Materials Characterization Paper In Support of the Final Rulemaking:

Identification of Nonhazardous Seco ndary Materials That Are Solid Waste

Coal Combustion Residuals - Coal Fly Ash, Bottom Ash, and Boiler Slag

February 3, 2011

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1. Definition of CCRs

Coal combustion residuals (CCRs) are formed duri ng coal-burning processes in power plants and

industrial boilers. Coal combus tion produces various forms of CCRs that are categorized by the process in which they are ge nerated. The CCRs that can be used as ingredients in the manufacture of portland cement include: 1

• Fly ash: Exhaust gases leaving the combustion chamber of a power pl ant entrain particles during the coal combustion process. To preven t fly ash from entering the atmosphere, power plants use various collection devices to remove it from the gases that are leaving the stack. Fly ash is the finest of coal ash particles.

• Bottom ash: With grain sizes ranging from fi ne sand to fine gravel, bottom ash is coarser than fly ash. Utilities collect bottom ash from the floor of coal burning furnaces used in the generation of steam, the production of electric power, or both. Th e physical characteristics of the residuals generated depend on the characteristics of the furnace.

• Boiler Slag: Boiler slag consists of molten ash collected at the base of cyclone and pulverized coal boilers. Facilities cool boiler slag with water, which then shatters into black, angular pieces that range in size from c ourse sand to fine gravel and have a smooth

appearance.

2. Annual Quantities of CCRs Generated and Used

(1) Sectors that generate CCRs:

• The coal-fired power industry, represen ted by NAICS sector 221112 – Fossil Fuel Electric Power Generation, is the larges t generator of CCRs. Other industries, such as commercial boilers and mineral and grain processors that use coal as a fuel source, also produce small quantities of CCRs.

(2) Quantities and prices of CCRs generated:

• In 2008, the coal-fueled electric power industry generated approximately 72.4 million tons of coal fly ash, 18.4 million to ns of bottom ash, and 2.0 million tons of boiler slag.

• In 2003, the price per ton of c oncrete-quality fly ash, frei ght on board (FOB) (i.e., costs net of shipping or transport costs), ranged from $0-$45 (ACAAa).

• In 2003, the price per ton of bottom ash ranged from $3-$8 FOB (ACAAa).

1 This paper focuses on CCRs used primarily as an ingredient in cement manufacture; see the Materials Characterization Paper for Coal Refuse for further information on mining rejects and combustion applications.Coal Combustion Residuals

2 • The price of boiler slag could not be determined at this time; as with many small markets, it may be that most transacti ons involving boiler slag are private.

(3) Trends in generation of CCRs:

• The coal-fired power indus try is the largest generator of CCRs in the United States. Coal-generated electricity s upplied approximately 45 percent of the electricity consumed in the United States in 2009. 2 Since electricity demand is projected to increase in coming years, a nd coal will continue to be an important fuel source, the quantity of CCRs produced and available for beneficial reuse may also increase (USDOE 2008, p.10) . While other industries th at use coal as a fuel

source in commercial or industrial boilers (e.g., mineral and grain processors) also produce CCRs, these quantities tend to be small, and increases or decreases in their production will not have a significan t impact on the overall trend in CCR production.

3. Uses of CCRs

(1) Ingredient and combustion uses of CCRs:

• Fly ash, bottom ash, and boiler slag can be added to the raw material feed in clinker manufacturing to contribute specifi c required constituents, such as silica, alumina, and calcium, in the final cement composition.

• Fly ash with high unburned carbon content can also be reburned in cement kilns for energy recovery at the same time as it provides ingredient value, or re-burned in a fluidized bed combustor for energy recovery, before being used as an ingredient (PMI As h Technologies, 2010)

• Public comments from the American Co al Ash Association (ACAA) in response to the Advanced Notice of Proposed Rule making (ANPRM) indicate that fly ash is a particularly useful fu el because of its high minera ls and carbon content (Goss 2009).

• ACAA’s comments also indicate that an el ectric generating faci lity in Wisconsin uses ash containing high amounts of carbon (20 to 30 percent carbon) as a substitute for coal (Goss 2009).

(2) Non-combustion uses of CCRs:

• Fly ash can be used in a number of non-combustion ap plications. Its most common, and most high-value, use is as a supplementary cementitious material in concrete (i.e., a substitute for, or am endment to, portland cement in concrete mixes). In this application, fly ash can provide certain material advantages such as greater workability, higher strength, a nd increased longevity in the finished concrete product. Fly ash is also used as a partial substitute for virgin dirt, sand, or gravel in structural fill, or as a substitute for portland cement in waste stabilization (ACAA 2006).

2 http://www.eia.doe.gov/cneaf/electricity/epm/table1_1.htmlCoal Combustion Residuals

3 • Bottom ash can be used to offset virgin sand and gravel in a pplications such as structural fill, road base , and concrete (ACAA 2006).

• Boiler slag can be used to offset virgin sand and gravel in applications such as

structural fill and blasting grit (ACAA 2006).

(3) Quantities of CCRs landfilled:

• In 2008, 42.3 million tons of coal fly ash, 10.4 million tons bottom ash, and 0.34 million tons boiler slag were landfilled, representing roughly 58 percent, 56 percent, and 17 percent of generation, respectively.

(4) Quantities of CCRs stockpiled/stored:

• The American Coal Ash Association (AC AA) estimates that between 100 million and 500 million tons of fly ash have accumu lated in U.S. landfills since the 1920s, when the disposal of fly ash in landfills began. It is unclear, however, how much of this fly ash is availabl e for beneficial use.

• The recoverability of fly ash depends significantly on the manner in which it is disposed. Fly ash disposed of in a monofill or holding pond likely would be

suitable for beneficial use because it ha s generally not been commingled with other materials. Unfortunately, the AC AA is unaware of data indicating how much of the 100-500 million tons of stockpile d fly ash is deposited in monofills or holding ponds

• The recovery of landfilled ash for beneficial reuse does not appear to be widely practiced. Although a portion of the fly ash located in stockpiles across the U.S. may be available for beneficial use, a recent analysis of the market for fly ash found that approximately 49 percent of th e 72.4 million tons of fly ash generated in 2006 was beneficially used (ACAA). Th erefore, even if large quantities from stockpiles were made availa ble, it is unlikely that the quantity re-used would increase significantly. In other words, th e demand for fly ash appears to be met by existing production.

• Certain electric utilities, however, have pursued programs to recover ash for use of its residual unburned carbon in po wer plants. Examples include:

o Wisconsin Energy Corporation began rebur ning ash at its Pleasant Prairie Power Plant in 2000 and expanded re burning to include ash recovered

from landfills in 2001 af ter receiving approval under Wisconsin’s first Environmental Cooperative Agreement. The patented process can use either dry high-carbon fly ash direc tly from the company’s older power plants, or use moist high-carbon ash from WEC’s power plants, stockpiles, existing landfills, and remediation projects. According to its 2006 Performance Report, WEC reburned a pproximately 11,023 short tons of

recovered landfill ash in 2002 (WEC 2006a, p.69). 3

o In 2001, Western Kentucky Energy's Co leman station in Hawesville, Kentucky, inaugurated an ash-recovery program developed by staff at the

3 The report indicates that between 2003 and 2006, the facility did not reburn any recovered coal ash from its landfill. During these years, howeve r, the facility continued to reburn coal ash generated by power plants.Coal Combustion Residuals

4 University of Kentucky Center for Applied Energy Research (CAER). The CAER researchers developed a system to remove fly ash from holding ponds and extract carbon to create a reburning fuel or several other products (BNET 2002, pp. 1-2).

• Wisconsin Energy Corporation also rec overs landfilled as h for sale as a

construction material. Under the E nvironmental Cooperative Agreement and Wisconsin regulations for beneficial industrial byproduct use, the company recovered 31,967 short tons ( 706.293 cubic feet) of coal ash from its P4 landfill and sold it as a base material to replace stone or gravel under roads, parking lots, and buildings. Since 2002, more than 93,69 6 short tons have been recovered (WEC 2006a, p.70).

Exhibit 1: Overview of Generation and Use of CCRs in 2008

Commodity Annual Quantity

Generated Annual Quantity Used as Ingredient

Annual Quantity

Landfilled Annual Quantity in

Other Uses Total Quantity Stockpiled as

of 2006 Fuel Cement Ingredient

in Kilns

-----------------------------Short Tons -------------------------

Coal fly ash 72.4 million Undetermined 3.2 million 42.31

million 26.89

million 100 – 500

million a

Bottom ash 18.4 million 0 0.61 million 10.36

million 7.43 million Undetermined

Boiler slag 2.0 million 0 0 million 0.34 million 1.66 million Undetermined

Sources : Unless otherwise noted, data are from Amer ican Coal Ash Association. (ACAA), 2008, Coal Combustion Product (CCP) Production and Use Survey,

Notes: a. Personal communication with Dave Goss, ACAA, November 27, 2006.

4. Management and Combustion Processes for CCRs

(1) Types of units using CCRs:

• When used in clinker ma nufacture, fly ash, boiler sl ag, and bottom ash are fed

into cement kilns with other raw material feed. (2) Sourcing of CCRs:

• Although electric utility companies produce as h at their coal-fir ed power plants, most utilities do not handle, dispose of, and/or sell th e ash that they produce. There are approximately 40 to 50 commercial ash marketing firms operating throughout the United States, in all states except Hawaii. In addition to commercial ash marketing organizations, certain coal-burning electric utility companies have formal ash marketing pr ograms of their own. Most coal-burning electric utility companies currently em ploy an ash marketing specialist whose responsibility it is to monitor ash generation, quali ty, use or disposal, and toCoal Combustion Residuals

5 interface with the ash marketers or brokers who are under contract to the utility companies (Turner Fairbank Hi ghway Research Center).

(3) Processing of CCRs:

• Use of CCRs as a raw feed in cemen t kilns does not require processing. However, kilns do require feed of consis tent quality, quantity, and composition in

order to ensure that the feed mix in the kiln is appropriate. In particular, levels of key metals (e.g., iron and alumina) in CCRs are carefully calibrated with other ingredients to ensure that the final cement product has the correct mineral and

metal content.

• Due to its pozzolanic properties, stockp iled class C fly ash may harden over time if exposed to moisture. (Class F fly ash does not exhibit this characteristic). Hardened class C fly ash must be crushed prior to beneficial use but is typically limited to use as an aggregate in concrete . Class F fly ash does not lose reactivity

over time and can be recovered from stoc kpiles for use in concrete, but it is unclear to what extent stockpiled Class F fly ash can be used in cement kilns, or whether it requires processing prior to use.

• Bottom ash may require stockpiling for a shor t period of time (at least 1 or 2 days) to allow excess water to drain prior to beneficial use. Ponded bottom ash reclaimed from a lagoon should be stoc kpiled and allowe d to drain for a somewhat longer time period, perhaps up to 1 or 2 weeks, depending on the amount of rainfall. After size reduction, bottom ash can be screened to produce different size ranges, if desired. (Turner Fairbank Hi ghway Research Center).

• The State of Michigan has identified one facility that quenches bottom ash in a water bath, removes the water, and then adds the remaining material to a coal pile

that feeds a boiler more efficient than the combustion unit that originally produced the ash. (Sliver, 2010).

• An example of the recovery process used by Wisconsin Energy Corp. includes:

o Identifying a disposal site that cont ains the byproducts (typically fly ash and bottom ash) and removing a portion of the byproduct;

o The removed materials are crushed, scr eened, and periodically sampled in accordance with ASTM D2234; 4

o Analyzing a sample of the portion of the byproducts to determine the loss on ignition of the portion of the byproducts;

o Either fly ash or bottom ash or a mixtur e of both is added in a fine particle condition to the furnace of a pulverized coal boiler in a small proportion to the pulverized coal fed to the furnace. The ash is burned with the pulverized coal. The proportion of coal ash is preferably in the range of 1 percent to 3.5 percent, by wei ght, of the pulverized coal.

o Introducing the portion of the byproducts along with pulverized coal into a pulverized coal furnace if the portion of byproducts has a loss on ignition

4 During a pilot project to reprocess landfilled combustion products that was conducted by Wisconsin Energy Corporation in July and October 1998, samples were collect ed every 30 minutes from th e transfer point where the ash fell onto the stacker conveyor during the entire operation per the ASTM standard, and a composite sample was prepared for every 5,000 tons processed and tested.Coal Combustion Residuals

6 greater than or equal to a predeter mined loss on ignition value (typically greater than or equal to 1 to 5 percent); and

o Burning the portion of the byproducts in the furnace with the pulverized coal to render the bypr oducts into a commercially valuable fly ash and bottom ash having very low loss on ig nition, typically lower than 3 percent (WEC 2003, p.7; WEC, p.1). 5

• Public comments received in response to the ANPRM indicate that there are at least four patented processes for re moving unwanted carbon from fly ash, allowing the processed material to be used as an ingr edient in concrete. In addition, the resulting carbon stream can be re-introduced into a boiler as a fuel (Goss 2009).

(4) State status of CCRs use as ingredient:

• In the state of Wisconsin, Wisconsin En ergy Corporation has an agreement with the state to burn recovered landfill ash at their power plants.

• At this stage, we have not identified any other states that have specifically given beneficial use designation to the use of CCRs in clinker manufacture, or that prohibit fly ash use in clinker, but we have not performed an exhaustive investigation of state ac tivities and regulations.

5. CCR Composition and Impacts

(1) Composition of CCRs:

• The chemical properties of fly ash are infl uenced to a great extent by those of the coal burned. There are basically four types, or ranks, of coal, each of which varies in terms of its heating value, its chemical composition, ash content, and geological origin: anthracite, bitu minous, subbituminous, and lignite. The principal components of bituminous coal fly ash are silica, alumina, iron oxide, and calcium oxide, with varying am ounts of residual, unburned carbon, as measured by the loss on ignition. Silica, alumina, and calcium are also the primary ingredients in portland cement , along with iron oxide. Lignite and subbituminous coal fly ashes are charac terized by higher concentrations of calcium and magnesium oxide and reduced percentages of silica and iron oxide,

as well as a lower residual carbon conten t, compared with bituminous coal fly ash. Very little anthracite coal is burned in utility boilers, so there are only small amounts of anthracite coal fly ash. Fly ash contains trace metals, such as vanadium, zinc, copper, chromium, ni ckel, lead, arsenic, and mercury. 6

5 Landfill ash recovery operations at the Western Kentuc ky Energy (Coleman Station) involves the following activities. Ash first must be recovered from the pond or land fill and then separated into its fundamental components: carbon, silicates, and high-density, iron-rich materials. A coarse carbon-fuel product is recovered by density separation using concentrating spirals. A fine car bon-fuel product is recovered with flotation cells.

6 See USEPA, March 15, 1999.Coal Combustion Residuals

7 • Exhibit 2 details the compounds found in fly ash generated from the combustion of bituminous, sub-bituminous, and lignite coal. Exhibit 3 presents the elemental composition of fly ash, retrieved from different samples in the same study. Because Exhibit 2 provides data on compounds in fly ash and Exhibit 3 provides fly ash composition by chemical element , the data in the tw o exhibits are not

additive.

Exhibit 2: Overview of Fly Ash Co nstituent Compounds – Expressed in PPM

Component Bituminous Subbitminous Lignite

Silicon Dioxide 200,000 - 600,000 400,000 - 600,000 150,000 - 450,000

Aluminium Oxide 50,000 - 350,000 200,000 - 300,000 100,000 - 250,000

Iron Oxide 100,000 - 400,000 40,000 - 100,000 40,000 - 150,000

Calcium Oxide 10,000 - 120,000 50,000 - 300,000 150,000 - 400,000

Magnesium Oxide 0 - 50,000 10,000 - 60,000 30,000 - 100,000

Sulfur Trioxide 0 - 40,000 0 - 20,000 0 - 100,000

Sodium Oxide 0 - 40,000 0 - 20,000 0 - 60,000

Potassium Oxide 0 - 30,000 0 - 40,000 0 - 40,000

Loss On Ignition 0 - 150,000 0 - 30,000 0 - 50,000

Source: Coal Fly Ash Material Description – Turner-Fairbank Highway Research Center

• Bottom ash and boiler slag are composed pr incipally of silica, alumina, and iron oxide, with smaller percentages of calc ium and magnesium oxides, sulfates, and other compounds. The composition of the bott om ash or boiler slag particles is controlled primarily by the source of the co al and not by the type of furnace. Bottom ash or boiler slag derived from lignite or sub-bituminous coals has a higher percentage of calcium oxide than the bottom ash or boiler slag from anthracite or bituminous coals. (Turne r-Fairbank Highway Research Center).

• Exhibit 4 below includes detailed constituent sampling results for bottom ash and boiler slag produced from the combustion of several types of coal mined from different locations. In addition, Exhibits 5 and 6 provide an elemental breakdown of bottom ash and boiler slag.

• All of these materials provide effective substitutes for most or all of the raw materials in cement, but the relative levels of different oxides must be carefully managed to ensure that the kiln pr oduct meets industr y specifications.Exhibit 3: Overview of Fly Ash Constituent Elements – Expressed in PPMTetra Tech – Fly Ash Sample 11Tetra Tech - Fly Ash Fly Ash Sample 221993 Regulatory Determination DataConstituent Minimum Maximum Median Minimum Maximum MedianMean Minimum Maximum MedianArsenic 3.3 160 25.2 2.3 279 56.7 10.5 0.2 205 4.6Barium 52 1152 872 110 5400 991 76.4 0.0003 391 43.4Beryllium - - - - - - 1589 0.02 10850 806.5Boron 205 714 258 10 1300 371 469.5 2.98 2050 311Cadmium 0.4 14.3 4.27 0.1 18 1.6 6.1 0.01 76 3.4Chromium 83.3 305 172 3.6 437 136 129 0.19 651 90Cobalt 6.22 76.9 48.3 4.9 79 35.9 - - - -Copper 42 326 130 33 349 116 123 0.2 655 112Fluorine 2.5 83.3 41.8 0.4 320 29 - - - -Lead 5.2 101 13 3.1 252 66.5 67 0.02 273 56.8Manganese 123 430 191 24.5 750 250 - - - -Mercury 0.008 3 0.073 0.005 2.5 0.1 4.3 0.013 49.5 0.1Nickel - - - - - - 117.5 0.1 1270 77.6Selenium 0.13 11.8 5.52 0.6 19 9.97 8.7 0.0003 49.5 7.7Silver 0.08 4 0.7 0.04 8 0.501 3.7 0.01 49.5 3.2Strontium 396 2430 931 30 3855 775 - - - -Thallium - - - - - - 19.2 0.15 85 9Vanadium 100 377 251 11.9 570 248 397 43.5 5015 252Zinc 56.7 215 155 - - - 286.5 0.28 2200 148Source: US EPA, March 15, 19991,2. These samples are designated “Mechanical Hopper Ash” and “ Fine Fly Ash”, respectively, in the original studyExhibit 4: Overview of Bottom Ash and Boiler Slag Constituent Compounds, (Expressed in PPM)Bottom Ash Boiler SlagCoal Type BituminousSub-bituminousLignite Bituminous LigniteLocation West Virginia Ohio Texas West Virginia No. DakotaSilicon Dioxide 536,000 459,000 471,000 454,000 700,000 489,000 536,000 405,000Aluminium Oxide 283,000 251,000 283,000 193,000 159,000 219,000 227,000 138,000Iron Oxide 58,000 143,000 107,000 97,000 20,000 143,000 103,000 142,000Calcium Oxide 4,000 14,000 4,000 153,000 60,000 14,000 14,000 224,000Magnesium Oxide 42,000 52,000 52,000 31,000 19,000 52,000 52,000 56,000Sodium Oxide 10,000 7,000 8,000 10,000 6,000 7,000 12,000 17,000Potassium Oxide 3,000 2,000 2,000 - 1,000 1,000 1,000 11,000Source: Coal Bottom Ash/Boiler Slag Material Description – Turner-Fairbank Highway Research CenterCoal Combustion Residuals9Exhibit 5: Coal-Fired Utility Large-Volume Wastes: Bottom Ash and Boiler Slag Concentrations (ppm)Tetra Tech data providedfor 1988 Report to CongressData Provided for 1993 Regulatory DeterminationBottom Ash Bottom Ash Boiler SlagConstituent Min. Max. Median Mean Min.Max. Median Mean Min. Max. MedianAntimony - - - 4.10 0.18 8.40 4 0.70 0.25 1 0.80Arsenic 0.5 168 4.45 7.70 0.80 36.50 4.70 23 0.01 254 4.50Barium 300 5789 1600 1526 24 9360 633 698.70 6.19 1720 413Beryllium - - - 2.2 1.4 2.9 2.52 7 7 7 7Boron 41.9 513 161 109.90 1.79 390 90 31.70 0.10 55 49.50Cadmium 0.1 4.7 0.86 2.70 0.05 5.50 3.1 22.40 0.01 40.50 40.50Chromium 3.4 350 120 411 3.41 4710 121 592.1 1.43 5981 158Copper 3.7 250 68.1 61.40 2.39 146.30 61.10 52 1.37 156 32Fluorine 2.5 104 50 - - - - - - - -Lead 0.4 90.6 7.1 35 0.86 843 13.20 34.60 0.40 120 8Manganese 56.7 769 297 - - - - - - - -Mercury 0.005 4.2 0.023 0.013 0.003 0.04 0.009 5.10 0.016 9.50 9.50Nickel - - - 161.20 1.9 1267 79.6 81.4 3.3 177 83Selenium 0.08 14 0.601 1.10 0.007 9 0.80 4.80 0.01 14 4.50Silver 0.1 0.51 0.2 3 0.06 7.10 3 22.20 0.01 74 37Strontium 170 1800 800 - - - - - - - -Thallium - - - 0 2 2 0 37.30 33.5 40 38.50Vanadium 12 377 141 143.10 24 264 141 146.10 75 320 75Zinc 4 798 99.6 123.10 3.8 717 52.60 79.20 4.43 530 35.80Source: US EPA, March 15, 1999(2) Impacts of CCRs use:

• In clinker manufacture, CCRs partially offset the need for virgin silica, iron, and alumina sources. Using CCRs in the cement kiln can reduce the unit consumption of virgin feed stock materials, which ma y reduce the overall emissions associated with materials extraction and processi ng, since CCRs generally require less preprocessing than the virgin materials they replace.

• With respect to emissions from the cement kiln itself, to the extent CCRs have a lower emission profile than the virgin materials they replace, overall emissions will be reduced. However, CCRs may have hi gher emissions of pollutants such as mercury than virgin silica, iron and al umina sources when burned in the kiln.

• The specific lifecycle impacts of CCR use as a raw material in clinker production

are not evaluated here because of uncertain ties in lifecycle scenario development. For example, it is difficult to determine the replacement ratio between CCRs and other raw feed materials in clinker pr oduction. Thus, the correct quantity of material to be modeled is unclear. In addition, CCRs may substitute for a combination of virgin raw materials a nd other secondary materials (e.g., blast furnace slag, foundry sand, cement kiln dust, etc.); the choice of material often depends on location-specific factors such as the proximity of material sources to the cement kiln and relative availability of different materials. Avoided upstream impacts depend heavily on the specific ma terial being displa ced in the lifecycle

scenario.

• When fly ash with a high unburned carbon content is introduced to the cement kiln during clinker manufacture, fuel s upply may be reduced to accommodate the additional energy provided by the carbon in the fly ash (Bhatty, Javed et al. 2001).

• One health risk issue is currently gaining attention in the use of fly ash in highheat applications such as cement ma nufacture. When exposed to elevated temperatures (approximately 2,750 degrees Farenheit) in a cement kiln, laboratory experiments have found that mercury is r eadily released from fly ash (PflughoeftHasset et al. 2007). At this time, the leve l of mercury in fly ash has not been considered significant enough to create a hea lth risk. However, as coal utilities increasingly employ mercury capture technologies, some facilities may implement technologies that result in fly ash with much higher mercury content

that is not suitable for use in cement manufacture. Other, more expensive technologies would ensure that most or all fly ash is separate from mercury capture; at this point it is not clear how much, if any, fl y ash would be affected by mercury capture technology.

• Combustion of stockpiled CCRs to produce a low loss on ignition (LOI) coal ash has several potential advantages:

o Removal, recovery, and characterization of landfilled CCRs so that recovered CCRs may be put to benefi cial use. Characterization includes energy content, sulphur content, mois ture, and trace metals content for energy and air emissions analyses.

o Preservation of licensed landfill space.

o Preservation of coal reserves by re covering heat from reclaimed CCRs.Coal Combustion Residuals

11 o Production of low LOI coal ash that may be substituted for portland cement thereby reducing the need for portland cement and reducing air emissions from its production process.

o Reduced need for limestone quarries (due to the use of ash as a substitute for portland cement) and landfill sites (WEC, p.2). 7

7 Recovery of landfilled ash may require extra screening. For example, during the removal of ash from a landfill in Wisconsin in 2000, the removed materials were crushed, screened and periodically sampled in accordance with ASTM D2234. It was found that over 99 percent of the material removed consisted of coal combustion products, with foreign materials consisting of lost items from landfill operators (e.g., soda cans, safety ribbon, gloves, etc.) (WEC, 2006, p3).Coal Combustion Residuals

12 References

American Coal Ash Association (a), “Frequently Asked Questions,” accessed at: www.acaa-usa.org.

American Coal Ash Asso ciation. (ACAA), 2008, Coal Combustion Product ( CCP) Production and Use Survey,

accessed at: . http://acaa.affiniscape.com/associati ons/8003/files/2008_ACAA_CCP_Sur vey_Report_FINA L_100509.pdf

American Coal Foundation, “All About Coa l: Fast Facts About Coal,” accessed at: http://www.teachcoal.org/about coal/articles/fastfacts.html

.

American Coalition for Clean Coal Electricity (A CCCE), “America’s Power: Factoids,” accessed at: http://www.americaspower.org/The-Facts/Factoids

Bhatty, Javed et al., “Use of High-Carbon Fly Ash In Cement Manufacture,” Cement Americas , May 1, 2001,

accessed at: http://cementamericas.com/mag/cement_highcarbon_fly_ash/

.

BNET Business Network, “Disposal and Reuse of Coal Combustion Byproducts; With Scores of New Coal-Fired Projects Now Being Considered in the US, Coal Combustion Byproducts are Gaining the Attention of Owners, Developers, Financial Backers, Governments, Environmental Groups, and the General Public,” 2002, accessed on August 21, 2008, at: http://findarticles.com/p/articles/mi_qa5392/is_200201/ai_n21309385.

Goss, David, public comment public comment in response to EPA’s Advanced Notice of Proposed Rulemaking for

Identification of Non-Hazardous Materials That Are Solid Waste, EPA docket EPA-HQ-RCRA-2008- 0329, submitted on behalf of American Coal Ash Association, February 2, 2009.

Pflughoeft-Hasset, Debra F. et al., 2007, Analysis of How Carbon-Based Sorbents Will Impact Fly Ash Utilization and Disposal, Presented at 2007 World of Coal Ash, May 7-10, 2007, Covington, Kentucky, accessed at: http://www.flyash.info/2007/151pflug.pdf

.

PMI Ash Technologies, LLC, public comment in response to EPA’s Proposed Rulemaking for Identification of Non-Hazardous Materials That Are Solid Waste, EPA docket/document number EPA-HQ-RCRA-2008- 0329-1315, submitted August 3, 2010.

Sliver, Steven R., public co mment in response to EPA’s Proposed Rule making for Identifica tion of Non-Hazardous Materials That Are Solid Waste, EPA docket/ document number EPA-HQ-RCRA-2008-0329-1395, submitted on behalf of the State of Michigan Department of Natural Resources & Environment, August 3,

2010.

Turner Fairbank Highway Research Center and the Federal Highway Administration, User Guidelines for Waste and Byproduct Materials in Pavement Construction , accessed at: http://www.tfhrc.gov/hnr20/recycle/waste/begin.htm

.

Turner Fairbank Highway Research Center an d the Federal Highway Administration, Coal Fly Ash Material Description , accessed at: http://www.tfhrc.gov/hnr20/recycle/waste/cfa51.htm

Turner Fairbank Highway Research Center and the Federal Highway Administration, Coal Bottom Ash and Boiler Slag Material Description , accessed at: http://www.tfhrc.gov/hnr20/recycle/waste/cbabs1.htm

United States Census Bureau, 2002 Economic Census , Industry Snapshots for Cement Manufacturing , accessed on August 18, 2008 at: http://quarterhorse.dsd.census.gov/TheDataWeb_HotReport/servlet/HotReportEngineServlet?emailname=bCoal Combustion Residuals

13 h@boc&filename=mfg1.hrml&20071204152004.Var.NAICS2002=327310&forward=20071204152004.V

ar.NAICS2002

.

United States Department of Energy, Energy Informati on Administration (EIA). 2008, “Annual Energy Outlook 2008 with Projections to 2030,” Publication DOE/EIA-0383 (2008), June 2008.

United States Department of Energy, Energy Information Administration (EIA). 2010, “Net Generation by Energy Source: Total (All Sectors),” Table 1.1. Repo rt Released March 15, 2010. accessed at: http://www.eia.doe.gov/cneaf/electricity/epm/table1_1.html

United States Environmental Protection Agency (EPA). March 15, 1999, Technical Background Document for the Report to Congress on Removing Wastes from Fo ssil Fuel Combustion: Waste Characterization, accessed

at: http://www.epa.gov/epawaste/nonhaz/indu strial/special/fossil//ffc2_399.pdf

United States Environmental Protection Agency (EPA). June 3, 2008, Study on Increasing the Usage of Recovered Mineral Components in Federally Funded Projects Involving Procurement of Cement or Concrete to Addr ess the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users

. Wisconsin Energy Corporation (WEC). 2006 Performance Report, Environmen tal Performance, 2006a accessed on August 21, 2008, at: http://www.wisconsinenergy.com/performrpt/index.htm.

Wisconsin Energy Corporation (WEC). Annual Performance Report, Environmental Cooperative Agreement, Pleasant Prairie Power Plant, Pleasant Prairie, Wisconsin, June 2006b, accessed on August 25, 2008 at: http://dnr.wi.gov/org/caer/cea/ecpp/agr eements/wepco/repor ts/2006report.pdf

Wisconsin Energy Corporation (WEC). “Amendment and Extension of the Environmental Cooperative Agreement between We Energies’ Pleasant Prairie Power Plant and Wisconsin Department of Natural Resources,” Fact Sheet, Pub #CO-312, February 2006c, accessed on August 25, 2008 at: http://dnr.wi.gov/org/caer/cea/ec pp/agreements/wepco/agreement s/amended/factsheet20060205.pdf

Wisconsin Energy Corporation (WEC). “Coal Combustion Products Utilization Handbook,” first published in 2000, second edition 2004, accessed on August 22, 2008 at: http://www.bloomconsultants.com/publishedMT_Coal-Combustion.htm