Did you know that half of the electricity used in the United States is generated by burning coal?
And when coal is burned ash is left over. For example, whenever someone uses $100 of electricity, close to an average monthly bill, they will have consumed a ton of coal and produced close to 200 pounds or a barrel of ash. Just like other forms of recycling, the US EPA encourages the recycling of ash in beneficial use projects like Cumberland Park. A small group of volunteers known as the Giles County Partnership For Excellence created Cumberland Park as a way to recycle the ash in a way that benefits our community. Some current facts are listed below .
- Costs for ash disposal, and in this case beneficial use, are a fuel cost that gets passed on to APCo customers. Initial CCB placement this project has saved $1.5 million in an environmentally approved, responsible manner, for APCo customers. This helps to keep rate increases to a minimum.
- Unlike the TVA disaster from December 2008, CPK is a dry (designed to handle rainfall events) storage application. In other words, more CPK's would require less wet ash ponds (surface impoundment) like the one that failed at TVA.
- Two years worth of groundwater testing, as requested, from monitoring wells at the site, shows no impact to groundwater from the ash placement. Attached to this site are the ground water monitoring reports prepared by Draper Aden and Associates which were submitted to the county board of supervisors. These reports are complete with sample quality control and chain of custody. AEP is on record as stating if there was ever a problem they would stand by the project.
- CPK fill area is protected from inundation by a 100 year flood by
a protective berm. Upon completion and submittal to FEMA, it will be certified as out of the flood plain.
- Two feet of final cover is advanced on portions of the ash when brought to grade. Seeding then follows.
- CPK continues to have successful inspections from state agencies such as DEQ and DCR. In fact, never has there been an inspection noting violations.
- Structural fills are a form of beneficial use projects encouraged by the EPA to save valuable landfill space.
- Facts such as these help an informed citizenry to dismiss claims made by some as tactics to arouse fear and suspicion concerning this project.
A Word About Responsible Use of Coal Ash
Coal ash has been in the news lately and not in a positive way. The breach of the TVA impoundment near Knoxville has drawn negative sentiment from citizens and government alike. However, the Cumberland Project differs from the Knoxville project in several key ways:
- The TVA site involved an impoundment which was a part of a wet ash slurry process of removing fly ash. Glen Lyn Plant utilizes the dry system of ash conveyance as the ash is conveyed to a silo (this ash has consistency of baby powder). Here it is blended with a controlled amount of moisture to optimize compaction and loaded into a truck, and then taken to a fill site, where it is compacted, brought to grade, then covered with two feet of soil to produce a stable, buildable site.
- Water is controlled at the Cumberland site. Even water that may pool after heavy rains is contained into settling ponds away from the building site itself. This level of engineering protects the site, which will be raised more than12 feet above the flood plain when finished
- Structural fill projects are a safe alternative to the type of pond storage using a water slurry.
- The Cumberland site has been regularly inspected by the Department of Environmental Quality and other regulatory agencies. The project has received no negative reports from any of these inspections.
- These types of projects are encouraged by the Environmental Protection Agency as noted in the C2P2 program.
- Monitoring wells have been voluntarily drilled at the site and are checked regularly to establish a baseline reading and note any changes. Additionally ash is periodically tested as it arrives on site on a voluntary basis to make sure it continues to conform to required parameters for heavy metals.
Giles County Partnership for Excellence Foundation’s
Cumberland Park Structural CCB Fill
- What are CCB’s? Where do they come from? CCB’s are Coal Combustion By-Products. They are produced from burning coal. The term CCPs is used interchangeably. Most coals have an ash content of around 10%; therefore, for every 100 tons of coal burned (about the capacity of one railroad car) 10 tons of CCB’s are produced. Glen Lyn typically burns on average about 20 rail cars every day of the year thus yielding on average 200 tons per day of CCBs. There are two types of CCBs produced at the Glen Lyn Plant, fly ash and bottom ash. Fly ash make up about 80% of the CCBs produced. This ash would pass from the boiler to the stack and out to the atmosphere were it not captured by the electrostatic precipitators (ESPs). The ESP removes 99.95% of the fly ash from the stack and transfers it by a vacuum system to the plant silo. Here it can be moistened with water and hauled by trucks to the landfill or beneficial use site. The other 20% of the CCBs produced is called bottom ash because it is too heavy to pass through the boiler and ESP and it falls to the bottom of the boiler. From there it is sluiced through pipes to one of the two bottom ash ponds where it is collected. Once a pond is full it is dewatered and the bottom ash loaded and hauled by trucks to the landfill or beneficial use site.
Is coal ash hazardous? From American Coal Ash Association Web site Coal, like soil, rocks and other natural materials found in the earth’s crust contain trace amounts of heavy metal elements. The burning of coal results in some of these elements being oxidized in the coal ash that is produced. Typically, these heavy metals include arsenic, boron, cadmium, chromium, copper, lead, selenium and zinc.
American Coal Ash Association's FAQ
Beginning in 1988 and continuing through 2000, the U.S. Environmental Protection Agency (EPA) studied extensively the risk that coal ash presents to the environment. First, in a report to Congress dated February 1, 1988 the EPA concluded that the ash resulting from the combustion of fossils fuels was not hazardous and did not need to be regulated as a hazardous waste under the Resource Conservation and Recovery Act (RCRA). In a Report to Congress dated March 1999, the EPA again confirmed that coal ash did not require regulation as a hazardous waste and encouraged the beneficial use of coal combustion byproducts. On May 22, 2000, the Federal Register published the EPA’s final determination “Notice of Regulatory Determination on Wastes from the Combustion of Fossil Fuels.” This Federal Register is available on ACAA‘s website under “What are CCPs?” The Fly Ash Resource Center
As stated earlier, coal ash contains varying concentrations of these heavy metals. Despite the large volumes of ash produced, the total quantity of heavy metals is relatively small, and an even smaller amount of these elements can be released to the environment. Annually, utilities report the total quantity of metals and other materials released in to the environment through Toxic Release Inventory (TRI) reporting requirements. For example, the largest quantities of heavy metals are in the form of manganese, barium and vanadium. Much smaller amounts of copper, lead and other metals are reported under TRI. The impact of these heavy metals is slight. Studies conducted by the University of North Dakota indicate that for most heavy metals, even if released directly into groundwater, the concentrations are so low that they would not adversely affect drinking water quality. A U.S. Geological Survey (USGS) fact sheet states that a “Standardized test of the leach ability of toxic trace elements such as arsenic, selenium, lead and mercury from fly ash shows that the amounts dissolved are sufficiently low to justify regulatory classification of fly ash as non-hazardous solid waste.” Other regulations and standards regarding the use and disposition of coal ash are in place and vary by application from state to state. American Coal Ash Association
However, it is important to note that despite these relatively low concentrations, if improperly managed, any waste can have a negative impact on the environment. The United States and Canadian utility industry have implemented many methods of control and monitoring to ensure that when coal ash is disposed, there will be no adverse affect to human health or to the environment. Environmental stewardship is an important part of the utility industry.
- What is required by law concerning their use or disposal? Virginia Solid waste regulations mandate that CCB’s be disposed of in a Class I Industrial landfill unless one of the conditional exemptions for beneficial use is employed. Examples would be as admixtures for paint or plastics, as raw material for cinder blocks, or other end product or for drainage material/base course for pavement. Regulations also state that CCB’s can be used for structural backfill when certain criteria are met such as 2 foot separation from water table, proper compaction and covering.
- Have Glen Lyn CCB’s been used in the past for this purpose? In 1995 JTM Industries which is now Headwaters Industries (contractor for the Cumberland Project) constructed a 90,000 CY structural fill in Vinton, VA. A market, gas station and greenhouse were constructed on this site. In 1999 and 2000 Headwaters constructed a 190,000 CY structural fill on the Fairchild site in Glen Lyn. This made valuable commercial property out of a vacant field. An AEP regional maintenance center was constructed on a portion of the site.
- Why this Cumberland Park Project? Project involves the development of over 1,200 feet of new Route 460 developmental road frontage. The development of this area adjacent to the Narrows town limits in the western portion of the County, would offer the potential for growth of the County or Town tax base and the potential for many new area jobs. This project is being developed by the Giles County Partnership for Excellence Foundation with the exclusive use of Glen Lyn CCBs. Marginal land is turned into valuable developmental property increasing the tax base and further benefiting the community by providing funds for the vocational education programs of the county schools. Additionally, recycling this fly ash will save the construction and development of many acres of rural areas for a landfill.
- Who designed the project? The project utilizing Glen Lyn Coal Combustion Products (CCP’s) has been designed by Draper Adden and Associates with input from Schnabel Engineering. It is being built by Headwaters Inc. using much of the area labor currently in use at the CCB facility. It is being built in a professional manner in compliance with all state and federal regulations.
- Will the CCB’s simply be dumped at the site? No, the CCB’s are spread in thin lifts and compacted with rollers under strict quality control testing. Optimum moisture is added to obtain placement density meeting ASTM 698 - 95% standards. (Density suitable for building foundations). Likewise, mandated quality control testing and monitoring is undertaken in the construction of all earthwork, and placement of all drainage structures. Erosion and Sediment Plan has been developed and is followed.
- Will the project be a nuisance to neighbors during construction? Headwaters Inc. has had much experience in developing these structural fill sites and has always operated in harmony with the general public. Water trucks and an on demand irrigation system will ensure that dust is not a nuisance. Care is taken to keep noise levels down and no tracking of mud off site will be allowed.
- What will the end use be? Developmental sites, potentially, lots for small businesses, light industry, or perhaps a hotel or large business. Proceeds from the land development will be rolled back into the community, through the schools, and/or other applications to help create much needed jobs.
- How much CCB will be placed there to bring it up to grade? Estimated over 300,000 cubic yards
- Are their concerns regarding the closeness to the New River? A hydrological study has never previously been done for this area. Due diligence engineering studies by Draper Adden and Associates (DAA) using the latest hydrological computer software has defined the floodway and flood plain for the fill area. The CCB’s will be protected from inundation by an earthen berm of controlled backfill armored with anchor reinforced vegetation system capable of withstanding 100 year flood stage flow velocities with additional safety factors. Issues relating to the New River flood plain and floodway have been addressed and are included in the site design and permitting process. A Conditional Letter of Map Revision (CLOMR) has been submitted to FEMA and approved and is to be followed upon project completion by a Letter of Map Revision (LOMR) once the project reaches grade.
- Will the fill site affect flood elevations elsewhere? The computer modeling initiated by DAA has investigated this possibility and found little or no impact.
Concerns relating to groundwater? In compliance with the Virginia State Regulations for Structural Fills a 2 foot buffer distance is maintained from the seasonal high-water table. Additionally, TCLP testing of CCB contact water as required by DEQ has shown that CCBs produce no danger for metals contamination of groundwater.
- Does this project involve public funding? No, this project is located on private property, utilizes private funding, and utilizes no tax money, to the contrary it will eventual create tax revenue.