DRAFT
DRAFT
DISCUSSION
OUTLINE
August
28,
2001
Coal
Ash
Management
I.
Categories
of
Coal
Ash
Management
1)
Used
as
product
(
i.
e.
concrete;
asphalt
filler;
etc)
2)
Used
beneficially
in
the
environment
(
i.
e.
structural
fill;
soil
amendment/
additive)
3)
Beneficially
used
in
active
or
abandoned
coal/
noncoal
minesites
4)
Disposal
II.
Coal
Ash
Management
Principles
for
Beneficial
Use
°
Proper
coal
ash
characterization
to
insure
adequate
protection
of
public
health
and
safety
and
the
environment
°
Reutilization
°
Beneficial
use
of
coal
ash
placement
in
mines:
°
Case
studies
and
monitoring
required
by
the
states
support
the
concept
that
coal
ash
is
a
manageable
material
in
a
mine
environment.
°
Unique
opportunity
to
increase
usage
for
mine
reclamation
and
provide
a
safe
environment
for
disposal
of
ash.
°
Opportunity
for
cost
effective
placement
of
coal
ash
to
help
resolve
the
disposal/
placement
of
increased
amounts
of
coal
ash
being
generated
today
and
into
the
future.
°
Opportunity
to
save
green
space
by
minimizing
the
need
to
develop
ash
disposal
sites
near
power
plants,
often
in
flood
plains.
°
Opportunity
to
place
ash
back
into
its
place
of
origin,
usually
in
a
geochemical
environment
conducive
for
such
placement.

III.
Coal
Ash
Regulatory
Principles
for
Beneficial
Use
°
Coal
ash
is
NOT
a
hazardous
waste,
but
should
be
properly
managed.
°
Few
proven
damage
cases
related
to
coal
ash
placement.
°
States
believe
that
through
cooperation
at
the
state
AND
federal
levels
we
can
make
the
best
use
of
existing
regulatory
and
statutory
authorities
to
protect
public
health
and
safety
and
the
environment.
°
Flexibility
and
discretion
are
necessary
for
the
achievement
of
successful
program
outcomes
due
to
the
difference
in
coal
ashes,
regional
geology,
regional
climate,
mine
site
conditions,
types
of
uses,
and
other
factors.
°
Inter­
agency
cooperation:
°
State
programs
(
i.
e.
mining
programs,
solid
waste
programs,
air
and
water
programs)
have
substantial
experience
and
expertise
in
managing
coal
ash
placement
in
a
mining
environment
(
often
via
coordination
of
efforts
among
state
agencies).
DRAFT
DRAFT
°
Present
day
regulatory
framework
in
states
demonstrates
ability
to
manage
coal
ash
acceptably.
°
Opportunity
for
public
involvement
is
necessary.
°
Parameters
for
determination
of
beneficial
use
at
mine
sites:
°
Ash
composition
is
compatible
for
intended
uses
°
Use
at
selected
site
will
not
create
problems
or
exacerbate
existing
problems
°
There
must
be
a
valid
purpose
for
using
the
ash,
which
could
include:
°
Acid
Mind
Drainage
(
AMD)
remediation
°
Solid
enhancement/
replacement
°
Subsidence
control
°
Approximate
Original
Contour
°
Appropriate
Post­
mining
Land
Use
°
Mine
fire
control
°
Mine
reclamation
IV.
Conclusions
°
Approved
beneficial
use
determinations
by
the
states
preclude
the
need
for
further
waste
regulation
by
EPA
°
Experience
at
the
state
level
in
implementing
existing
state
and
federal
laws
substantiates
the
adequacy
of
the
existing
regulatory
structure.
°
Comprehensive
federal
regulations
will
be
difficult
to
implement
from
a
nationwide
perspective
due
to
differences
in
regional
geology,
climate,
ash
composition
and
other
factors.
°
State
data
and
information
supports
these
conclusions
and
are
available
for
review.

V.
Disposal/
Placement
at
Minesites
(
other
than
Beneficial
Use)

°
Can
be
done
safely
and
with
adequate
environmental
controls
under
existing
state
and
federal
regulations
(
including
SMCRA,
CWA,
state
statutes
and
regulations)
°
Potential
program
components
include:
°
Waste
characterization
°
Site
considerations
(
i.
e.
site
prohibitions;
operation
plans;
approximate
original
contour;
buffer
zones;
physical
hazards;
hydrologic
analyses)
°
Environmental
controls
(
i.
e.
volume
restrictions;
placement
requirements;
use
of
liners;
compaction;
state
ground
water
protection
plans;
water
quality
standards;
air
quality
standards;
monitoring;
reporting)
°
Determination
of
End
Points
(
i.
e.
active
mining
=
contemporaneous
reclamation;
abandoned
mines
=
reclamation;
disposal
=
closure)
°
Assurance
of
Project
Completion
(
i.
e.
financial
assurances
(
surety
bonds,
insurance,
etc.);
enforcement
authorities;
clean­
up
authorities
and
funds
(
CERCLA);
risk
analysis;
other
regulatory
controls
(
BMPs,
NPDES,
Waste
Regulations)).
