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To ensure that disposal of ash does not cause groundwater contamination, the Maryland Department of the Environment (MDE) has proposed regulations to control the disposal of coal combustion byproducts (CCBs) and the use of CCBs in mine reclamation. MDE has sent those regulations to the legislature and they are expected to be published in the Maryland Register on December 21, 2007. No federal program exists to regulate the management of these materials. The agency also will publish an Advanced Notice of Proposed Action in the same issue of the Maryland Register to solicit feedback and input from interested parties on MDE’s plans to promulgate regulations at a future date to define and regulate the beneficial use of CCBs. MDE began this effort in May 2007. The federal government has discussed similar regulations but after five years, has not yet moved forward. Recognizing that under certain conditions, disposal of these materials poses threats, MDE set a very tight timeline for developing this proposal.
CCBs are generated from burning coal. They are non-combustible and vary based on the type of combustion device. Fly ash is generally a dust-like gray material that is light weight and captured by air pollution control equipment. Bottom ash is heavier than fly ash and is captured at the bottom of the combustion device. Oftentimes, fly ash and bottom ash are collectively referred to as “coal ash”. Boiler slag is typically black and is angular with a smooth surface. In the near future pollution control equipment to be installed at various coal fired power plants will be installed to capture sulfur dioxide emissions. This process will generate a sludge, often referred to as “scrubber sludge”, which is another type of CCB.
The various coal combustion facilities in Maryland produce about 2 million tons of coal ash annually. This rate of generation is expected to continue. Scrubber sludge to be generated by flue gas desulfurization (FGD) pollution control technology is expected to be produced at a rate of about 2.5 million tons annually.
CCBs may be disposed in a dedicated disposal unit or used for a variety of purposes. Disposal occurs in surface impoundments or landfills. Potential uses of CCBs can include mine reclamation, structural fill applications, or use as a substitute for cement in the production of concrete. Approximately 1 million tons of coal ash is beneficially used in Maryland.
Without the proper controls, constituents of CCBs released into the environment may pose a risk. The improper management of CCBs on land can result in high concentrations of various constituents such as selenium, sulfate, arsenic, iron, etc… being released into surface or groundwater. Similarly, without controls on the handling of the material, fugitive emissions may create a public nuisance or cause respiratory problems.
MDE’s proposed regulations will require that any dedicated disposal facility for CCBs meet existing standards for an industrial solid waste landfill. This includes the need for a permit from the Solid Waste Program and includes the installation of liners, leachate collection, groundwater monitoring and reporting to MDE. The proposed regulations also establish strict standards on the use of CCBs in coal and noncoal mines. This includes both active and abandoned mines. Most notably, the use of the material in noncoal mines will require adherence to standards similar to those proposed for dedicated disposal facilities. There will also be an annual reporting requirement for those generating CCBs to identify the type and amount generated annually. This reporting will include an identification of the facility from which the CCB is generated as well as the location for the disposal or use of the substances. A public hearing has been scheduled on the proposed regulations for February 5, 2008 at 10:00 at MDE’s Montgomery Park offices.
The regulation of various beneficial uses of CCBs will be proposed at a future date. In the interim, MDE is soliciting input on the types of controls and standards to institute for the beneficial use of the material to ensure public health and the environment is protected. Beneficial use could include uses such as for roadway embankments, dedicated structural fills, a soil conditioner, a blasting grit, and a substitute for cement in the production of concrete. A public meeting has been scheduled for February 26, 2008 at 10:00 at MDE’s Montgomery Park offices.
Click here for information on CCBs and the proposed regulations.
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