ANALYSIS OF NON-UTILITY COAL COMBUSTION WASTE

GENERATION AND MANAGEMENT

BASED ON THE 2001 CIBO VOLUNTARY SURVEY

April 2002 

Prepared for:

U.S. Environmental Protection Agency 

Office of Solid Waste 

Prepared by:

Science Applications International Corporation 

Engineering and Environmental Management Group 

11251 Roger Bacon Drive 

Reston, VA 20190

Under Subcontract to: 

Eastern Research Group 

2200 Wilson Boulevard, Suite 400 

Arlington, VA 22201

EPA Contract No. 68-W-02-036, WA 12 

SAIC Project No. 01-1026-08-2996-xxx
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ANALYSIS OF NON-UTILITY COAL COMBUSTION WASTE

GENERATION AND MANAGEMENT

BASED ON THE 2001 CIBO VOLUNTARY SURVEY

In 2001, the Council of Industrial Boiler Owners (CIBO) conducted a voluntary survey of nonutility facilities that burn coal. The U.S. Environmental Protection Agency (EPA) defines nonutilities as facilities that are not primarily engaged in the generation of electric power for 

commercial sale. The CIBO survey was designed to obtain basic, existing information about the 

identity of these facilities and the amounts of wastes and waste management practices at these 

facilities. The purpose of the survey was to provide information to inform EPA’s upcoming 

rulemaking on coal combustion waste (CCW). 

This document is an analysis of the information obtained in response to the CIBO survey. First, 

it provides an analysis of how accurately the survey responses represent the known universe of 

coal-burning non-utility facilities. Second, it presents the information on CCW generation and 

management obtained from the survey. The analysis considers much of this information in 

comparison to the generation and management of CCW at electric utilities. 

1. REPRESENTATIVENESS OF THE CIBO SURVEY 

EPA has identified 759 non-utility facilities with the capacity to burn coal and, therefore, 

generate CCW. EPA identified this population of coal-burning non-utilities using four sources: 

· EPA's Industrial Combustion Coordinated Rulemaking (ICCR) Database, 

· EPA's Unified Air Toxics (UAT) Database, 

· The U.S. Department of Energy (DOE) Energy Information Administration’s (EIA) EIA860B Database, and 

· The DOE EIA’s EIA-3 Database. 

Appendix A presents further information on these sources and the methodology EPA used to 

create its inventory of coal-burning non-utilities using these sources. The facilities in the 

inventory are commercial, industrial, and institutional facilities that burn coal to generate heat, 

steam, or electricity primarily for their own use (as opposed to for commercial sale). 

The 66 respondents to the CIBO survey represent 8.7 percent of EPA’s inventory of coalburning non-utilities. As discussed in Sections 1.1 and 1.2, the survey respondents are generally 

representative of the population in terms of their distribution geographically and among industry 

sectors. Furthermore, while the sample is small in terms of the number of facilities represented, 

the survey respondents represent a large proportion of non-utility coal consumption and CCW 

generation, as shown in Sections 1.3 and 1.4. 

1.1 Geographic Representativeness
Analysis of Non-Utility CCW Generation and Management April 2002 

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Figure 1 is a map showing the distribution of the CIBO survey respondents in comparison to the 

facilities in EPA’s inventory. Figure 2 shows the survey response rate by State and EPA Region 

in tabular form. As shown in these figures, the survey respondents have a geographic 

distribution that is roughly the same as that of the non-utility population. 

The three EPA Regions (Regions 3, 4, 5) that account for the majority of coal-fired non-utilities 

also account for the majority of survey respondents. Five of the top six EPA Regions in terms of 

number of facilities in the population are well represented in the survey, with response rates of 6 

to 16 percent. Of these six, only Region 8 seems somewhat under-represented, with a response 

rate of 4 percent. Overall, correlation of survey respondents to the population by Region is 0.92. 

 There is greater variation in response rate by State. All States with more than 20 non-utilities, 

however, are represented in the survey responses. Correlation of survey respondents to the 

population by State is 0.59. 

Figure 1 

 Map of CIBO Survey Respondents and EPA’s Inventory of Non-utilities

(Numbers shown are # of respondents/# of facilities in EPA’s inventory) 
Analysis of Non-Utility CCW Generation and Management April 2002 

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Figure 2 

Survey Response Rate by State and EPA Region

State 

Facilities in 

Inventory 

Facilities in 

CIBO Survey 

Response 

Rate EPA Region 

Facilities in 

Inventory 

Facilities in 

CIBO Survey 

Response 

Rate 

PA 103 5 5% Region 5 342 22 6%

IL 97 2 2% Region 4 151 20 13%

MI 90 3 3% Region 3 146 15 10%

OH 56 3 5% Region 7 30 4 13%

WI 40 8 20% Region 8 26 1 4%

MN 38 2 5% Region 6 19 3 16%

NC 36 7 19% Region 10 12 0 0%

VA 31 6 19% Region 1 11 1 9%

TN 26 3 12% Region 2 11 0 0%

GA 23 2 9% Region 9 11 0 0%

SC 22 3 14% Total 759 66 9%

IN 21 4 19%

KY 18 0 0%

AL 17 3 18%

IA 16 0 0%

TX 12 2 17%

WY 11 0 0%

MO 10 3 30%

WV 10 3 30%

NY 9 0 0%

FL 7 1 14%

CA 5 0 0%

ID 5 0 0%

ME 5 1 20%

ND 5 0 0%

UT 5 0 0%

AK 3 0 0%

AR 3 0 0%

AZ 3 0 0%

MA 3 0 0%

NE 3 1 33%

SD 3 0 0%

WA 3 0 0%

HI 2 0 0%

LA 2 0 0%

MS 2 1 50%

NJ 2 0 0%

OK 2 1 50%

VT 2 0 0%

CO 1 1 100%

CT 1 0 0%

DE 1 0 0%

KS 1 0 0%

MD 1 1 100%

MT 1 0 0%

NV 1 0 0%
Analysis of Non-Utility CCW Generation and Management April 2002 

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OR 1 0 0%

Total 759 66 9%

1.2 Representativeness by Industry

Figure 3 shows the survey response rate by industry sector, as indicated by North American 

Industry Classification System (NAICS) code. The three manufacturing sectors with the largest 

number of facilities in the population (paper; food, beverage, and tobacco; and chemical 

manufacturing) are well represented in the survey, with response rates from 10 to 21 percent. 

The single largest non-manufacturing sector (educational services) appears to be somewhat 

under-represented, with a 5 percent response rate. Non-manufacturing sectors, in general, are 

less well represented than manufacturing sectors. Overall, however, correlation of survey 

respondents to the population by industry sector is 0.77. Thus, the survey respondents have a 

distribution by sector that is roughly similar to that of the population. 

Figure 3 

Survey Response Rate by Industrial Sector

NAICS code(s) Industry 

Facilities in 

Inventory 

Facilities in 

CIBO 

Survey 

Response 

Rate 

322 Paper Manufacturing 128 27 21%

311-312 Food, Beverage, and Tobacco Product Manufacturing 95 9 10%

325 Chemical Manufacturing 88 14 16%

327 Nonmetallic Mineral Product Manufacturing 56 0 0%

336 Transportation Equipment Manufacturing 43 0 0%

313-314 Textile Mills and Textile Product Mills 33 3 9%

331-332 Primary Metal and Fabricated Metal Manufacturing 27 2 7%

315-316, 321, 

323-324, 326, 

333-335, 337, 

339 All Other Manufacturing 55 0 0%

Total Manufacturing 525 55 10%

611 Educational Services 141 7 5%

21 Mining (except Oil and Gas) 29 1 3%

92 Public Administration 24 1 4%

62 Health Care and Social Services 14 0 0%

2213 Water, Sewage, and Steam and Air-conditioning Supply 11 2 18%

421-422, 482, 

484, 488, 493, 

531, 541, 

561-562, 813 All Other Non-manufacturing 13 0 0%
Analysis of Non-Utility CCW Generation and Management April 2002 

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Total Non-manufacturing 232 11 5%

Unknown Unknown 2 0 0%

Total 759 66 9%

1.3 Proportion of Coal Consumption Represented

EPA estimates that the 759 non-utilities in its inventory consumed greater than 65 million tons of 

coal in 2000. Appendix B describes the methodology EPA used to develop this estimate. 

Although EPA’s estimate is based in part on data from DOE’s EIA,1 EPA’s total is somewhat 

greater than coal consumption for 2000 for U.S. manufacturing plants as reported by EIA 

(61,820,000 tons). The differences between these figures are the result of the following factors: 

· EIA’s data include coal consumption at cement manufacturing facilities that burn coal 

only within their cement kilns (as opposed to in separate coal-fired boilers). Because 

such facilities are outside the scope of EPA’s regulatory determination, EPA’s estimate 

does not include coal consumption by these facilities. 

· EIA’s data do not include coal consumption by non-manufacturing facilities (e.g., 

institutional and commercial facilities. EPA’s estimate includes these facilities. 

· EIA’s data do not include coal consumption by facilities that burned less than 1,000 tons 

of coal in 2000. EPA’s estimate includes these facilities. 

 1

 “Table 43: U.S. Coal Consumption at Manufacturing Plants by North American Industry Classification 

System (NAICS) Code.” Quarterly Coal Report, October-December 2000. Energy Information Administration; 

Office of Coal, Nuclear, Electric and Alternate Fuels; U.S. Department of Energy. Washington, D.C. DOE/EIA–

0121(2000/4Q). 
Analysis of Non-Utility CCW Generation and Management April 2002 

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The respondents to the CIBO survey reported burning a total of greater than 16 million tons of 

coal per year.2

 Figure 4 compares this total to EPA’s estimated coal consumption for the entire 

population. While the survey respondents cover only 8.7 percent of EPA’s inventory of 

facilities, they account for almost 25 percent of the estimated total coal consumption. Thus, the 

survey respondents include some of the largest facilities in terms of coal consumption. This 

result is significant because coal consumption is a major determining factor in the quantity of 

CCW waste generated, as discussed in Section 1.4, below. 

2

 This total accounts for 65 of the 66 respondents. One respondent indicated that coal consumption data 

was confidential business information. 
Analysis of Non-Utility CCW Generation and Management April 2002 

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 Figure 4 

 Proportion of Coal Consumption Represented by CIBO Survey Respondents

1.4 Proportion of CCW Generation Represented

EPA estimates that the 759 non-utilities in its inventory generate approximately 7.8 million tons 

of CCW per year. EPA’s estimate is based primarily on each facility’s estimated coal 

consumption and accounts for the following factors that can affect waste generation: 

· The presence of particulate control devices that determine whether a facility generates fly 

ash. 

· The presence of flue gas desulfurization (FGD) devices that determine whether a facility 

generates FGD waste. 

· The use of fluidized bed combustion (FBC) technology. In general, FBC facilities tend 

to generate more CCW than facilities using conventional coal combustion technologies 

because of the presence of spent bed and sorbent materials in the waste and the potential 

for using higher ash content fuels.3

 3

 For further discussion, see “Chapter 5: Fluidized Bed Combustion Wastes.” Report to Congress on 

Wastes from the Combustion of Fossil Fuels, Volume 2 - Methods, Findings, and Recommendations. United States 

Environmental Protection Agency, Office of Solid Waste and Emergency Response. Washington, D.C. EPA 530-

R-99-010. March 1999.
Analysis of Non-Utility CCW Generation and Management April 2002 

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EPA’s estimate does not account for certain other factors that can affect waste generation, such 

as coal quality and differences between combustion technologies other than FBC (e.g., 

pulverized coal versus stoker boilers). Data on these factors were not available for most of the 

facilities in EPA’s inventory. Appendix C provides further details on the methodology EPA 

used to develop this estimate. 

The respondents to the CIBO survey reported generating a total of greater than 2.1 million tons 

of CCW per year.4 Figure 5 compares this total to EPA’s estimated CCW generation for the 

entire population. While the survey respondents cover only 8.7 percent of EPA’s inventory of 

facilities, they account for greater than 27 percent of the estimated total coal consumption. This 

result is consistent with the observation that survey respondents generate a large proportion of 

total coal consumption. It also reflects the following characteristics of the survey respondents: 

· The survey respondents are more likely to have particulate control devices. Of 65 

respondents that provided data on these devices, all 65 (or 100 percent) have them. In 

comparison, EPA estimates that only 78 percent of non-utility facilities in the inventory 

have particulate control devices. 

· The survey respondents are slightly more likely to have FGD devices. Of 65 respondents 

that provided data on these devices, 6 (or 9.2 percent) have them. In comparison, EPA 

estimates that only 8.2 percent of non-utility facilities in the inventory have particulate 

control devices. 

· The survey respondents are slightly more likely to use FBC technology. Of 65 

respondents that provided data on combustion technology, 7 (or 10.8 percent) have at 

least one FBC unit. In comparison, EPA estimates that only 3.8 percent of non-utility 

facilities in the inventory use FBC technology. 

4

 This total accounts for 65 of the 66 respondents. One respondent indicated that CCW generation data was 

confidential business information. Note also that the total waste reported generated by respondents varies from the 

total reported disposed and beneficially used (see note to Figure 5 for discussion). 
Analysis of Non-Utility CCW Generation and Management April 2002 

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The conclusion that the survey respondents represent a large proportion of total non-utility CCW 

generation is significant. This conclusion implies that data from the survey about CCW 

management practices, discussed in Section 2 of this report, are applicable to a larger proportion 

of the total CCW quantity than might otherwise be indicated by the number of survey 

respondents alone. 

 Figure 5 

 Proportion of CCW Generation Represented by CIBO Survey Respondents

Note to Figure 5: The total CCW generation shown in Figure 5 varies from the total CCW reported disposed and 

beneficially used in Section 2 of this report. This variation does not necessarily indicate inconsistent responses to 

different survey questions, as waste generated in a given year may not be disposed or used in the same year. 

2. GENERATION AND MANAGEMENT OF NON-UTILITY CCW

[To be completed] 

2.1 Non-utility CCW Generation

[Comparison to utilities and trends] 

2.2 Beneficial Use of Non-utility CCW

[Overall proportion and comparison to utilities] 

2.3 Co-disposal of Non-utility CCW with Other Industrial Wastes
Analysis of Non-Utility CCW Generation and Management April 2002 

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[Number of facilities and proportion of waste co-disposed] 
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2.4 Location and Type of Non-utility CCW Management Units

[3rd party, permitted facilities; surface impoundments versus landfills in comparison to utilities; 

discuss distinction between disposal and storage-only units] 

2.5 Size of Non-utility CCW Management Units

[Comparison to utilities] 

2.6 Environmental Controls and Monitoring at Non-utility CCW Management Units

[Prevalence of controls, comparison to utilities] 

2.7 Closure Plans and Controls at Non-utility CCW Management Units

[Prevalence of controls]