1. Rochelle Routman, PG Environmental Specialist Georgia Power
Ash Management from Coal Fired Power Plants Current Practices and Potential Impact of Proposed EPA Regulation
Rochelle Routman, PG
Environmental Specialist
Georgia Power

2. Georgia Power: Who we are
Largest of four Southern Company electric utilities
2.3M+ customers
8,600 employees
Nearly 13,000 miles of transmission lines
70,000 miles of distribution
lines
High customer satisfaction
Rates below the national average
Gulf Power
Mississippi
Power
Georgia
Alabama
Alabama
Power
Georgia
Power

3. Coal US Resources The US has the largest reserves of coal in the world
Based on current consumption, there is about 200 years of accessible coal remaining to generate energy

4. Energy Generation Coal is Vital
45% of energy generated in the US is from coal
About 11% renewables, including hydro
Energy efficiency, clean coal technology, and renewables are necessary to meet energy needs of the future

5. Ash A coal combustion byproduct
Bottom Ash
Falls to the bottom of the furnace
Sluiced to an ash pond
Fly Ash
Collected by electrostatic precipitators
Either sluiced to an ash pond or handled in a dry landfill

6. Composition of Ash Dependant on coal source, combustion, etc.
Generally consists of silicon, aluminum, iron, and calcium
Also contains trace amounts of heavy metals, such as arsenic, selenium, chromium
Is classified as an industrial solid waste

7. Ash Handling Facilities
Ash Landfill
Ash Pond

8. Southern Co Ash Handling Practices
Fly Ash Production 2009: 3.9 Million Tons
Bottom Ash Production 2009: 1.0 Million Tons
Fly Ash Management 2009 (% of total)
Bottom Ash Management
2009 (% of total)
Wet -- 29%
Wet --74%
Dry -- 71%
Dry -- 26%
Dry includes landfilling and sending directly to silo for beneficial reuse

9. Southern Co. Beneficial Reuse About 30% Annually
Bottom Ash
Top Ash
Replacement for naturally mined aggregate (clay and shale)
Road base
Concrete block
Cement manufacturing
Ready-mix concrete
One ton of fly ash used as replacement for cement conserves landfill space to hold about 1200 lbs of waste, reduces the equivalent of 2 months of an automobile’s CO2 emissions, and saves the same amount of energy used by an average home for 19 days
(US EPA, April 2005, EPA-530-K )
Cement is the “glue” that binds together concrete to form a hardened product.
Technical benefits include increased strength, workability, and durability as well as lower cost

10. Georgia Power Ash Dam Safety
Inspections
Annual
Weekly
Daily
Training
Vegetation control
Instrumentation
Ash dam inspection by plant personnel

11. CCB Regulation Currently exempt from RCRA regulation
Bevill Amendment
Regulated as an industrial waste in Georgia
December 2008: Tennessee Valley Authority impoundment failure
Triggered ash pond dam inspections and proposed CCR rule
1980 Congress enacted the Solid Waste Disposal Act Amendments to RCRA, also known as the "Bevill Amendment," which excluded coal ash from Subtitle C regulation.

12. TVA Kingston, TN Spill December 22, 2008
Failure of dam containing fly ash
Approximately 5.4 million cubic yards of fly ash sludge were released into branch of Emory River

13. TVA Kingston, TN Spill

14. TVA Ash Spill Root Cause Analysis
According to TVA’s web site:
High water content of the wet ash
Increasing height of ash
Construction of the sloping dikes over the wet ash
Unusual bottom layer of ash and silt

15. EPA Ash Pond Inspections
As a result of TVA spill, EPA contractors inspected ash impoundment dam integrity
Tremendous effort by both EPA and the utilities
Each ash pond received condition rating
Reports are posted on EPA web site

16. EPA Ash Dam Inspections Condition Ratings
What it means
EPA rating of 228 units inspected to date (
Satisfactory
No safety deficiencies
106
Fair
Acceptable performance 67
Poor
Remedial action/ investigations needed 55
Unsatisfactory
Unsafe; immediate action required

17. Georgia Power Ash Dam Inspections Condition Ratings
What it means
EPA rating of 25 units inspected to date (
Satisfactory
No safety deficiencies 22
Fair
Acceptable performance 2
Poor
Remedial action/ investigations needed
1 - Conditional
Unsatisfactory
Unsafe; immediate action required
Ash Pond 2 - AP 2 was rated poor in the draft report because further critical studies or investigations were
needed to identify potential dam safety deficiencies. SCECS has provided additional
information to address most the critical issues. Acceptable performance is expected under all
required loading conditions (static, hydrologic. seismic) in accordance with the applicable safety
regulatory criteria. However, the potential for scour of the riverbank exists. That potential will
require special or extra inspections.

18. New Ash Rules Propose to Regulate CCRs = Coal Combustion Residues
CCRs generated by electric utilities and independent power producers
CCRs destined for disposal in
Landfills or
Surface impoundments

19. EPA’s Proposed Ash Rule: Two Main Options
RCRA Subtitle C Option: Hazardous waste regulation
RCRA Subtitle D Option: Non-hazardous, solid waste regulation
RCRA Subtitle D “Prime” Option
Slight variation of Subtitle D Option—“Useful Life”

20. Common Requirements Between Subtitles C and D
Dam Safety requirements
Design construction/maintenance documents; closure plans; inspections ; annual certification by an independent PE
Groundwater monitoring and Liners
Corrective action
Used when contamination is detected

21. RCRA Subtitle C Option “Special Waste” classification
Subject to most hazardous waste requirements
Includes CCRs intended for disposal, not CCRs intended for beneficial use
Federal permit required
Regulation from generation to disposal
Including during and after closure of disposal unit

22. RCRA Subtitle C Option Some Industry Implications
Ash Pond phase-out
Shortage of hazardous waste handling facilities
White House Council on Environmental Quality: Classifying ash as hazardous waste will add about 130 M tons annually to the 2.5 M tons of hazardous waste now disposed of annually
Likely decline in beneficial reuse due to stigma
American Concrete Association: Designation of fly ash as a ‘hazardous waste’ will likely eliminate its inclusion in future project specifications for fear of possible legal exposure and liability.
Designation as “special waste” will most likely not encourage beneficial reuse
EPA believes it will increase beneficial reuse
EPA deleted C2P2 website

23. RCRA Subtitle D Option State-led approach; no federal permits
EPA has no direct role
Performance Standards
More focused on performance than Subtitle C Option
E.g., national performance criteria for safe disposal in landfills

24. RCRA Subtitle D Option Some Industry Implications
Retrofit existing surface impoundments with composite liners within 5 years - or close.
Except for D Prime option
Effect of phasing out surface impoundments
Capacity shortages
Still higher costs; rate recovered

25. Public Comment Closing date November 19, 2010
EPA received 450,000 comments
Latest newsflash: Rule will not be finalized in 2011, due to the large amount of comments that EPA must review

26. Proper management of CCBs is an important part of the process of providing reliable, affordable, and environmentally responsible energy