Materials Characterization Paper In Support of the Final Rulemaking:

Identification of Nonhazardous Seco ndary Materials That Are Solid Waste

Coal Refuse

February 3, 2011

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1. Definition of Coal Refuse

This paper focuses on coal refuse that is a by-product of coal mining (mining rejects). 1 Coal refuse is generally defined by a minimum ash c ontent combined with a maximum heating value, measured on a dry basis (ARIPPA, p. 1 and EPA 2002, p. 2-2). Coal refuse mining rejects are a low BTU-value material generated by the coal mi ning process. The material consists primarily of non-combustible rock, with so me attached carbon material th at could not be effectively separated due to its small size. Large volumes of these materials were accumulated at mining sites from the time mining first began in the A ppalachians through the late 1970s. Beginning in the late 1970s, laws were enacted that, for the fi rst time, required stabiliz ation and reclamation of mining sites, including coal refuse disposal piles and fills (ARIPPA, p.1). Current mining operations continue to generate the material, though likely at lower rates than in previous decades (Neufeld p. 1). Mining rejects are referred to by various names, including: “gob” (garbage of bituminous) or “boney” in the bituminous coal mining regions of western Pennsylvania, West Virginia and elsewhere; an d “culm” in the eastern Pennsylvania anthracite region. Coal refuse piles also may be referr ed to as slate dumps (Energy Justice 2007, p.1; WPCAMR 2001, p.2; NRC 2006, p.16).

2. Annual Quantities of Coal Refuse Generated and Used

(1) Sectors That Generate Coal Refuse:

• Coal Mining Rejects are genera ted by NAICS industry sector 212111

- Bituminous Coal and Lignite Surface Mining, 212112 - Bituminous Coal

1 An additional source of coal refuse is coal mill re jects. Mill rejects are produced by coal-fired power stations that use roller mills to generate coal mill rejects. These rejects are the dense material in fuel coal that cannot be ground by the mills at a power plant to the desired size for burning in the boilers (EPA, 2008). Mill rejects appear to have limited fuel value. In a 1995 pilot test, when compared to clean coal the sulfur content of mill rejects increased from 1.43 percent to 6.1 percent, and ash content increased from 9.4 percent to 80.3 percent. The heating value of the original coal was 13,206 Btu/lb compared to th at of the mill rejects of 1,931 Btu/lb (EPRI, 1998, p. 4-8). Most mill rejects are co-managed with coal combustion byproducts (CCBs) in landfills or impoundments. A 1996 EPRI survey of coal-fired power plants found that 55 percent of the 264 site s included in the survey co-managed mill rejects with CCBs in landfills or impoundments. An additional limited survey of 24 utilities representing 40 power plants for this project found that 75 percent of these plants co-managed mill rejects in landfills or impoundments. Mill rejects typically represent 0.003 to 0.00 5 percent of the total ash produced (EPRI, 1998, p.iv). As mill rejects appear to have limited fuel value, are typically landfilled, and are a relatively smaller waste stream, they were excluded from this analysis.Coal Refuse

2 Underground Mining, and 212113 - Anthracite Mining. The U.S. Department of Energy categorizes the locations of th ese industries into three regions:

o Appalachian Region, which includes th e states of Alabama, Kentucky (eastern), Maryland, Ohio, Pennsylvani a, Tennessee, Virginia, and West Virginia;

o Interior Region, which includes the stat es of Arkansas, Illinois, Indiana, Kansas, Kentucky (western), Louisiana, Mississippi, Missouri, Oklahoma, and Texas; and

o Western Region, which includes the stat es of Alaska, Arizona, Colorado, Montana, New Mexico, North Dakota , Utah, Washington, and Wyoming (USDOE 2007b, p.14).

(2) Quantities and Prices of Coal Refuse Generated: One estimate reports that, annually, coal mines in the U.S. generate 109 million metric tons (120 million short tons) of coal refuse from 600 coal preparation plants in 21 coal-producing states (TFHRC post-1994, p.1).

A second estimate can be derived from othe r knowledge of coal production. In 2007 the amount of coal produced at U.S. co al mines reached an all-time high of 1,145.0 million short tons; this production data incl udes quantities extracted from surface and underground mines, and normally excludes secondary materials removed at mines or associated preparation plants (USDOE 2007a). 2 Thus, the amount of raw mining product is higher than this 1,145.0 million s hort ton total. The amount of mining reject resulting from this production is uncertain, but up to 50 percent of the raw mined product may end up as refuse depending on the rock and im purities in the coal (VCE 1996). This 50 percent es timate is most applicable where coal is mined from longwall mines or otherwise has relatively hi gh rock, impurities, a nd partings content (VEC 1996, p.1). Treating this 50 percen t value as an upper bound, no more than 1,145 million short tons of coal reject were likely to have been generated in 2007 (i.e., 50 percent of raw mined product is saleab le product, while 50 percent is rejects). As an example of specific data from one st ate, fifteen million tons of mining reject are generated annually in Vi rginia (VCE 1996). Anothe r estimate found that, since

the 18 th century, the refuse rate of coal was about 40 percent of the volume of coal mined in the U.S. (Neufeld p. 1). However, the same source cites that current coal preparation plants are more efficient, produc ing less coal waste, re sulting in a refuse rate of about 25 percent in the 1990s.

Public comments submitted to EPA by the Council of Industrial Boiler Owners (CIBO) in response to the Advanced Notice of Proposed Rulemaking (ANPRM) indicate that approximately 1.1 billion tons of waste coal are located throughout the United States. CIBO reports that this ma terial has an energy equivalency of more than 2 billion barrels of oil (assuming an average Btu value of 5,500 Btu per pound for the waste coal) (Bessette 2009).

2 This amount does not include the recovery of coal refuse, which was 0.8 million short tons in 2007.Coal Refuse

3 The combustor survey database devel oped by EPA for the 2009 proposal of the

Commercial and Industrial Solid Waste Incinerator (C ISWI) standards and the

Industrial Boilers Maximum Achievable Control Technology (MACT) standards includes one source that reported burning a pproximately 308,000 tons of coal refuse per year (EPA 2009). 3

Information on the price of co al refuse is limited, but can be expected to compare favorably with “virgin” energy sources in the applications where it is used.

(3) Trends in Generation of Coal Refuse:

Generation of coal refuse correlates with the production and use of coal. According

to the DOE’s Annual Energy Outlook 2007 with Projections to 2030 , coal production is projected to increase in coming decades, particularly in the Powder River Basin of Wyoming. From 2005 to 2030, production in the Powder River Basin is projected to grow by 289 million tons. The Rocky Mountain, Central West, and East North Central regions are projected to show the largest increases in coal demand, by about 100 million tons each, from 2005 to 2030. Increasing coal use for electricity generation at existing plants and construction of a few new coal-fired plants lead to forecasted annual production increases that average 1.1 percent per year from 2005 to 2015. The forecasted growth in coal pr oduction is stronger from 2015 to 2030, averaging 1.8 percent per y ear, as new coal-fired gene rating capacity is added and several coal-to-liquids (CTL) plants ar e brought on line (USDOE 2007b). Overall, the generation of coal refuse will likely incr ease as the demand for coal-based energy grows; however, it is unclear how this increa se will affect recaptu ring of existing coal refuse from stockpiles.

3. Uses of Coal Refuse

(1) Combustion Uses of Coal Refuse:

• There are 18 coal refuse plants (Foss il fuel electric power generation - NAICS 221112), and 13 more that use it as a secondary fuel, with bituminous coal as their primary fuel. Fourteen of the 18 coal refu se plants are in Pennsylvania, three are in West Virginia, and one is in Utah. Seventeen more plants have been proposed in Pennsylvania, West Virginia, Kent ucky, Indiana, Illinois, Colorado, and Virginia (Energy Justice 2007, p.1).

• According to the Anthracite Region Independent Power Producers Association (ARIPPA), from 1988 to the end of 2003, coal refuse plants in Pennsylvania used 88.5 million tons of coal refuse, mostly fr om “legacy” refuse piles. ARIPPA’s records show that the plants in the Co mmonwealth burn an av erage of about 7.5 million tons of coal refuse per year as fuel, mostly from “legacy” coal refuse piles (PADEP 2004a, p.2).

3 Although we report coal refuse quantities from the database in tons, the database includes material quantities expressed in terms of heating values (Btu). To express this info rmation as a tonnage, we assumed that coal refuse has a heating value of 7,750 Btu per pound, which is the midpoint of the 6,000 to 9,500 Btu per pound range reported by the National Research Council (NRC 2006) . In addition, we suspect that the combustor survey database may under count the number of sources burning coal refuse, as such sources may have simply identified

their fuel source as "coal".Coal Refuse

4 • The type of process used for the com bustion of mining reje cts is circulating fluidized bed (CFB) combustion (also know n as fluidized bed combustor (FBC) boiler technology) (Energy Justice 2007, p.1). CFB is an integrated technology for reducing sulfur dioxide (SO 2 ) and NO

x emissions during the combustion of coal. For the CFBs currently in use in all sectors, coal is the primary fuel source, followed by biomass and coal refuse. The h eat input capacities of all industrial, commercial, and institutional (ICI) CFB units generally range from 1.4 to 1,075 MMBtu/hr. (EPA 2004, p.2-7).

(2) Non-Combustion Uses of Coal Refuse

Granular Base: For non-combustion applicatio ns, such as use for embankment fill, coal refuse is usually cleaned befo re use to remove carbonaceous material that has been known to spontaneously igni te. It may also be spread in thin, compact layers between earth fill to reduce oxygen exposure and therefore reduce the possibility of ignition (TFHRC post-1994). Coarse coal refuse can be used as aggregate in granular base applications. Proper compaction of coarse coal refuse to its maximum dry density is necessary to achieve stability within a pavement structure. Fine coal refuse slurry has li ttle or no load carrying capability and is, therefore, unsuitable for use as a co nstruction material (TFHRC post-1994, p.1). In addition, there has been occasional use of coal refuse in Alabama, Kentucky, Virginia, and West Virginia as an alte rnative material for bases and sub-bases (TFHRC post-1994, pp.1-2). 4

A reference indicating the potential vol ume of coal refuse employed in noncombustion uses was not identified in the c ourse of the preparation of this paper.

• Mine Reclamation Projects: Ash leftover from combustion in a CFB boiler is alkaline and used for mine reclamation proj ects. The ash is often hauled back to the same gob pile site, where it can be mixed with soils impacted by acid mine drainage around abandoned mines to neut ralize acidity and immobilize heavy metals. The Commonwealth of Pennsylvani a has certified CFB ash for beneficial use in mining reclamation projects, and the Department of Environmental Protection regulates and routinely te sts it (WPCAMR post-2001, p.2). Following combustion of gob in the CFB boiler, the solids that remain are called ash. 5

• Stockpile Remediation : Some environmental groups advocate for the remediation of coal refuse stockpiles where they st and instead of burning them for fuel. Research has shown that beach grass can grow in the coal piles and can rebuild organic matter. Restored organic matter al lows plant cover and eventually native species to take root (Energy Justice p. 2).

4 The Pennsylvania Department of Transportation has rej ected anthracite refuse usage as aggregate for base and subbase courses because of high percent dissolution losses in the sodium sulfate (soundness test). West Virginia is evaluating the use of coal refuse as subbase material (TFHRC, post-1994, p.2).

5 CFB Ash can be used for other kinds of reclamation projects. For example, one project will use CFB ash injected into the partially flooded underground voids of an abandoned mine to mitigate acid mine drainage that currently breaks out on the surface (WPCAMR).Coal Refuse

5 (3) Quantities of Coal Refuse Stockpiled/Stored 6
Comprehensive national data concerning the volume of legacy mining rejects was not identified during the course of this revi ew. Before 1977, most mining rejects were stockpiled and abandoned since mining comp anies were not legally responsible for cleaning up mining waste. This resulted in thousands of abandoned coal refuse stockpiles. Pennsylvania alone has 820 ab andoned piles constituting 258 million tons of coal refuse in the state (PA DEP 2004b p. 1). According to one source, upwards of

2.4 billion tons of coal refuse had been abandoned in Pennsylvania by 1977 (ARRIPA p.1). In 1977 the Surface Mining Control and Reclamation Act (SMCRA) was passed, requiring coal companies to reclaim the sites that they mine. At that time, state and federal governments began to clean up the abandoned st ockpiles using the

Abandoned Mine Lands Reclamation Fund es tablished by SMCRA and continue to do so today. Many state reclamation proj ects suggest sending re fuse piles to CFB plants. According to ARIPPA, from 1987 to the end of 2003, coal refuse plants in Pennsylvania consumed 88.5 million tons of the material, mostly from “legacy” refuse piles. ARIPPA’s records show th at the plants in the Commonwealth burn an average of about 7.5 million tons of coal re fuse per year, mostly from “legacy” coal refuse piles (PADEP 2004a, p.2). In fact, many of the coal refuse plants have 10 to 15 years of fuel available (WPCAMR post-2001 p. 1).

Currently, mining rejects are managed on-s ite by the mining company, while few are abandoned. Although CFB boilers burning coal refuse appear to primarily utilize volumes from “legacy” stockpiles, coal refu se and selective over burden material from active mines are being utilized as fuel as well (Bessett 2009). Having particularly valuable refuse makes it more likely that a current generator will send ash to a coal refuse plant. Relatively low sulfur conten t, high energy value, and close proximity to the plant make coal refuse more appealing for a CFB (WPCAMR post-2001 p. 1).

4. Management and Combustion Processes

(1) Types of Combustion Units: The two major technologies used to burn coal are pulve rized coal combustion and fluidized bed combustion. Of the approxi mately 600 operating coal-fired power plants in the United States , about 160 utilize fluidized bed combustion (Goswami 2007). Although both technologies can be utilized to combus t either normal coal or waste coal, fluidized bed boilers are noted for their capability to burn fuels with low

carbon content. This is a result of the turbulent mixing process that takes place in the fluid beds, which creates good heat and mass transfer and allows the burning to take place at lower temperatures. Therefore, fluidized bed boilers are capable of combusting fuels, such as low-carbon wa ste coal, that do not have a high enough heating value to support combustion at high temperatures (Woodruff 2004).

(2) Sourcing information: Sources of mining rejects include co al refuse or “gob/culm piles.” 7

6 See the CCP Materials Characterization Paper fo r further information on CCP landfill volumes.Coal Refuse

6 (3) Processing Information: Coal refuse is regulated similarly to coal as a raw material. A coal refuse handler must receive a permit under the Office of Surface Mining and Control and

Reclamation Act. Coal refuse that is recl aimed for secondary use is also subject to oversight by the Mining Safety and Hea lth Administration (Bridgeford p. 4-5).

Following necessary licensing, the general process is as foll ows: material is hauled from mining areas (i.e., gob and culm piles) to coal-fired power plants, crushed into pieces smaller than 1⁄4 inch for fluidized be d boilers or fine particles for pulverized coal combustion, and then burned for energy (Woodruff 2004).

For fluidized bed boilers, crushed limestone is injected into the bottom of the combustion chamber along with the fuel , where the calcium carbonate in the

limestone is converted into calcium oxide. The calcium oxide then reacts with the sulfur in the coal refuse, thereby reduci ng the sulfur oxide emissions. The heavier fuel and limestone particles that cannot be retained in the circulating fluidized bed drop to the bottom of the chamber. Th is burned fuel, know n as bottom ash, is

removed from the combustion chamber al ong with any ash captured at the top, which is known as fly ash (PADEP 2004b, Ch 1, pp. 3-4). Ash leftover from CFBs may be hauled back to the same gob/culm pile site, where it can be mixed with soils

around abandoned mines to neutralize ac idity and immobilize heavy metals (WPCAMR post-2001, p.2).

Due to advances in coal preparation tec hnology over the past cen tury, the processing

of coal has evolved over time such that materials that would have been considered mine rejects in the past are now handled and processed as coal. In the early twentieth century, coal preparation involved simple size segregation into lump coal for

domestic use and intermediate-sized coal for industrial use. Coal fines were considered unfit for use and were disposed of as mine rejects in coal refuse piles. Today, however, coal preparation plants ar e much more capable of separating coal from mineral matter through processes such as density separation and froth flotation (NRC 2007). In the past, mines discarded coal pieces smaller than 0.5 millimeters, but technological improvements have allowed th e size of rejected fi nes to decrease to those smaller than 0.04 millimeters (Yoon 2009).

(4) Changes in Technology to Improve Use of Coal Refuse in Combustion: As noted, the advent of circulated fluidi zed bed (CFB) combustion boilers, along with higher fuel costs, has facil itated the combustion uses of coal refuse. In addition, certain technology advancements are in use or development that may serve to further improve the application of coal refuse in combustion:

7 Based on the sources consulted in the development of this document, brokers or traders do not appear to be involved in sourcing the waste products to the power pl ants. It appears the utilities/power plants are supplying themselves with the waste pile materials.Coal Refuse

7 • CSIRO

- Liquatech hybrid coal and gas turbine system, developed in Australia, harnesses existing technologies in a 1.2 megawatt hybrid coal and gas turbine system that burns coal refuse and methane gas to generate electricity. The turbine system burns coal and methane in a kiln, producing hot air, wh ich is then driven through a heat exchange unit and subsequently passed over a gas turbine to produce electricity. The electricity can either be used to power a mine’s operations or be returned to the grid fo r general consumption. (CSIRO 2002, p.1).

• Radar Acquisitions Corp. is in the process of developing an engineered solid fuel (Re-FuelTM) for utilities. The primary component of Re-FuelTM is coal refuse (gob piles and coal slurry pond material); the secondary component is biomass (i.e., agricultural ma terial or sawdust). The goal of the RPS FuelsTM technology is

to convert these two materials into a product that looks a nd acts like coal, but burns more efficiently and with re duced stack emissions (Radar, p.1).

(5) State Status of Combustion as Beneficial Use: There are currently three states that have pow er plants that burn coal refuse as fuel (Pennsylvania, West Virginia, and Utah). There are currently five additional states that are proposing to build power plants that will burn coal refuse: Kentucky, Indiana, Illinois, Colorado, and Virginia. 8

5. Coal Refuse Composition and Impacts

(1) Composition of Coal Refuse

The Btu value for this material is 6,000 to 9,500 Btu per pound (NRC, 2006). Nationally, this material has an average of 60 percent of the BTU value of normal coals (Energy Justice 2007, p.1). The ash conten t of coal refuse is high: according to an ARIPPA-sponsored study, twelve Pennsylvani a plants using coal refuse as a key ingredient of their fuel, burned over 8 milli on tons/year of refuse coal and generated in the process approximately 5 million tons of ash (Earthtech 2000, Vol. 1, p. iv).

Similar to coal itself, the chemical compos ition of coal refuse varies geographically. Exhibit 1 presents elemental data from the published literature for coal refuse samples

extracted from the Peerless Seam in West Virginia (Stewart et al. 2001) and a separate seam in southwest Virginia (Li et al. 1997). Based on data submitted by RRI Energy in response to the proposed rule, Exhi bit 2 presents constitu ent concentrations of coal refuse for samples from Ca mbria, Indiana and Somerset County, Pennsylvania.

8 Note that this information represents the results of preliminary research; we have not performed an exhaustive investigation of state activities and regulations for all states concerning coal refuse.Coal Refuse

8 Exhibit 1: Chemical Properties of Coal Refuse from West Virginia and Virginia

Element ppm
Ag <5

Al 91,000

As <10

B 200

C 167,000-190,000

Ca 23000

Cd 0-6.4

Cr 70-83.3

Cu 26-60

Fe 30000
Hg 0.3
Mg 8000

Mn 140-1026

N 2700

Ni 29.8

P 160

Pb 15.8-20

S 36500

Si 222000

Zn 60-112

Sources: Stewart, et al (2001), Li, et al (1997)

Mining rejects have a higher concentration of mercury than normal coals. In West Virginia and nationally, gob has 4 times more mercury than bituminous coal. In Pennsylvania, gob has 3.5 times more mercur y than bituminous coal. Culm has 19 percent more mercury than anthracite coal. Bituminous rejects also have higher

levels of sulfur. Data on other metals in the material is sparse, but single metals tests on Pennsylvania culm and gob show both to have about four times more chromium and three times more lead (Energy Justi ce 2007, p.1), and the content of arsenic is relatively elevated as well (Coleman and Bragg, 1990, in Earthtech, 2000, Vol. 1, pp. 15-16).

The composition of coal mining rejects is si milar for those mined from legacy piles and those generated from current mining act ivities, although the size of the fines produced has decreased over the years as a result of technology improvements. However, the ash concentrations and contaminant concentrations of coal mining rejects depend largely on the type of coal and location of the mine, rather than the year in which the rejects were mined (Yoon 2009).Coal Refuse

9 Exhibit 2: Constituents of Coal Re fuse from Indiana and Pennsylvania

Sample Description Sample ID Sb As Be Cd Cr Co Pb Mn Hg Ni P Se

Coal Refuse

(values in

ppm) Sample 1 1.5 50.7 2.1 0.3 80.2 22.7 33.1 134 0.644 44.7 718 7.8

Sample 2 1.7 53.4 2.1 0.3 84.5 23.8 35.2 139 0.748 50.5 719 8.6

Sample 3 1.5 47.3 2.1 0.3 84.7 22.8 33.1 144 0.613 47.1 745 8.6

Average 1.6 50.5 2.1 0.3 83.1 23.1 33.8 139 0.668 47.4 727 8.3

Source: RRI Energy, Inc. (2010). Values represent constituent co ncentrations of coal refuse in Cambria, Indiana and Somerset County, Pennsylvania.

(2) Impact Information As noted, the typical process used for the combustion of mining rejects is circulating fluidized bed (CFB) combustion (Energy Ju stice 2007, p.1). CFB is an integrated technology for reducing sulfur dioxide (SO 2 ) and NO

x emissions during the combustion of coal. In a typical CFB boiler, crushed coal and inert material (sand, silica, alumina, or ash) and/or a sorben t (limestone) are maintained in a highly turbulent suspended state by the upward flow of primary air from the windbox located directly below the combustion floor. This fluidi zed state provides a large

amount of surface contact be tween the air and solid particles, which promotes

uniform and efficient combustion at lowe r furnace temperatures than conventional coal-fired boilers. The lower combustion temperature is below the threshold at which nitrogen and oxygen form NO

x and therefore leads to reduced emissions. Once the hot gases leave the combustion chamber, th ey pass through the convective sections of the boiler, which are similar or identical to components used in conventional boilers. For the CFBs currently in use in all sectors, coal is the primary fuel source, followed in descending order by biomass, coal refu se, and municipal waste. The heat input capacities of all ICI CFB units generall y range from 1.4 to 1,075 MMBtu/hr (EPA 2004, pp.2-7).

Concerning impacts related to emissions from this combustion process, the Pennsylvania Department of Environmenta l Protection (PADEP) required the owners of a Pennsylvania bituminous coal refuse fire d facility to conduct extensive air toxics emissions stack testing to support its request to burn a 10 percent mixture of coal tar

contaminated soil in combination with nor mal coal refuse. The coal refuse facility

shows lower emissions for all of the toxic pollutants compared to a typical pulverized coal combustor. The dioxin levels were approximately 4 times lower, while most metals were about half, with the excepti on of mercury, which was 10 times lower per gigawatt-hour generated (PADEP post-2004, p.2). Based on stack testing of two CFB combustion plants, 99.7% to 99.8% of the mercury was captured in the ash (Earthtech, 2000, Vol. 1, p. vi). Accordi ng to the same source (Earthtech, 2000,Coal Refuse

10 Vol.1, p. 1), there are several reasons for the general low emission levels of trace metals such as As, Cd, Cr, Hg, Pb, Ni and Se in the fluidized be d combustion process. Those include the significantly lowe r combustion temperatures (800-950 0 C) as compared to pulverized coal combustion boilers (1200-1540 0 C), Lower combustion temperatures allow mercury to condense as it is exhausted and therefore is more likely captured by emissions control devices downstream (Las Brisas Energy Center p. 1). The presence of a fabric filter ba ghouse (FF) also decreases mercury emissions

in both CFB and PC units. Units with a FF produce fly ash with both a larger surface area and larger pore volume, and therefore allows for more complete fixation of mercury and lower emissions. The relativ e amount of mercury emitted can also depend on the type of coal burned (Yan et al. 2008).

The culm (reject anthracite coal) combusting facilities represent the majority of the coal refuse facilities in Pennsylvania and the data submitted to the Department shows

that these facilities have been achievi ng a NOx emissions level of 0.15 lbs/MMBtu. In comparison, a typical pulverized coal f acility without add-on selective catalytic reduction (SCR) controls, which is presentl y the majority of pulverized units, would emit NOx in the 0.3 to 0.5 lb/MMBtu range. This continuous emissions monitoring (CEM) data also shows that some of the coal refuse facilities ha ve been achieving an

SO 2 emissions rate of 0.20 to 0.25 lbs/MMBtu range using limestone injection. The pulverized coal-fired boilers typically em it in the range of 2 to 3 lbs. of SO 2 per MMBtu. The six Pennsylvania pulver ized coal-fired units with SO 2 scrubbing operate

in the 0.1 to 0.4 lbs. of SO 2 per MMBtu range (PADEP post-2004, p.2).

Pennsylvania coal refuse burning facilities are lower emitters of both NOx and SOx than the typical coal-fired utilities. However, it should also be noted that an SO 2 emission rate of 0.1 lbs/MMBtu is achievable for a newly built pulverized coal-fired unit that would be requi red to install an SO 2 scrubber under an SO 2 Best Available Control Technology (BACT) determination. Th erefore, newly constructed electric generating combustors of either coal refuse or coal would emit at very comparable levels, because both would be employing ve ry similar BACT for all pollutants. (PADEP post-2004, p.2).

Impacts related to the use of coal refuse ar e discussed qualitatively below. Note that

a further discussion of the uses of coal co mbustion products (CCPs) as ingredients is provided in the CCP Material s Characterization Paper.

• Other Impacts Related to Mining Rejects: The potential benefits of returning suita ble FBC ash to abandoned or active mine

lands for use in reclamation include:

o The alkaline nature and encapsulating abil ity of the material make it useful for some mine reclamation applications. In particular, reclaiming coal refuse piles without the benefit of adding F BC ash does less to address the oftensevere water quality problems that emanate from some of the piles.Coal Refuse

11 o The reclamation of abandoned mine land (AML) with FBC ash is often privately funded, freeing up state and fe deral government AML resources for other applications.

o The ash from FBC plants has chemical and physical properties that limit the potential for the ash itself to become a source of environmental contamination (Earthtech, 2000, Vol 1, pp. v-v i; PADEP 2004b, Ch. 1, pp.6-7).

o Reclaiming AML with ash serves to elim inate the safety hazard of abandoned mine highwalls and cropfalls.

In addition, as indicated in public comments submitted to EPA in response to the ANPRM, the use of coal refuse as a fu el results in environmental benefits associated with (1) reduc ing abandoned mining waste piles, which threaten groundwater and air quality (through wi ndblown fugitive emissions), and (2) reclaiming abandoned mine sites, there by returning lands to productive use (Bessette 2009). According to public comm ents, coal waste piles that are not removed generally create severe acid mi ne drainage, with pH levels of approximately 2.5. Elevated concentrations of metals, including arsenic, occur at these sites, as well. Legacy coal refuse piles in Pe nnsylvania, those refuse piles that were a result of coal mined prio r to Pennsylvania receiving primacy on July 31 , 1982, include more than 220 million tons of refuse and cover more than 8,500

acres. Since 1990. 78 million tons of coal re fuse have been mined for fuel in the Anthracite Region and 35 million tons of coal waste have been mined in the Bituminous Coal Region of Pennsylvania (Brady 2010).

• Additional Avoided Impacts:

Exhibit 4 summarizes the air emissions a ssociated with the combustion of coal refuse and the corresponding emissions from the combustion of coal. The exhibit also presents the cradle-to-gate emissi ons that may be avoided by using coal

refuse as a substitute for coal. These cradle-to-gate environmental benefits may be offset by the environmental impacts as sociated with extracting coal refuse from coal refuse piles and processing this material, but data are not readily available on these impacts. Note th at there may be alternative uses (e.g., aggregate, mine reclamation) that are e nvironmentally preferable to combustion.

Furthermore, use of coal refuse as a fuel serves the important benefit of removing the piles of gob and culm. The piles can be a fire hazard and a source of surface and ground-water pollution.Coal Refuse

12 Exhibit 4: Emissions from Combustion of Co al Refuse and Extraction and Combustion of

Traditional Coal

Pollutant Coal Refuse Coal

Combustion Combustion Combustion plus Upstream

---------- Lb./MMBtu ----------

Criteria Pollutants

PM2.5 - - -

PM10 - 0.054 0.054

PM, unspecified - - 0.246

NOx 0.15 0.482 0.504

VOCs - 0.006 0.014

SOx 0.20 - 0.25 1.446 1.469

CO - 0.068 0.085

Pb - 8.93x10 -6 9.19x10 -6

Hg - 2.05x10 -6 2.14x10 -6

Greenhouse Gases

CO 2 - 210.7 214.7

CH 4 - 0.007 0.458

N 2 O

- 0.003 0.003

MTCO 2 E/MMBtu

- 0.096 0.102

Sources: PADEP post-2004, p.2; Franklin Asso ciates 1998.

Note: “-” signifies data not available; may equal zero.

The emission information presented in this table is derived from Life Cycle Inventory (LCI) data, as compiled by Franklin Associates. LCI data identifies and quantifies resource inputs, energy requirements, and releases to the air, water, and land for each step in the manufacture of a product or process, from the extraction of the raw materials to ultimate disposal. The LCI can be used to identify those system components or life cycle steps that are the main contributors to envir onmental burdens such as energy use, solid waste, and atmospheric and waterborne emissi ons. Uncertainty in an LCI is due to the cumulative effects of input uncertainties and data variability.

There are several life cycle inventory databases available in the U.S. and Europe. For this paper, we applied the most readily available LCI database that was most consistent with

the materials and uses examined. These LCI data rely on system boundaries as defined by Franklin Associates, as described in the documentation for this database, available at: http://www.pre.nl/download/manuals /DatabaseManualFranklinUS98.pdf

.Coal Refuse

13 References

Anthracite Region Independent Power Producers Association (ARIPPA), “Coal Refuse,” fact sheet, undated, accessed on August 21, 2008, at: http://www.arippa.org/coalrefuse.asp

.

Bessette, Robert D., Public comment in response to EPA’s Advanced Notice of Proposed Rulemaking for the

Identification of Non-Hazardous Materials That Ar e Solid Waste, EPA docke t EPA-HQ-RCRA-2008-0329, submitted on behalf of the Council of Industrial Boiler Owners (CIBO).

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