may not be safe in these applications, and the public will need to be vigilant about industrial waste recycling projects to ensure that additional and unnecessary hazardous wastes are not added to roads, used as soil amendments, or added to cement kiln raw materials or concrete products.

USDA is currently exploring benefits and risks of using waste foundry sand in agricultural and horticultural applications. In the meantime, hazardous foundry sands may be lumped into categories with all foundry sands when people casually discuss the issue <http://www.afsinc.org/pdfs/Final_Beneficial_Reuse_Guide.pdf>.

When any environmental testing is recommended in this arena, it is usually limited to the TCLP test. The TCLP test simulates engineered landfill conditions and is designed to determine if certain listed contaminants identified by US EPA are present in landfill leachate. This test may be appropriate for characterizing the waste in an engineered landfill, but it is not a sufficient safety test to determine other exposure risks from inhaling, handling, or trace element volatilization from industrial byproducts. Communities and project engineers will need to be careful when determining appropriate and safe uses for industrial byproducts if they are going to bring them into contact with people or food. We cannot just listen to the industry line on this one, and unfortunately, we can’t count on EPA to keep the facts transparent here either. We need to keep the pressure on EPA and industries to demonstrate the safety of their projects, or else to keep their industrial waste out of places where we might come into contact with it.  Wikipedia defines the precautionary principle as “a moral and political principle that states if an action or policy might cause severe or irreversible harm to the public, then in the absence of a scientific consensus that harm would not ensue, the burden of proof falls on those who would advocate taking the action.” We should encourage EPA to follow a precautionary principle approach to applications/uses of these wastes.  Let’s err on the side of caution and make sure that we don’t let the real testing of these waste applications happen in a manner that is irreversibly harmful to humans and the environment.

Sources for quotes:

http://www.eei.org/magazine/editorial_content/nonav_stories/2003-07-01-ccp.htm

http://www.epa.gov/epaoswer/osw/conserve/resources/ind-mat.htm

How EPA Helps Industries Claim Greenhouse Gas Reduction Credits for Adding Toxic Fly Ash to Buildings

Coal-burning utilities must be pretty excited about all the buzz they’re getting these days from the most unlikely of sources: green building enthusiasts. Somehow, with a lot of promotion and a little help from the government, coal-fired power plants are able to avoid costly disposal and waste management of their toxic byproduct, fly ash, by increasing the use of coal fly ash in cement admixes and concrete construction projects. Incredibly, after extracting the coal from the earth, processing it, burning it, and then hauling the captured solid leftovers from the coal smoke to cement and concrete suppliers, coal-burning industries are getting an environmental credit for reducing greenhouse gases and recycling a waste product. Let’s review how this happened….

Activities like coal mining and coal burning emit tons of greenhouse gases into the atmosphere. So does the process of making cement for concrete. Coal fly ash, a waste byproduct from burning coal, has certain cementitious properties (in addition to mutiple toxic elements like mercury) that mean that in some applications, it can be used as a partial replacement for energy-intensive Portland cement used in concrete. The American Coal Ash Association estimates that over 71 million tons of coal fly ash were produced in the U.S. in 2005 (1), making this toxic industrial waste an expensive waste management liability, unless someone else can be convinced to buy or use the waste (2) . This is where EPA and DOE weigh in. EPA conducted a skewed “comparison” of the greenhouse gas emissions from Portland cement raw material mining and manufacture, and the greenhouse gas emissions from using the coal burning byproduct fly ash (while specifically not including emissions from burning the coal to make the fly ash or from mining activities to obtain the coal in the first place)(3). EPA omitted greenhouse gas emissions from hauling, burning, or mining coal in their skewed comparison between coal burning and virgin cement manufacture emissions, resulting in a popular false claim that replacing Portland cement with coal fly ash reduces greenhouse gas emissions by one ton for every ton of Portland cement replaced (4).

While this analysis on its own is inherently flawed (see related page on the calculations), it also avoids discussion of the risk involved in adding a toxic industrial waste material to infrastructure and consumer products. Buildings and other projects constructed with coal fly ash cement are not labeled. People may not know what toxics could be volatilizing into the air from within the cement walls of their school or workplace, nor will demolition or construction crews be advised during building tear-down or construction that the dust coming up from the work site may contain fine particles laced with mercury, selenium, radium, chromium, lead, etc. There are no plans to label or treat infrastructure projects that handle drinking water sources differently, just as there are no health-based testing standards for these materials (current ASTM standards only address engineering properties of fly ash cement projects).

In addition, the entire process is built upon the continued burning of the dirtiest fossil fuel – coal. Increasing fly ash use and promoting fly ash cement as a “green” product ignores (greenwashes) enormous quantities of greenhouse gas emissions from burning coal, as well as the health of people who live near coal burning power plants, the people who will handle the fly ash cement, and the people who will be exposed to these fly ash cement construction projects. Giving environmental credit to these industries promotes polluting practices at the expense of the global climate and human and ecological health.

Coal fly ash is not a green construction material.

Sources:
1. http://www.acaa-usa.org/PDF/2005_CCP_Production_and_Use_Figures_Released_by_ACAA.pdf
2. The U.S. Department of Energy and EPA are funding projects to increase or promote utilization of coal combustion waste in many applications, including building, road construction, carpet backing, agricultural soil application, FGD gypsum wallboard, etc. DOE’s website cites a goal of increasing coal utilization byproduct use by 50% by 2010, in order to realize potential economic benefits in the range of $500 million to $1 billion < http://www.fossil.energy.gov/programs/powersystems/pollutioncontrols/overview_coalbyproducts.html>.
3. http://www.epa.gov/climatechange/wycd/waste/downloads/FlyAsh_11_07.pdf
4. Actually, EPA’s claims on ghg savings vary… see EPA Office of Solid Waste Director’s speech to American Coal Ash Association 2003 Annual Conference citing ton-for-ton savings <http://www.epa.gov/epaoswer/osw/conserve/speeches/c2p2.pdf> and C2P2 factsheet citing .8 tons CO2 saved per ton Portland cement replaced with fly ash <http://www.epa.gov/epaoswer/osw/conserve/c2p2/cases/burnout.pdf>, while the Department of Energy cites savings of .8 tons of CO2 for every ton of fly ash used in concrete <http://www.fossil.energy.gov/programs/powersystems/pollutioncontrols/overview_coalbyproducts.html>.