Coal combustion waste by any other name…. is still waste

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.)

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