The Coal Combustion Product Partnership

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• The Coal Combustion Product Partnership
• Opportunities and Challenges
• John Sager, USEPA
• C2P2 Coordinator
• July 26, 2006

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C2P2 Today

• C2P2 is 3 years old with 137 members.
• Department of Energy, Federal Highway
  Administration, American Coal Ash Association,
  and Utility Solid Waste Activities Group are
  considered major partners.
• C2P2 is generally regarded as a model Resource
  Conservation Challenge Program.
• CCP use increased from 31 in 2001 to 40 in
  2004, with total generation in 2004 of 122
  million tons, based the most recent ACAA survey.
• Successful C2P2 program development led to
  formation of the Industrial Recycling Council of
  secondary material industries and EPAs
  Industrial Material Recycling Team.
• 2006 C2P2 awards scheduled for National Recycling
  Council Congress in Atlanta in October with NRC
  adopting industrial materials as focus area.

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C2P2 Core Activities Today

• Membership and Award Program
• State reviews
• Technical assistance workshops
• Publications
• Outreach web site, fact sheets, case studies
• Related activities
• IWEM and risk assessment tool development
• Beneficial Use Summit support
• Green Highways
• Construction Initiative
• American Concrete Institute Sustainability
  Committee, ASTM committees, EPA Sector
  Strategies, Office of International Activities

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Membership and Award Program Highlights and Next
Steps

• Awards ceremony at World of Coal Ash Symposium in
  Lexington, KY in 2005 was a great success,
  invigorating the entire CCP industry.
• 2006 awards will be held at NRC congress in
  Atlanta in October. Details are still to be
  worked out, but this development highlights the
  success of C2P2 and the mainstreaming of
  industrial material recycling.
• Current membership roll is predominantly made up
  of CCP sellers. Significant increases in
  membership would likely require changes, such as
  more EPA staff devoted to recruiting (e.g.,
  account reps like Energy Star), and the
  development of incentives for consumers such as
  concrete companies and state DOTs to join.

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State Review Highlights and Next Steps

• Texas review report was published in 2005.
  Findings include
• --high rate of utilization (60 70)
• --supportive regulatory environment based on a
  history of cooperation between Texas CEQ and well
  organized industry.
• Florida review conducted in 2005 report expected
  in 2006. Findings include
• --high rate of utilization based on widespread
  residential and commercial construction and an
  estimated 500,000 tons of ash imported from out
  of state
• --significant quantity of fly ash generated in
  state can not be used in concrete due to air
  emission controls.
• --State regulations can be restrictive for land
  placement
• --Florida DEQ is considering new regulations.
  DEQ and CCP industry plan increased dialogue as a
  result of well received review.
• Northern state expected for review in 2006
• Plans are in the works for state review summary
  report to be led by DOE in 2007 or 2008.

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Technical Assistance Workshops Highlights and
Next Steps

• Successful 2005 workshops held in Puerto Rico,
  Atlanta, Chicago, Denver, Milwaukee and
  Washington, D.C.
• Puerto Rico workshops (2) were a major
  undertaking, involving meetings with industry and
  commonwealth offices of environment,
  transportation, agriculture, and economic
  development.
• Milwaukee workshop was the first of its kind for
  C2P2, held in conjunction with the University of
  New Hampshire and expanded to include foundry
  sands and other materials.
• Cosponsored workshop with OPEI on use of
  byproduct materials in cement kilns.
• 2006 workshop plans include early discussions
  with Regions 1 and 9 and targeted FHWA and DOT
  locations.

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Publications and Outreach Highlights and Next
Steps

• Health and Environmental Impacts booklet on
  highway construction (Green Book) published in
  2005 to positive reception
• Building construction resources web site created
  in 2006
• C2P2 web site continues in development and is a
  primary source of information
• Interagency agreement in place in 2006 2007 to
  begin update to FHWA User Guidelines for
  Industrial Byproduct Materials in Pavement
  Construction. Additional joint efforts to be
  identified.
• Analysis and report or booklet on use of flue gas
  desulfurization material planned for 2006-2007.
• Significant cooperation and interaction with
  Regions expected in 2006, including support of
  beneficial use summit in San Francisco and
  industrial material recycling training for
  regional EPA staff in October.
• Construction Initiative continues to hold promise
  for promoting C2P2 goals
• Report to Congress on mineral recycling due in
  2007 may have impact on federal purchasing of
  CCPs.

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IWEM and Risk Assessment Tool Development

• IWEM can be an effective tool for supporting
  beneficial use determinations. Use is slowly
  taking hold in States and Regions following
  release in 2003 (e.g., Minnesota guidance, Ohio
  reg development, and Region 8 solid waste
  conference).
• Results of IWEM assessment by University of New
  Hampshire due in 2006.
• C2P2-sponsored beneficial use modeling conference
  in New Hampshire held in 2005 attended by EMRAD
  and ORD was a great success.
• C2P2 will continue to promote development of
  monitoring data to assess and benchmark IWEM and
  3MRA.

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C2P2, Highways, and Building Construction

• Promoting use of CCPs in highway construction has
  occupied more resources to date than similar work
  in the area of building construction.
• Green Highways may afford opportunities for
  targeted workshops, changes in specifications,
  and possibly a third party certification process
  like LEED.
• --Increased dialogue between environmental and
  transportation planners is good.
• Biggest growth area for CCP use in concrete
  where GHG savings can be realized may be in
  building construction, not highways, as long as
  new asphalt continues to be used in highways.
• Emergence of American Concrete Institute
  Sustainability Committee provides a god
  opportunity for serious discussion about
  increasing use of CCPs in concrete.
• Development of a goal for use of supplementary
  cementitious materials (SCMS) in concrete,
  including coal ash, silica fume and cement kiln
  dust, may help promote GHG emission benefits
  associated with CCPs and other materials.

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Challenges and Opportunities

• EPA Strategic Plan goal of 50CCP recycling by
  2011
• Mercury emissions
• Low NOx burners
• National Academy of Sciences report "Managing
  Coal Combustion Residues in Mines"
• IWEM
• Report to Congress on mineral recycling
• Construction Initiative
• Green Highways

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Impact of Air Regulations

• Air regulations pose challenges for use of CCPs
  in some applications.
• Low NOx burners burn less carbon, which creates a
  fly ash that may not meet concrete specifications
  (e.g., specifications for coloration). For
  example, Florida has huge need for ash but does
  not use some of available in-State ash.
• Mercury issues are increasingly identified as
  barriers to CCP utilization.
• EPA Office of Air and Radiation has previously
  said they do not expect recent mercury
  regulations to significantly impact fly ash.
• ORD research suggests that mercury does not leach
  readily from CCPs, nor is off-gassing from
  wallboard a problem. Biggest concern in recent,
  draft ORD paper seems to be use of CCPs with
  mercury in cement kilns.

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Mercury and CCPs

• Many different applications and products for
  CCPs, need to consider impact of mercury in
  different situations
• C2P2 looks to EPA regulations for applicable
  limits
• EPAs Using Coal Ash in Highway Construction A
  Guide to Benefits and Impacts is the primary
  policy document produced by the Office of Solid
  Waste. It states
• Studieshave shown that mercury releases
  from coal ash to the environment are negligible.
  Results from water leachate tests showed that
  mercury was very stable in coal fly ash.
• Nonetheless, careful evaluation is necessary when
  considering land placement of CCPs near
  groundwater in road base or in fill, with respect
  to mercury and other metals.

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Mercury and CCPs

• C2P2 looks to EPAs Office of Research and
  Development and the Department of Energy for some
  of their research in this area. Please note work
  from Susan Thorneloe at EPAs Office of Research
  and Development and Bill Aljoe at DOEs National
  Energy Technology Laboratory.
• Proposed regulation of the use of fly ash as
  feedstock for cement kilns is an area of
  particular focus today. Please note work from
  Keith Barnett at EPAs Office of Air and
  Radiation.
• Worker safety in wallboard manufacture is another
  area of concern with respect to mercury

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Mercury Resources

• http//www.epa.gov/airmarkets/camr/index.html
• http//www.epa.gov/airmarkets/cair/index.html
• http//www.environmentalintegrity.org/pubs/Dirty2
  0Kilowatts.pdf (do a search for "mercury")
• Industry website http//www.mercuryanswers.org/
• Non-profit Annapolis Center site
  www.AnnapolisCenter.org

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CCPs in Cement Kiln Feed

• Following are some questions that can help
  determine the overall environmental impacts of
  using fly ash to produce clinker
• What are the mercury contents of fly ash (the DOE
  data should go a long way to answering that
  question)?
• What specific raw materials does the fly ash
  replace?
• What are the typical mercury contents of he
  replaced raw materials?
• What other impacts does the addition of fly ash
  have on the kiln, if any. Does it affect fuel
  use, does it affect other emissions? Are there
  any data to quantify these impacts? If not, can
  the impacts be estimated based on some type of
  combustion calculations?

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NAS Report "Managing Coal Combustion Residues in
Mines"

• The National Academy of Sciences (NAS) published
  the report "Managing Coal Combustion Residues in
  Mines" in March, 2006. which was requested by
  the EPA under the direction of Congress.
• The report generally supports the cautious use of
  mine placement of coal ash in appropriate
  circumstances.
• Free PDF downloads of the entire report, the
  summary and the press release are available on
  their website at http//www4.nationalacademies.org
  /news.nsf/isbn/0309100496?OpenDocument.

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Report to Congress on Mineral Recycling

• Report to Congress on use of recovered minerals
  in cement and concrete due in 2007
• Focus of report is on materials for which the EPA
  has procurement guidelines, including CCPs, slag,
  foundry sands and silica fume.
• The legislation calls for EPA to make
  recommendations as to how to increase the use of
  these materials.
• Workgroup participation is open to interested
  parties.

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Possible uses of IWEM to support industrial
material recycling goals

• How can IWEM, or any other model, help?
• Lets consider coal ash.
• C2P2 is a partnership program to promote the
  beneficial use of coal combustion products
  (CCPs).
• In 2004, 122 million tons of coal ash was
  generated by electric utilities in the United
  States, 49 million tons or 40 of which was put
  to beneficial use as CCPs.
• EPA has set a strategic plan goal to increase the
  recycling rate to 50 by 2011. How do we get
  there?

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Using IWEM to Increase Industrial Material
Recycling

• The highest environmental and economic value use
  of CCPs is the use of coal fly ash as a
  supplementary cementitious material (SCM) in the
  manufacture of cement and concrete.
• IWEM is not going to provide significant insight
  into the use of SCMs and other, above the ground,
  encapsulated uses. EPA has taken the position
  that we support and promote these uses.
• The real need is for help in making decisions
  about putting CCPs in the ground, as structural
  fill, in flowable fill, in embankments, in road
  base, and in soil modification.

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Using IWEM to Increase Industrial Material
Recycling

• While EPA does not have any formal policy in this
  area, it is arguable that use in embankments,
  flowable fill, and structural fill may be
  analogous to placement in a an unlined landfill
  or waste pile for which IWEM may be used in its
  current form.
• IWEM also has a land application module for which
  beneficial use is already addressed in the Guide.
• Modeling road base, sometimes known as linear
  landfill, is another area where IWEM may be
  helpful with appropriate modeling considerations
  about the length of roads, infiltration through
  road surfaces, and capillary effects at the edge
  of the road.
• Similar analogies and engineering evaluations can
  be made for in-ground applications with foundry
  sands, CD material, and other materials.

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Issues to Consider

• Minnesota was a leader in the development of IWEM
  and is the first State to incorporate the model
  into its regulations. Following are some of the
  issues they have encountered
• (1) What type of long term technical assistance
  can EPA provide? The manual can answer some
  questions, but interpretation of unusual results
  or input of new data often creates new questions.
  
• (2) There is a need for leachate data for
  construction and demolition disposal sites. Can
  EPA assist in identifying representative leach
  ate data and/or link leach ate data to various
  waste inputs? The pros and cons of using "real"
  leachate values vs. those from one of the
  leaching procedures may be helpful. (Boron is
  material that was discussed)
• (3) Some of the current levels in the IWEM
  database are out of date (e.g., MCL levels, other
  risk-based levels). These need to be updated to
  ensure the output...maximum leach ate value...is
  accurate and protective.

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Issues to Consider

• More Minnesota issues
• (4) There are some special issues with using IWEM
  for land application of leach ate or other
  materials (a) infiltration rate vs. dilution
  factor not always appropriate in a land
  application scenario (b) other factors like soil
  attenuation, etc are not accounted for, but would
  have a significant affect on public health
  safety. How can these be addressed by end users?
  This is an important decision for IWEM's use in
  ben. use decisions
• (5) What is the infiltration rate for composite
  liners...how was it developed and is it based on
  double composite liners and not the specific
  liner that IWEM prescribes?
• (6) How can you add unique liner designs?
• (7) Why does Tier 1 always looks at both the MCL
  and a HBN?
• (8) When is it appropriate to substitute a Kd
  value?
• (9) Decision needed on the use of HRLs or a of
  HRLs for use at the point of compliance in
  IWEM.

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Issues to Consider

• Additional considerations for use in modeling
  roadways
• 1. Length and width of the roadway source term
• 2. Widths of the two berms
• 3. Angle of the groundwater direction with
  respect to the roadway
• 4. Infiltration rates corresponding to the
  road-bed and the berms on either side of the
  road-bed.
• 5. The enhanced version will have to be tested
  and verified.
• 6. Demonstrations on the use of the enhanced
  version of IWEM are under consideration.
• 7. A user guide and the documentation may be
  provided along with copies of the enhanced IWEM.

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• For more information, contact
• John Sager
• USEPA
• Office of Solid Waste
• C2P2 Coordinator
• 703-308-7256
• sager.john_at_epa.gov