From: Bactow@aol.com [mailto:Bactow@aol.com] 

Sent: Thursday, October 08, 2009 8:34 AM

To: Wastewise

Subject: Coal Ash Comments 

 

October 8, 2009 

 

EPA Docket Center 

EPA Docket ID No. EPA-HQ-RCRA-2008-0329 

Identification of Non-Hazardous Materials That Are Solid Waste 

Environmental Protection Agency 

Mailcode: 2822T 

1200 Pennsylvania Ave. NW 

Washington, DC 20460 

 

Attention: EPA Docket ID No. EPA-HQ-RCRA-2008-0329 

 

Dear Sir or Madam: 

 

U.S. Harvest Energy and Technologies Corporation (U.S.) is pleased to provide these 

comments pertaining to the Advanced Notice of Proposed Rulemaking concerning the 

Identification of Non-Hazardous Materials that are Solid Waste that was published in the 

Federal Register on January 2, 2009. 

 

Our Company (U.S.) intends process and market CCPs in the United States and we 

support the management and use of coal combustion products – or CCPs (the preferred 

industry term which emphasizes value) in ways that are environmentally responsible, 

technically sound, commercially competitive and supportive of a more sustainable global 

community. 

 

U.S. thanks the Agency for proposing to clarify which non-hazardous secondary 

materials are not solid wastes under RCRA when such material is burned for fuel value or 

used as an ingredient in manufacturing processes. Clarification is essential to this 

nation where natural resources need to be more widely conserved and secondary 

materials from manufacturing processes can be substituted for these natural materials 

economically and protective of human health and the environment. 

 

CCPs, which are created during the production of electricity in coal fueled power plants, 

consist of materials such as fly ash, bottom ash, boiler slag, flue gas desulfurization 

materials such as FGD (or synthetic) gypsum and spray dryer residues, and cenospheres. 

The total of all these materials is estimated to be greater than 130 million tons annually. 

Nearly 15 million tons of fly ash, for example, are used annually in the making of 

Portland cement concrete, helping offset nearly 15 million tons of CO2 in the process and 

sparing landfill space. An additional five million tons or more of fly ash, bottom ash and 

boiler slag are used as ingredients in the manufacture of Portland cement. 

In the manufacture of Portland cement, there are a number of cement kilns that use or 

have used high carbon fly ash as a fuel (when the carbon fraction of the ash is higher than 
permitted to allow the use of the fly ash in concrete). This purpose is twofold. First, the 

constituents within the fly ash are similar to those required from natural materials (such 

as shale, marl or limestone) in that they contain fractions of silica, iron and aluminum 

needed in the kiln. Secondly, the high carbon content imparts energy through its 

combustion, reducing the need for some portion of fuel for the kiln. 

 

We also fully support those situations where an electric generating station is able to 

recover high-carbon content ash as a fuel source with coal. The carbon content of the ash 

is approximately 20-30%, thus reducing the total fresh coal required. 

 

The use of these alternative fuels reduces the energy required to extract and transport 

virgin resources, such as coal, potentially eliminating the need to add to or create 

new landfill space for these materials that might otherwise be disposed. The reduction in 

energy related to extraction and transportation can have a measurable impact on reducing 

CO2 emissions as well. It is essential that this nation conserve its natural resources and 

make better use of industrial materials that can serve the same purposes. 

 

There are several patented processes for removing unwanted carbon from fly ash that 

allow processed technically compliant fly ash to be used in concrete. 

 

Benefits include: 

Consistent enhanced pozzolan product ready mix producers desire. A carbon content of 

1.0% or less has virtually no effect on entrained air in concrete. A carbon content of 

approximately 3%, for example, has a dramatic effect on air entrained concrete. 

The ash produced can be utilized as is for higher value applications because of its high 

quality and consistency. The ash can be further processed for even higher value uses. 

Some of these include uses for industrial fillers in plastics, rubber, asphalt and specialty 

applications. 

The carbon product produced has a purity of 90% or greater. 

The byproduct carbon produced has a value based on a number of market areas, including 

at the least, as a high BTU fuel. Current market research indicates pure carbon can be 

used in traditional markets for purification as activated carbon. 

High purity carbon has the potential to remove mercury and other heavy metals from gas 

streams at coal-fired plants. This carbon may also be used with iron oxide to treat 

disposal water from power plants and landfills including discharge effluents containing 

arsenic, selenium, chromium and mercury, etc. 

We believe, current EPA standards of 10 ppb/L for arsenic and selenium are safe but the 

level of carbon in fly ash should be lowered from 6% to 3% for reasons stated and we 

appreciate this opportunity to provide comments on this advanced notice of proposed 

rulemaking. Should you have any comments or questions about this submittal, please 

contact me at: (443) 320-3123 or Bactow@aol.com. Thank you. 

 
Respectfully Submitted, 

 

William L. Robinson, Jr. 

Chairman & CEO 

U.S. Energy and Technologies Corporation 

5900 Greenspring Avenue 

Baltimore, Maryland 21209-3920 

(443) 320-3123 - Phone 

(410) 318-6452 - Fax