FGD) and OTHER COAL COMBUSTION PRODUCTS (Ccps)

MARKET OPPORTUNITIES FOR UTILIZATION OF OHIO FLUE GAS DESULFURIZATION (FGD) AND OTHER COAL COMBUSTION PRODUCTS (CCPs)

Volume 1 – Executive Summary

Tarunjit S. Butalia, Ph.D., P.E. William E. Wolfe, Ph.D., P.E.

Originally Issued: May, 2000

Department of Civil and Environmental Engineering and Geodetic Science The Ohio State University Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Complete electronic versions of Volumes 1 and 2 of this report may be downloaded from the following internet web sites:

http://ccpohio.eng.ohio-state.edu/ccpohio/ http://www.odod.state.oh.us/tech/coal/

ii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

ACKNOWLEDGEMENTS

This report was compiled as a part of a research project entitled Bringing Coal Combustion Products into the Marketplace (OCDO Grant CDO/R-96-26) and was performed at The Ohio State University. The principal sponsors of this research project are the Ohio Department of Development’s Coal Development Office and The Ohio State University. Industrial co-sponsors are American Electric Power, Cinergy, FirstEnergy and Dravo Lime Company (now Carmeuse NA). The US Department of Energy’s Federal Energy Technology Center (now National Energy Technology Laboratory) and American Coal Ash Association – national and Ohio chapter both provide support. Sponsoring trade organizations include the Ohio Farm Bureau Federation, Ohio Cattlemen’s Association, and Ohio Dairy Farmer’s Association.

The authors express their appreciation to all the respondents of the Ohio CCP survey. The data provided by them on the production and use of CCPs in the state has been invaluable and is included in this study. The help and guidance provided by the national American Coal Ash Association in compiling and providing CCP data relevant to Ohio is valued. Ms. Debra Pflughoeft-Hassett of University of North Dakota provided the authors with several topical reports on barriers to CCP use. These reports were helpful in identifying many of the barriers to CCP utilization. The assistance of Ms. Michelle Tinnel of the Ohio Department of Natural Resources- Division of Mines and Reclamation is appreciated. The resources of The Ohio State University Library, particularly the interlibrary loan division, and the Ohio Department of Transportation Library were helpful in the compilation of this report. The authors express their thanks to the staff of these libraries for their assistance. The input provided by the reviewers of the report contributed significantly towards an enhancement of the technical and economic issues associated with CCP utilization that are presented in this report. The comments received from the reviewers are appreciated.

iii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

iv Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

TABLE OF CONTENTS

Page

ACKNOWLEDGEMENTS iii

LIST OF FIGURES vi

LIST OF TABLES vii

1 INTRODUCTION 1 1.1 Background and Objectives 1 1.2 Information Sources 1

2 STATUS OF CCP INDUSTRY IN OHIO 3 2.1 Regulation of CCPs 3 2.2 Advantages and Limitations of Utilization 4 2.3 CCP Production and Utilization 4 2.4 CCP Producer Economics 5

3 FUTURE OF CCP INDUSTRY 13 3.1 Overview of Existing and Potential Uses 13 3.2 Highway / Road Applications 13 3.3 Mine Reclamation Uses 14 3.4 Agricultural Applications 15 3.5 Other Civil Engineering and Miscellaneous Uses 16 3.6 Social Costs and Benefits 16 3.7 Effect of Landfilling Costs on Potential FGD Utilization and Disposal 17 3.8 Future Projections and Estimates 18

4 RECOMMENDATIONS 27

5 CONCLUSIONS 29

6 REFERENCES 30

7 LIST OF ACRONYMS AND ABBREVIATIONS 31

v Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

LIST OF FIGURES

Page

Figure 2-1 Surveyed Coal-Fired Facilities in Ohio 8 Figure 3-1 Funded and Unfunded AML Problems in Ohio (1998 dollars) with Potential for FGD Utilization 22 Figure 3-2 Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled 24

vi Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

LIST OF TABLES

Page

Table 2-1 Types of Coal Combustion Products (CCPs) and Their Characteristics 6 Table 2-2 Annual Production of Selected Non-Fuel Mineral Commodities for Ohio 6 Table 2-3 Ohio Coal-Fired Facilities Surveyed 7 Table 2-4 CCP Production and Use – 1997 9 Table 2-5 FGD Material Production – 1997 10 Table 2-6 Estimated CCP Utilization by Type of Use – 1997 10 Table 2-7 Comparison of CCP Production and Use for Ohio, Regional States, and the United States – 1997 11 Table 3-1 Existing and Potential Uses of CCPs in Ohio 19 Table 3-2 Existing and Potential Uses of CCPs for Highway Applications 20 Table 3-3 Recommended Changes to ODOT Specifications 21 Table 3-4 Potential FGD Tonnage for Uncompleted AML Projects 23 Table 3-5 Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled 25

vii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

viii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

1 INTRODUCTION

1.1 Background and Objectives

The combustion of over 50 million tons of coal annually in the state generates enormous quantities (approximately 10 million tons annually) of solid by-products, referred to as Coal Combustion Products (CCPs). CCPs can be used, or disposed in landfills and surface impoundments. Developing economic and environmentally sound alternatives to expensive and non-productive landfilling of coal combustion products (CCPs) is of vital importance to the state of Ohio.

The report was compiled with the primary objective of understanding the opportunities that exist for innovative uses of these materials as alternatives to conventional materials, the advantages and disadvantages of utilizing CCPs, and to identify barriers to utilization. Opportunities for high-volume and high-value applications receive particular attention.

1.2 Information Sources

1 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

· Ohio Department of Natural Resources – Division of Geological Survey, Division of Mines and Reclamation; · Ohio Department of Transportation; · Ohio Environmental Protection Agency; · The Ohio State University; · Organization for Economic Co-Operation and Development; · Public Utilities Commission of Ohio; · Transportation Research Board; · United States Department of Agriculture; · United States Department of Energy – Federal Energy Technology Center (now National Energy Technology Laboratory), Energy Information Administration, Office of Fossil Energy; · United Stated Department of Interior - Office of Surface Mining; · United States Environmental Protection Agency; and · United States Geological Survey.

2 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

2 STATUS OF CCP INDUSTRY IN OHIO

Current coal consumption for Ohio exceeds 50 million tons annually, with almost half of this coal being mined in the state. Coal-fired electric utilities account for 90% of the coal consumed and supply nearly 90% of the state’s electricity. The combustion of such a large quantity of coal leads to enormous amounts of coal combustion products (CCPs). CCPs include fly ash, bottom ash, boiler slag, and flue gas desulfurization (FGD) material (refer to Table 2-1). CCPs can be utilized, or disposed in landfills and surface impoundments. The annual production of CCPs for the state is nearly 10 million tons. Total annual tonnage of CCPs generated in Ohio equals that of portland cement and ranks behind only crushed stone, sand, and gravel among all non-fuel mineral commodities (refer to Table 2-2). If all CCPs generated annually in Ohio were placed on top a football field, the height of CCP material would be about one mile.

2.1 Regulation of CCPs

Currently, CCPs are exempt from Subtitle C of the Resource Conservation and Recovery Act (RCRA), and are regulated by most states as solid wastes. A recently published final regulatory determination for all CCPs by USEPA (Federal Register of May 22, 2000, Part III, EPA, 40 CFR Part 261) concluded that CCPs do not warrant regulation under Subtitle C of RCRA and that USEPA is retaining the hazardous waste exemption for CCPs under RCRA Section 3001(b)(3)(C). However, EPA determined that voluntary Subtitle D (non-hazardous) national standards need to be developed for CCPs disposed in landfills or surface impoundments, and used in filling surface or underground mines. USEPA also determined that no additional regulations were warranted for CCPs that are used beneficially (other than for minefilling). In the regulatory determination, USEPA supported increases in beneficial uses of CCPs, such as additions to cement and concrete products, waste stabilization, and use in construction products such as wallboard. More detailed background information and updated documents on USEPA’s determination can be obtained from http://www.epa.gov/epaoswer/other/fossil/index.htm.

Ohio regulates fly ash, bottom ash, boiler slag, and FGD as solid wastes through the Ohio Environmental Protection Agency (OEPA). In particular, non-toxic fly ash, bottom ash, and slag are regulated as exempt wastes, i.e., they are exempt from the statutory definition of solid waste. FGD is considered to be an air pollution control waste and is regulated as a residual solid waste. The regulation of FGD as a residual solid waste, as compared to non-toxic fly ash as an exempt waste, has resulted in increased regulatory restrictions on the use of FGD materials. The beneficial use policy of OEPA was replaced with an Interim Alternative Waste Management Program (IAWMP) in 1997, which effectively replaced beneficial use with alternative disposal option. Under IAWMP, two types of alternative disposal options were made available, engineered use and land application. The IAWMP regulatory procedures currently followed by OEPA depend on the type of CCP and its intended use as well as the proposed use of the facility. The beneficial use policy developed in 1994 by the Division of Surface Water is still regarded as a guidance / policy document. The Long Term Alternative Waste Management Program (LTAWMP) was scheduled to be in place by July 1999. While some progress on the issue has been made, the deadline has not been achieved.

3 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

2.2 Advantages and Limitations of Utilization

The advantages of using CCPs instead of the current practice of landfilling are - 1) emphasis on recycling and decrease in the need for expensive landfill space, 2) conservation of natural resources of the state, 3) better products and significant technical benefits, 4) reduction in the cost of energy production for utilities, 5) substantial savings for end-users, 6) continued economic competitiveness of high-sulfur Ohio coal, 7) cleaner and safer environment, 8) reduced social costs, and 9) greater economic development. The potential drawbacks and limitations of CCP utilization are - 1) increased haulage cost and associated disturbance, 2) variability of material, 3) opposition from established raw material marketers, 4) potential for long-term effects, 5) increased design and monitoring costs, 6) bulky nature of FGD, 7) litigation potential, and 8) durability concerns. These technical, environmental, social, and economic issues need to be in balance for the effective use of a CCP for a particular application. Successful CCP uses will be those that are technically safe, environmentally sound, socially beneficial, and commercially competitive, as with any other raw material or product of commerce.

2.3 CCP Production and Utilization

Thirty-three coal-fired facilities in the state were surveyed by the authors. A list of surveyed coal-fired facilities is presented in Table 2-3 and shown in Figure 2-1. The 1997 production and utilization data for CCPs generated at surveyed Ohio plants was compiled on a plant basis and is presented in Table 2-4.

Ohio coal-fired facilities generated approximately 9.23 million short tons (MST) of CCPs in 1997 (on a dry weight basis). This consisted of 4.76 MST of fly ash, 0.97 MST of bottom ash, 0.35 MST of boiler slag, 2.68 MST of FGD (dry weight basis), and 0.47 MST of mixtures of fly ash, bottom ash, boiler slag, and cenospheres. The FGD production in the state is high due to the use of high-sulfur coal by FGD scrubbers complying with Clean Air Act Amendments of 1990. The Gavin plant (GAV) produced 25% of all CCPs and accounted for nearly 60% of FGD generated in the state. The largest generator of fly ash and bottom ash in the state was the J.M. Stuart station (JMS). The Muskingum River plant (MUS) generated 42% of all boiler slag produced in Ohio. Fly ash and bottom ash combined account for nearly 67% of CCP production, while FGD generated in the state was 29% of all CCPs produced in 1997.

The state has five FGD generating facilities. Four of these facilities, Zimmer, Conesville, Gavin, and Niles, employ a wet scrubbing process, while the OSU McCracken power plant generates a spray dryer ash. Table 2-5 lists these plants, amount of FGD generated at each facility, the quantity of coal and lime/limestone used in 1997, and the design sulfur content for the scrubbers. Removal of SO2 from the flue gases at these five plants required approximately 0.73 MST of lime / limestone sorbent. This resulted in the generation of more than 2.6 MST (dry weight) of FGD. The NLS plant generates FGD gypsum, and the ZIM plant that currently produces stabilized FGD is expected to start generating FGD gypsum in year 2000. The moisture content of wet FGD typically ranges from 30% to 60%. Hence, the amount of wet FGD generated in the

4 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

state for 1997 ranged between 3.4 MST and 4.2 MST, with an average annual production rate of approximately 3.8 MST per year.

Of the CCPs generated in Ohio, 21% were utilized. Approximately 23.4% of combined fly ash and bottom ash generated, 74.7% of bottom ash generated, but only 8.4% of FGD generated in the state was utilized. Of the total CCPs utilized, fly and bottom ash accounted for 75% of the use, boiler slag (13.4%), and FGD (11.6%). The various types of end uses for fly ash, bottom ash, boiler slag, and FGD were also investigated and the results are shown in Table 2-6. For fly ash and bottom ash, over 40% of the use was in cement / concrete / grout applications while structural fills accounted for 32.5% of use. About 86% of the boiler slag utilized was for blasting grit and roofing granules. Other boiler slag uses were structural fills, and snow and ice control. For FGD material, major uses included wallboard industry consumption (33.3%), mining and reclamation applications (24%), and miscellaneous uses (42.7%). Miscellaneous uses included FGD feeding and hay storage pads and material used for various research and field demonstration projects.

The production and use of coal combustion products in Ohio were compared with ACAA Region 3 states (Illinois, Indiana, Kentucky, Michigan, Ohio, and Wisconsin), as well as the United States (refer to Table 2-7). ACAA Region 3 states included USPEPA Region 5 states and the state of Kentucky. Ohio generates about 8.8% of CCPs produced in the United States and of the total amount utilized across the nation, the state accounts for 6.6% use. Fly ash and bottom ash, boiler slag, and FGD production is 8%, 12.7%, and 10.6%, respectively, of the US national production. Fly ash and bottom ash, boiler slag, and FGD use in Ohio is 5.9%, 10.1%, and 10.3%, respectively, of the US national use. The Ohio CCP utilization rate of 21.0% is lower than the national utilization rate of 27.8% as well as the ACAA Region 3 utilization rate of 25.6%.

2.4 CCP Producer Economics

The total landfilling cost is generally higher than avoided landfilling cost. The total and avoided landfill costs can be significantly different for utilities with and without captive landfills. CCP producers with existing captive landfills would have made a significant capital investment in their landfills and generally have low landfill operating costs. CCP generators without captive landfills have no capital invested in any landfill and generally pay high landfilling operating costs depending on the distance from the CCP production facility to the landfill and costly tipping fees.

Considering the total landfill cost to be the sum of landfill capital cost and landfill operating cost, it can be observed that for captive landfill CCP producers, the use of any CCP material (instead of landfilling) results in 100% savings of operating costs but only partial savings of the capital cost associated with the new phase of landfill development. On the other hand, utilities without

5 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

captive landfills have zero capital cost investment, but high operational costs. Any material beneficially utilized and not sent to the landfill results in much higher cost savings for CCP generators without captive than those with existing captive landfills.

Current CCP landfilling costs (capital and operating) within the state range from about $3 to $35 per ton for CCP producers with and without captive landfills. CCP producers with captive landfills have low total landfill costs (approximately $3 to $15 per ton). Cost of landfilling FGD material is generally lower than that of fly ash. The landfill operating cost for CCP producers with captive landfills can range from 30% to 90% of total landfilling cost. FGD material, in general, has a higher landfill operating cost as a percentage of total landfill cost compared with fly ash. However, CCP generators without captive landfills generally have much higher total landfilling costs (about $10 to $35 per ton) due to high tipping fees and longer haulage distance.

Table 2-1: Types of Coal Combustion Products (CCPs) and Their Characteristics

Amount typically CCP type Characteristics Texture generated per ton Major constituents of coal burned (lbs.) Non-combustible particulate Powdery, silt- Fly ash matter removed from stack like 160 Si, Al, Fe, Ca gases Material collected in dry- Sand-like Bottom ash bottom boilers, heavier than 40 Si, Al, Fe, Ca fly ash Material collected in wet- Glassy, angular Boiler slag bottom boilers or cyclone particles 100 Si, Al, Fe, Ca units Solid/semi-solid material FGD obtained from flue gas Fine to coarse 350 Ca, S, material scrubbers (dry or wet) Si, Fe, Al*

* Stabilized FGD is a mixture of filter cake (Ca, S), fly ash (Si, Fe, Al), lime, and water. Major constituents of FGD gypsum are Ca and S. (Source: Butalia et al., 1999)

Table 2-2: Annual Production of Selected Non-Fuel Mineral Commodities for Ohio

Type of non-fuel mineral Production (million tons/year)

Crushed stone 69 Sand 29.8 Gravel 28.4 Coal combustion products 10 Cement 10

(Sources: Wolfe, M., 1998; ODNR-Division of Geological Survey; CCP survey by authors)

6 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 2-3: Ohio Coal-Fired Facilities Surveyed

Plant Plant name Type of Owner / operator of County City designation facility facility WHG W.H. Gorusch Station EU AMP Washington Warren Township CAR Cardinal EU AEP, Buckeye Power Jefferson Brilliant MIF Miami Fort EU CIN Hamilton North Bend ZIM W.H. Zimmer EU CIN / AEP / DPL Clermont Moscow WCB Walter C. Beckjord EU CIN Clermont New Richmond CON Conesville EU AEP Coshocton Conesville PIC Picway EU AEP Pickaway Columbus JMS J.M. Stuart EU DPL Adams Aberdeen KIS Killen Station EU DPL Adams Manchester HUT O.H. Hutchings EU DPL Montgomery DOV Dover EU City of Dover Tuscarawas Dover COH Hamilton EU City of Hamilton Butler Hamilton GAV Gen. J.M. Gavin EU AEP Gallia Cheshire MUS Muskingum River EU AEP Morgan Beverly KYG Kyger Creek EU OVEC Gallia Cheshire ORR Orrville EU City of Orrville Wayne Orrville PNS Painesville EU City of Painesville Lake Painesville SML Shelby Municipal Light EU City of Shelby Richland Shelby Plant SMR St. Marys EU City of St. Marys Auglaize St. Marys AST Ashtabula EU FE Ashtabula Ashtabula AVN Avon Lake EU FE Lorain Avon Lake ELK Eastlake EU FE Lake East Lake LKS Lake Shore EU FE Cuyahoga Cleveland NLS Niles EU Orion / FE Trumbull Niles BRG R.E. Burger EU FE Belmont Shadyside SMS W.H. Sammis EU FE Jefferson Stratton BYS Bay Shore EU FE Lucas Oregon CHM Champion Hamilton Mill NUPP Champion International Butler Hamilton OSU McCracken Power Plant NUPP Ohio State University Franklin Columbus OUP Ohio University Physical NUPP Ohio University Athens Athens Plant MCO MCO Steam Plant NUPP Medical College of Ohio Lucas Toledo GPP Goodyear Power Plant NUPP Goodyear Tire & Rubber Summit Akron MDC Mead Corporation NUPP Mead Corporation Ross Chillicothe EU: Electric utility NUPP: Non-Utility Power Producer AEP: American Electric Power AMP: American Municipal Power-Ohio CIN: Cinergy DPL: Dayton Power & Light FE: FirstEnergy OVEC: Ohio Valley Electric Corporation (Sources: Energy Information Administration, 1998; CCP survey by authors)

7 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

AST PNS ASHTABULA BYS ELK WILLIAMS FULTON MCO LUCAS LAKE OTTAWA AVN WOOD GEAUGA HENRY LKS TRUMBULL DEFIANCE SANDUSKY ERIE CUYAHOGA LORAIN PORTAGE HURON SUMMIT SENECA NLS PAULDING MEDINA PUTNAM HANCOCK GPP MAHONING

VAN WERT SML WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN ORR MERCER MARION HOLMES CARROLL AUGLAIZE DOV SMS SMR LOGAN KNOX SHELBY UNION MORROW COSHOCTON HARRISON DARKE DELAWARE CAR CON CHAMPAIGN LICKING MIAMI MUSKINGUM GUERNSEY BELMONT FRANKLIN CLARK OSU BRG PERRY PREBLE NOBLE MONROE HUT FAIRFIELD GREENE MADISON PIC MORGAN PICKAWAY FAYETTE HOCKING MUS WASHINGTON BUTLER WARREN CLINTON WHG COH,CHM ROSS ATHENS VINTON MDC OUP HAMILTON HIGHLAND MIF PIKE MEIGS JACKSON WCB GAV BROWN ADAMS SCIOTO KYG ZIM GALLIA KIS 0 10 20 30 40 miles

0 10 20 30 40 50 kilometers JMS LAWRENCE

Note: Refer to Table 3-3 for plant name abbreviations (Source: CCP survey by authors)

Figure 2-1: Surveyed Coal-Fired Facilities in Ohio

8 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 2-4: CCP Production and Use - 1997

Plant Fly ash & bottom ash Boiler slag FGD Material CCP total Percent designation (1000 ST) (1000ST) (Dry 1000 ST) (1000 ST) Uilization

Production Use Production Use Production Use Production Use WHG 120 0 120 0 0.0% CAR 490 14.7 490 14.7 3.0% MIF 402 288 402 288 71.6% ZIM 368 368 750 not 1118 368 32.9% reported WCB 449 267 449 267 59.5% CON 342 47 34 34 272 150 648 231 35.6% PIC 21 11 21 11 52.4% JMS 876.5 12.8 876.5 12.8 1.5% KIS 200 0 200 0 0.0% HUT 195 0 195 0 0.0% DOV 4.4 1 4.4 1 22.7% COH 14.1 14.1 14.1 14.1 100.0% GAV 781 92 1578 0 2359 92 3.9% MUS 270 0 145 145 415 145 34.9% KYG 98 0 121 33 219 33 15.1% ORR - - - - - PNS 7.9 1.4 7.9 1.4 17.7% SML 6 0 6 0 0.0% SMR 3.3 0 3.3 0 0.0% AST, AVN, 1479 322 48 48 75 75 1602 445 27.8% ELK, LKS, NLS, BRG, SMS, BYS* CHM 11 11 11 11 100.0% OSU - - 5.4 0 5.4 0 0.0% OUP 1.3 1.3 1.3 1.3 100.0% MCO 2.5 0 2.5 0 0.0% GPP 14.8 0 14.8 0 0.0% MDC 49.2 0 49.2 0 0.0% Totals = 6206 1451.3 348 260 2680.4 225 9234.4 1936.3 % Utilization = 23.4% 74.7% 8.4% 21.0%

(Source: CCP survey by authors)

9 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 2-5: FGD Material Production - 1997

Plant FGD material Dry/ Wet Quantity of Design sulfur Lime / designation generated FGD coal content (%) Limestone (Dry 1000ST) received sorbent used (1000 ST) (1000 ST)

ZIM 750 (estimated) Wet 3252 4.5 231 CON 272 Wet 4235 7.9 76.2 GAV 1578 Wet 7061 3.5 400.8 NLS 75 (estimated) Wet 502 3 24.1 OSU 5.4 (FGD+FA+BA) Dry 14 3 1.5 Totals = 2680.4 15064 733.6

Table 2-6: Estimated CCP Utilization by Type of Use – 1997

(Sources: CCP survey by authors; American Coal Ash Association)

Fly ash & bottom Boiler slag FGD Material All CCPs ash Type of Use Quantity Percent Quantity Percent Quantity Percent Quantity Percent (1000 ST) used (1000 ST) used (1000 ST) used (1000 ST) used

Cement/Concrete/ Grout 618.4 42.6% 4.7 1.8% 0.0 0.0% 623.1 32.2% Flowable Fill 19.6 1.4% 0.0 0.0% 0.0 0.0% 19.6 1.0% Structural Fills 471.4 32.5% 18.4 7.1% 0.0 0.0% 489.8 25.3% Road Base/Subbase 73.2 5.0% 0.3 0.1% 0.0 0.0% 73.6 3.8% Mineral Filler 3.0 0.2% 0.0 0.0% 0.0 0.0% 3.0 0.2% Snow and Ice Control 69.4 4.8% 11.8 4.5% 0.0 0.0% 81.1 4.2% Blasting Grit/Roofing Granules 0.0 0.0% 223.2 85.9% 0.0 0.0% 223.2 11.5% Mining Applications 141.6 9.8% 0.0 0.0% 54.0 24.0% 195.6 10.1% Wallboard 0.0 0.0% 0.0 0.0% 75.0 33.3% 75.0 3.9% Waste Stabilization/ Solidification 0.0 0.0% 0.0 0.0% 0.0 0.0% 0.0 0.0% Agriculture 5.5 0.4% 0.0 0.0% 0.0 0.0% 5.5 0.3% Misc./Other 49.3 3.4% 1.5 0.6% 96.0 42.7% 146.8 7.6% Total Use 1451.3 260.0 225.0 1936.3

10 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 2-7: Comparison of CCP Production and Use for Ohio, Regional States, and the United States – 1997

Fly ash & bottom Boiler slag FGD material CCP total Region ash (1000 ST) (1000 ST) (1000 ST) (1000 ST) Production Use Production Use Production Use Production Use

Ohio 6,206 1,451 348 260 2,680 225 9,234 1,936 23.4% 74.7% 8.4% 21.0%

ACAA Region 3* 20,948 6,207 1,494 1,334 10,888 981 33,330 8,522 29.6% 89.3% 9.0% 25.6%

United States 77,169 24,414 2,742 2,579 25,163 2,183 105,074 29,176 31.6% 94.1% 8.7% 27.8%

*: Illinois, Indiana, Kentucky, Michigan, Ohio, and Wisconsin (Region 5 of USEPA and Kentucky)

(Sources: CCP survey by authors; American Coal Ash Association)

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12 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

3 FUTURE OF CCP INDUSTRY

Traditionally, the majority of coal combustion products (CCPs) generated in Ohio have been disposed in landfills or stored in surface impoundments. Identification and promotion of cost- effective programs for the use of these raw materials (particularly FGD and fly ash), instead of storage and disposal, has been one of the important considerations of the energy strategy for Ohio (Ohio Energy Strategy Interagency Task Force, 1994). The recycling of these raw materials is important to help maintain the economic competitiveness of high-sulfur Ohio coal.

3.1 Overview of Existing and Potential Uses

Many coal combustion products are separated from other product streams. If treated and applied correctly, they can have versatile properties that make them suitable raw materials for many applications. The potential uses are divided into: highway, reclamation, agricultural, manufacturing, other civil engineering and miscellaneous uses. Several different types of application technologies for each broad category are identified and are listed in Table 3-1. It can be observed from Table 3-1 that wet and dry FGD have promising applications for many different types of uses. The potential high-volume uses for FGD are in highway construction and maintenance all over the state and related civil engineering applications, reclamation in the eastern one-third of the state, and wallboard manufacture. High-value markets exist for CCP uses in the manufacturing industry. Agricultural uses will generally be low-volume and low-value uses for utilities but are increasing in demand by the agricultural community. Significant environmental benefits from reclamation can result due to reduction in acid mine drainage, offsite sedimentation, and subsidence problems. Economic benefit to utilities will be greater for high-volume and high-value applications compared to low-volume and value products. Economic benefits for end users can be significant and will depend mainly on the cost of competing conventional materials, processing of CCPs (if any needed), haulage distance and its associated costs.

3.2 Highway / Road Applications

The construction of new roads and highways and the maintenance of nearly 113,550 miles of Ohio roads and highways means that highway / road applications of CCPs are potentially the highest volume uses with markets all over the state. The various existing and potential uses of CCPs for highway applications include portland cement and asphalt concrete, embankment and structural fill, stabilized base / sub-base, flowable fill, and subsidence control grout (refer Table 3-2). Cost savings of 25% to 40% are expected for the use of dry FGD in highway embankments. The current use of about 620,000 tons of fly ash for cement/concrete/grout applications is expected to increase provided the ash is not impacted significantly by high Loss on Ignition (LOI) or ammonia. Currently, state CO2 emissions are reduced annually by more than 500,000 tons because the use of fly ash admixtures replaces cement in concrete and grout applications. Increased use of fly ash concrete will result in greater CO2 emission reductions, thus making fly ash concrete an environmentally preferable product. The NOx rules proposed by

13 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

USEPA will result in an increase in LOI and / or chemical content (particularly ammonia) of some fly ashes generated in the state of Ohio. The increased carbon and ammonia content of the ash is expected to result in a detrimental impact on the properties of fly ash and its marketing. A 1998 survey conducted by the American Coal Ash Association reported that out of 20 responding coal-fired generating facilities from Ohio, 19 are expected to be affected by the proposed NOx guidelines. A court stay was recently issued on the proposed NOx rules and a ruling is not expected till the year 2000. However, some sort of NOx control and or other emission control regulations are expected to be implemented by USEPA and OEPA in the next 5 years. Manufactured aggregate from FGD could be used in large volumes for road construction applications.

Potential savings of about $37 million per year based on a moderate 10% cost savings can be realized by Ohio Department of Transportation (ODOT), county, townships and municipalities by using CCPs in the maintenance of highways and roads across the state. The successful implementation of high-volume CCP uses in Ohio will require a significant initiative on the part of ODOT to review and revise its specifications (refer to Table 3-3), particularly for fly ash and bottom ash, and vigorous technology transfer educational efforts aimed at ODOT, county, local township, and municipal project engineers and personnel, and other regulatory agencies.

3.3 Mine Reclamation Uses

Mine reclamation uses can be potentially high-volume applications. These markets will be concentrated in east and southeast Ohio. The potential for FGD and fly ash use in reclamation work exists for abatement of acid mine drainage, sedimentation control, and subsidence control and repairs. Surface reclamation (abandoned and current mined lands) as well as underground placement of CCPs are promising uses. Of the $209 million uncompleted reclamation work documented under the Abandoned Mined Land Inventory System (AMLIS), over $100 million worth of reclamation work has potential for FGD utilization. The counties leading in FGD use potential are shown in Figure 3-1. In a typical year, Ohio Department of Natural Resources – Division of Mines and Reclamation (DMR) funds approximately $2.5 million of reclamation work. The potential FGD tonnage for uncompleted AML reclamation work was evaluated and found to be over 8 million tons (refer to Table 3-4) The major use of FGD for abandoned mine lands is expected to be for reclamation of gob piles and spoil areas. Reclamation of gob piles was shown to result in savings ranging from $8,350 to $12,600 per acre for DMR. The potential economic saving to DMR for reclamation of unreclaimed gob piles across the state using FGD is estimated to be about $8 million. In many cases conventional construction materials like clay and resoil material may not be available and by the process of elimination FGD may be the best or the only suitable material to be used for reclamation. The current lack of utilization of FGD in existing surface mining operations permitted by DMR may be attributed to the sufficient availability of conventional materials and the limited exposure to the potential of FGD utilization. As FGD use in other reclamation applications becomes more common, operators may choose to incorporate FGD into site reclamation. FGD utilization will become more attractive to operators hauling coal to plants from which FGD can be brought to the project sites as haulback. Haulback potential from CCP generating facilities to operating mining operations using trucks as the means of transport exceeds 12 million tons per year across the state. Co-

14 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

mixing of sulfite rich FGD with coal refuse to mitigate acid mine drainage has a potential annual market volume of about 1.5 million tons. Underground placement of FGD and fly ash based grouts to control and avoid subsidence is of interest to DMR and ODOT. About 6,000 abandoned underground mines are found in 38 Ohio counties. Mine subsidence problems related to highway repairs can be expensive (in the range of several million dollars). Due to the potential risk of mine subsidence under highways, ODOT has developed a mine inventory and risk assessment manual (Manual for Abandoned Underground Mine Inventory and Risk Assessment) outlining procedures for site investigation, evaluation, monitoring, prioritizing, remediation, and emergency action. Fly ash and FGD based cement grouts could be used for the cost-effective remediation of emergency collapse projects. In addition, underground mined areas near highways that are prone to subsidence can be pressure grouted as a precautionary measure so as to avoid future potential risk to human life and costly emergency repairs. The volume of grout that could be used on each subsidence project depends on the extent of mine voids that would need to be filled, and in general will be a high volume application involving several thousand tons of grout per project. CCPs can also be potentially used to mitigate acid mine drainage from underground mines.

3.4 Agricultural Applications

Agricultural uses of CCPs are attractive low-cost alternatives, which are generating increased interest and demand by the agricultural community. Agricultural liming uses will be low-volume and value uses that have potential over the entire state, particularly northern Ohio. The potential dry and wet FGD use for the state for agricultural liming application is calculated to be approximately 365,000 and 1,000,000 tons per year, respectively. If subsidies are made available to cover the cost of transportation, then the use of FGD all over the state could be competitive with agricultural lime. Other soil amendment potential uses of FGD, such as sulfur and/or Ca:Mg ratio enhancer, synthetic gypsum, are expected to have similar market potential and constraints as the agricultural lime substitute uses. However, the use of dry FGD as a fertilizer and new soil blends could have better marketing potential due to a much higher value associated with these products.

15 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

3.5 Other Civil Engineering and Miscellaneous Uses

Liners for constructed wetlands hold promise as a cost-effective substitute for geocomposite clay liners (estimated savings of about $34,000 per acre). The low-permeability characteristic of many FGD materials has promise for the use of compacted FGD as a landfill cap, daily cover, and containment liner in place of commonly used clay. For a medium-sized landfill of 100-acre footprint, more than half million tons of FGD could be used for cap construction, and the resultant cost savings at closure are expected to be about $ 5 million (based on 1996-97 cost data).

Some CCPs can be used as feedstocks for the manufacturing industry. Applications with high- value and / or volume will be the most promising. Synthetic gypsum made from oxidation of sulfite-rich filter cake can be used in wallboard manufacture, as a feed for cement manufacturing plants, and as a soil conditioner. The conversion of FGD filter cake into gypsum holds promise for traditional wet scrubber products depending on the economics of oxidation and dewatering the FGD.

Magnesium hydroxide can be economically recovered from magnesium-enhanced lime scrubbing systems and subsequently used for wastewater sludge treatment. Several benefits result from the recovery of magnesium hydroxide. First, the utility is able to recover the magnesium hydroxide reagent from the FGD process and generate income from its sales, and at the same time save some of the costs associated with decreased landfill disposal. The end user, wastewater plants, would have access to a cheaper acid waste neutralization reagent, which could be as effective as commercially available reagents. The societal benefit would be an improved quality of the environment into which the wastewater is discharged as well as the treatment of pollution at its source rather than after it enters the natural environment. The potential markets for the recovered reagent will be cities and towns within a reasonable distance from magnesium- enhanced lime scrubbers.

Fly ash or cenosphere-enhanced plastics, alloys, composites, and ceramics are high-value products and the use of these materials for filler applications is expected to generate more durable and lighter products. Carbon extraction from high-carbon fly ashes may result in two sellable products - high quality carbon for the steel industry, and low-carbon fly ash for use in cement replacement applications.

3.6 Social Costs and Benefits

Social costs and benefits from an economic perspective refer to the aggregation of individual producer and consumer measures of full willingness to accept or pay compensation. Social cost- benefit analysis is concerned with estimating the full willingness to pay and willingness to accept measures of economic value regardless of whether or not those values are currently reflected in market price (Stehouwer, et al., 1995). Social cost associated with landfilling loosely refers to the potential reduction in property values in vicinity of a landfill. Social benefit refers to the potential increase in property values in vicinity of a landfill due to beneficial use instead of landfilling a material.

16 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Social costs associated with FGD landfill disposal are estimated to range between $0.10 and $0.35 per ton. Using reasonable estimates for social costs for various FGD generating facilities, the total welfare loss for Ohio due to landfilling of FGD is estimated to be about $0.8 million annually. Further, assuming that the social benefit per ton from use of other CCPs is similar to that of FGD, the annual economic benefit to society if all CCPs are utilized will exceed $2.5 million. This represents a significant societal benefit that can be realized from the recycling of CCPs as raw materials instead of the existing practice of disposing of them in landfills. In addition, the reclamation of abandoned mine lands using FGD material can result in a few cents per ton of social benefit.

3.7 Effect of Landfilling Costs on Potential FGD Utilization and Disposal

Results of a linear optimization model (Dick et al., 1999a, 1999b) for the three main high volume uses of CCPs, highway applications, reclamation of current surface mine and abandoned mine lands with an adoption rate of 10% were investigated. In the model, landfilling was considered to be the fourth but least desirable option. It was assumed that the highway applications could be used for road construction and repairs in all 88 counties. For reclamation purposes, FGD was considered as a soil amendment in 21 eastern counties and for the landfill option, four existing FGD landfills in vicinity of the Gavin, Conesville, Zimmer, and OSU McCracken power plants were considered. The transportation cost was assumed to be $.10 per ton per mile and was considered to be borne by the utility or FGD supplier. The source destinations were set at the centers of the 88 Ohio counties. The cost of application was assumed to be $3.50 per ton for the highway and reclamation uses. For mine reclamation, an application rate of 250 tons per acre was incorporated into the analysis.

A sensitivity analysis was presented by Dick et al., 1999a to determine the effect of landfilling costs on the quantity of FGD that could be potentially used versus landfilled. The sensitivity analysis results are shown in Figure 3-2. Table 3-5 shows the amount of FGD that would be potentially utilized and landfilled for landfilling costs varying from $5 to $27.50 per ton. It can be observed that a statewide average landfilling cost of $27.50 per ton would result in 64% of the FGD material generated in the state being utilized and only 36% being landfilled. A reduction of landfilling costs from $27.50 per ton to $20 per ton results in relatively little impact on the amount of FGD that would be utilized since landfilling is still a high cost option. As the landfill costs drop below $20 per ton, FGD use for highway or mine reclamation becomes less attractive than landfilling. At $15 per ton landfilling cost, 43% of the FGD generated would be utilized, whereas at $10 per ton, only 29% of FGD material would be utilized. For landfilling cost less than $10 per ton, the utilization rate falls rapidly. At a landfilling cost of $5 per ton, only a small amount (3%) of FGD would potentially be used and the rest (97%) would be landfilled.

17 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

corresponds to utilization of 0.65 MST of FGD or 16% utilization (refer to Figure 3-2). This projected utilization rate is almost double the 1997 utilization rate of 8.4% for FGD material. Results of the linear optimization model showed that there is significant economic incentive for utilities to promote the use of FGD for highway construction and maintenance, and surface mine reclamation. The current statewide FGD utilization rate of 8.4% can be doubled to 16% in the short term if utilities continue to subsidize the transportation costs up to the breakeven point and the end user pays for the processing costs. However for the long term, an FGD utilization rate much greater than 16% is needed. This will necessitate that the processing and transportation costs be borne by the end-user in the long run for successful and productive utilization of FGD materials across the state of Ohio.

3.8 Future Projections and Estimates

The future projections for the quantity and quality of CCPs generated in Ohio will depend on several factors including shifts in coal-based energy production in the state, competitiveness of high-sulfur Ohio coal, and future emission control restrictions. If all the current Ohio plants were to use high-sulfur coal and install FGD scrubbers, the production of FGD material in the state would range between 12 to 16 million tons per year. At the present time, three additional FGD scrubbers are being installed or planned in Ohio. These will be located at City of Hamilton (COH), Ohio University (OUP), and the Medical College of Ohio (MCO). All of these proposed facilities use small amounts of coal and will be using dry scrubbing technology. New coal-fired power plants are not expected to be installed in the state in the next 10-15 years. However, existing coal-fired plants will continue to provide the base load electricity to the state, while peaking electric loads are expected to be generated from natural gas or renewable sources. Compliance with Phase II of the Clean Air Act Amendments by January 2000 by Ohio coal-fired power plants is expected to result from a combination of a) fuel switching / and or blending with lower sulfur coals, b) obtaining additional SO2 allowances, c) installing FGD equipment, d) using previously implemented emission controls, e) retiring units, f) boiler re-powering, g) substituting Phase II units for Phase I units, and h) compensating Phase I units with Phase II units. A review of the current online Phase II compliance methods for Ohio projected by the USEPA shows that fuel switching / and or blending with lower sulfur coals will be the preferred option of choice in the state. Fuel switching and blending from high-sulfur to lower sulfur coals will result in higher amounts of fly ash production. The quality of CCPs generated are expected to be impacted severely by the proposed NOx rules due to an increase in the carbon and ammonia contents in the ash. The public response to the release of Toxic Release Inventory (TRI) information by utilities may have some negative impact on the marketing of CCPs. Identification of barriers to CCP use in the state, finding innovative solutions to reduce and overcome these barriers, as well as their positive implementation will result in an increase in the utilization of CCPs throughout Ohio.

18 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 3-1: Existing and Potential Uses of CCPs in Ohio

Type of coal combustion product Potential Use Fly ash Bottom Boiler FGD material ash slag Wet Dry Highway applications Cement/Concrete/Grout O X X X X Embankment / Structural fill O O X X X* Flowable fill O O X* X* Road base / subbase O O X O X Snow and ice control O O Synthetic aggregate O X* X Wetland liner X* X Reclamation uses Abandoned surface mine reclamation O O X* Reclamation of existing surface mined lands O X* X* Subsidence remediation and control O X X X Underground placement to mitigate AMD X* X* X Wetland and pond liner X* X Treatment of coal refuse O X Agricultural applications Agricultural liming substitute X X* Soil amendment O X X* X* Pond & animal manure holding facility liner X* X Livestock feedlot and hay storage pad O O X* New soil blends O O X Commercial fertilizer X X* Treatment of biosolids O X X O Manufacturing uses Paint O Wallboard O Roofing granules O O Cement industry O X X Steel industry X X X Fillers (plastics, alloys and composites) O X Mineral wool insulation X Ceramic products X X Recovery of metals X X X Other Civil Engineering uses Brick O X Concrete block O X X* X Landfill liner, daily cover, cap O O X Blasting grit O O Pipe bedding O O Water filtration O Drainage media O O Waste stabilization / solidification O X X X Treatment of sewage sludge X* Pond liner X* X* X O: Existing or past use in Ohio other than demonstration projects X: Potential for use in Ohio *: Research and/or demonstration project completed or in progress in Ohio

19 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 3-2: Existing and Potential Uses of CCPs for Highway Applications

CCP Type Application FGD Fly Ash Bottom Ash Boiler Slag Material Portland cement concrete Cementious material X

Asphalt concrete Hot mix aggregate X X Cold mix aggregate X X Seal Coat aggregate X Mineral Filler X

Embankments & Structural Fill X X X

Stabilized Base/Subbase Aggregate X X Cementious material X X

Flowable Fill Cementious material X X

Subsidence Control Grout X X

20 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 3-3: Recommended Changes to ODOT Specifications

CCP Type Application Fly Ash Bottom Ash Boiler Slag FGD Material Portland cement concrete Cementious material X

Asphalt concrete Hot mix aggregate * * Cold mix aggregate * * Seal Coat aggregate * Mineral Filler *

Embankments & Structural Fill * * *

Stabilized Base/Subbase Aggregate * * Cementious material * *

Flowable Fill Cementious material X *

Subsidence Control Grout * *

X: Existing ODOT specifications. Modifications should be investigated. *: ODOT specifications need to be developed.

21 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

ASHTABULA

LAKE WILLIAMS FULTON LUCAS OTTAWA WOOD GEAUGA TRUMBULL HENRY CUYAHOGA DEFIANCE SANDUSKY ERIE LORAIN PORTAGE HURON SUMMIT SENECA PAULDING MEDINA PUTNAM HANCOCK MAHONING

VAN WERT WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN MERCER MARION AUGLAIZE HOLMES CARROLL

LOGAN KNOX SHELBY UNION MORROW COSHOCTON HARRISON DARKE DELAWARE

CHAMPAIGN LICKING MIAMI MUSKINGUM GUERNSEY BELMONT FRANKLIN CLARK PERRY PREBLE NOBLE MONROE FAIRFIELD GREENE MADISON PICKAWAY MORGAN FAYETTE HOCKING WASHINGTON WARREN BUTLER CLINTON ROSS ATHENS VINTON

HAMILTON HIGHLAND PIKE MEIGS JACKSON

GALLIA BROWN ADAMS SCIOTO

0 10 20 30 40 miles

0 10 20 30 40 50 kilometers LAWRENCE

Less than $100,000 $2,000,000 to $5,000,000

$100,000 to $1,000,000 $5,000,000 to $10,000,000

$1,000,000 to $2,000,000 $10,000,000 to $20,000,000

(Source: AMLIS database) Note: FGD cost data has been evaluated by the authors

Figure 3-1: Funded and Unfunded AML Problems in Ohio (1998 dollars) with Potential for FGD Utilization

22 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 3-4: Potential FGD Tonnage for Uncompleted AML Projects

Dangerous Piles & Total for each County Gobs Spoil Area Pits Embankments county

FGD (tons) FGD (tons) FGD (tons) FGD (tons) FGD (tons) Athens 322,000 184,560 0 15,000 521,560 Belmont 493,500 84,000 1,500 2,000 581,000 Carroll 0 16,800 500 5,000 22,300 Columbiana 136,500 4,800 0 0 141,300 Coshocton 136,500 0 0 0 136,500 Gallia 0 726,720 0 0 726,720 Guernsey 14,000 3,600 0 0 17,600 Harrison 154,000 312,000 0 0 466,000 Hocking 164,500 111,360 0 0 275,860 Jackson 190,750 506,640 0 70,000 767,390 Jefferson 206,500 1,680 0 500 208,680 Lawrence 0 89,808 0 0 89,808 Mahoning 0 77,280 0 2,500 79,780 Medina 0 0 0 0 0 Meigs 101,500 834,960 0 0 936,460 Morgan 105,000 0 0 0 105,000 Muskingham 371,000 78,000 12,500 0 461,500 Noble 10,500 664,800 0 0 675,300 Perry 185,500 929,376 0 75,000 1,189,876 Portage 0 0 0 0 0 Stark 0 254,880 0 0 254,880 Summit 0 0 0 0 0 Trumbull 0 0 0 0 0 Tuscarawas 143,500 198,600 0 4,750 346,850 Vinton 56,000 90,720 0 0 146,720 Washington 0 107,760 0 0 107,760 Wayne 0 0 0 0 0 Total 2,791,250 5,278,344 14,500 174,750 8,258,844

Assumed FGD application rates: Gobs: 3500 tons/acre Spoil Area: 240 tons/acre Dangerous piles & embankments: 500 tons/acre Pits: 500 tons/acre

(Source: AMLIS database) Note: FGD data has been evaluated by the authors

23 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

15 ($ / ton) 10 Cost of Landfilling 5

0 0 0.5 1 1.5 2 2.5 FGD Alternative Uses (Million Tons)

15 ($ / ton) 10 Cost of Landfilling 5

0 1.5 2 2.5 3 3.5 4 FGD Landfilled (Million Tons)

(Source: Dick et al., 1999a)

Figure 3-2: Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled

24 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Table 3-5: Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled

Cost of Amount of FGD projected Amount of FGD landfilling to be utilized projected to be landfilled $27.50 2.55 MST (63.8%) 1.45 MST (36.2%) $25 2.55 MST (63.8%) 1.45 MST (36.2%) $20 2.45 MST (61.3%) 1.55 MST (38.7%) $15 1.72 MST (43.0%) 2.28 MST (57.0%) $10 1.17 MST (29.3%) 2.83 MST (70.7%) $5 0.13 MST (3.3%) 3.87 MST (96.7%)

(Source: Dick et al., 1999a)

25 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

26 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

4 RECOMMENDATIONS

Barriers to CCP utilization can be classified into three main categories: a) Institutional Barriers (restrictions on use of CCPs through requirements, standards, specifications, policies, procedures, or attitudes of organizations and agencies involved in CCP use or disposal, and include economic, marketing, environmental and public perception, and technical barriers), b) Regulatory Barriers (federal and state legislation affecting uses of CCPs), and c) Legal Barriers (Contract, patent, liability and some regulatory issues).

The barriers listed above can be eliminated or reduced with the synergistic efforts of CCP stakeholders. Several recommendations were identified to overcome the barriers identified in the report. In developing and refining these recommendations, the following basic criteria were considered: · Recommendations must be environmentally protective; · Recommendations must increase the amount and type of CCP uses in Ohio; · Recommendations should encourage the use of CCPs across the state and not be limited to certain geographical regions or counties; · Recommendations should not involve significant increase in budgetary and personnel resources currently available to state and federal agencies; · Recommendations should account for the diverse nature of CCPs generated in Ohio, particularly fly ash and FGD; and · Recommendations with long-term solutions should be preferred over those resulting in only short-term gains.

Based on the drawbacks and barriers to CCP use identified in the report and the recommendation criteria presented above, the following specific actions are recommended:

Recommendation No. 1: Because FGD material and its leachate generally have lower concentration of trace elements of concern than fly ash, OEPA should consider regulating FGD material as an exempt waste in a fashion similar to non-toxic fly ash instead of the current regulation of FGD as a residual solid waste. Appropriate changes to Ohio Revised Code and Ohio Administrative Code may be necessary.

Recommendation No. 2: OEPA should expedite its current internal review of waste regulations. The agency should develop and implement a Long Term Alternative Waste Management Program, in consultation with a CCP stakeholder external advisory group, which includes recognition of CCPs in established markets as produced co-products rather than wastes.

Recommendation No. 3: ODOT should review its current specifications with regard to fly ash, bottom ash, boiler slag, and FGD, and incorporate the additional uses of CCPs into ODOT specifications.

Recommendation No. 4: CCP generators should develop improved quality assurance / quality control testing methods and implement them at generating facilities so that the quality of CCPs generated is consistent.

27 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

Recommendation No. 5: For long-term effective utilization of CCPs, transportation and processing costs should be borne by the end-user. For the short-term, CCP generators should continue to cover costs associated with FGD transport within a specified delivery area for high volume and / or high value projects or products, up to the break-even point on cost avoidance. Minimum delivery rates (i.e., schedule and volume) should be assured by generators, subject to electric generation, to potential large volume end-users.

Recommendation No. 6: Improved specifications, fact sheets, design manuals, and testing procedures need to be developed and widely distributed by the CCP industry and university researchers in collaboration with standard-setting organizations.

Recommendation No. 7: Ohio research should continue to focus on promising uses of CCPs, particularly FGD and fly ash, with the co-funding from state and federal agencies, utilities, trade organizations, and research universities. Particular areas of research interest should be high-volume highway applications, high-value manufacturing uses, environmentally beneficial reclamation uses, durability issues, effects of new emission restrictions (e.g., NOx control), chemical forms of elements of concern in CCPs and their solubility and mobility in the environment, and long-term effects.

Recommendation No. 8: The CCP pilot extension program at The Ohio State University should work with the central and district offices of OEPA and ODOT, and county, municipal, and township engineering organizations, to provide technical information about CCP utilization. Further, the CCP pilot program should review as well as address the concerns of personnel at these agencies.

Recommendation No. 9: Continuance of the CCP pilot extension program currently in place at The Ohio State University should be explored in collaboration with the university, state agencies, utilities, and trade organizations.

Recommendation No. 10: Efforts to educate regulators, engineering consultants, potential end users, and the general public should continue. The educational efforts should focus on neutralizing the association of “waste” with CCPs, and should emphasize the environmental safety (non-toxicity) of CCPs, their potential uses, benefits and drawbacks. The public in particular should be made aware of the environmental costs of landfilling, and the environmental and social benefits resulting from reclamation and other efforts using CCPs.

28 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

5 CONCLUSIONS

Coal combustion products (CCPs) will continue to be generated in the state of Ohio. The current practice of disposing about 80% of these materials in landfills and surface impoundments can be avoided with significant social benefits. Many of these CCPs, if treated and applied properly, can be low-cost substitutes for conventional materials in highway and related civil engineering applications, reclamation uses, manufacturing industry, and agricultural applications.

The potential high-volume uses for FGD are in highway construction and maintenance all over the state and related civil engineering applications, reclamation in the eastern one-third of the state, and wallboard manufacture. High-value markets exist for CCP uses in the manufacturing industry. Agricultural uses will generally be low-volume and low-value uses for generators but will be attractive to the agricultural community (as evidenced by the increased interest and demand in the past several years). Significant environmental benefits from mine reclamation work can result due to reduction in acid mine drainage and sedimentation problems. The key to the success of CCP utilization in the state will be to maintain and expand the volume of current CCP use application technologies and to develop high-volume and / or high-value new innovative uses for FGD and fly ash.

The potential large-volume utilization of CCPs as raw material substitutes for conventional natural materials have significant technical benefits, economic advantages for utilities and end users, and environmental as well as social benefits. Several drawbacks and barriers to CCP utilization exist in the state. The barriers to CCP use in Ohio are regulatory, legal, and institutional (economics, marketing, environmental and perception related, and technical).

Ten recommendations have been made for the removal / reduction of barriers to CCP utilization. These barriers can be removed with the synergy and focused attention of government agencies, the utility industry, trade organizations, university research and technology transfer, and market development programs. The successful reduction and removal of these barriers along with a strong technology transfer and market development program will be critical to the future potential high-volume uses of CCPs, particularly FGD and fly ash in the state of Ohio. Success will allow Ohio coal to remain competitive with other coal sources, and keep the cost of energy production in the state low while protecting human health and the environment. The long-term successful utilization of CCPs will be possible for application technologies that are technically safe, environmentally sound, socially beneficial, and commercially competitive.

29 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

6 REFERENCES

Butalia, T., Wolfe, W., Dick, W., Limes, D., Stowell, R., 1999, Coal Combustion Products, The Ohio State Extension Fact Sheet, AEX-330-99, The Ohio State University, Columbus, Ohio. Dick, W., J. Bigham, L. Forster, F. Hitzhusen, R. Lal, R. Stehouwer, S. Traina and W. Wolfe, R. Haefner, G. Rowe, 1999a, Land Application Uses of Dry FGD By-Product: Phase 3 Report, Electric Power Research Institute, EPRI TR-112916, 1999. Dick, W., J. Bigham, L. Forster, F. Hitzhusen, R. Lal, R. Stehouwer, S. Traina, W. Wolfe, R. Haefner, and G. Rowe, 1999b, Land Application Uses of Dry Flue Gas Desulfurization By-Products: Executive Summary, The Ohio State University, 1999. Energy Information Administration, 1998, Cost and Quality of Fuels for Electric Utility Plants – 1997 Tables, Energy Information Administration, DOE/EIA-XXXX(XX), UC-950, May, 1998. Ohio Energy Strategy Interagency Task Force, 1994, The Ohio Energy Strategy Report, State of Ohio, Columbus, Ohio. Stehouwer, R., Dick, W., Bigham, J., Forster, L., Hitzhusen, F., McCoy, E., Traina, S. and Wolfe, W.E., Haefner, R., 1995, Land Application Uses for Dry FGD By-Products: Phase 1 Report, Electric Power Research Institute, EPRI TR-105264. Stehouwer, R., Dick, W., Bigham, J., Forster, L., Hitzhusen, F., McCoy, E., Traina, S., and Wolfe, W.E., Haefner, R., Rowe, G., 1998, Land Application Uses for Dry FGD By- Products: Phase 2 Report, Electric Power Research Institute, EPRI TR-109652. Wolfe, M., 1998, 1997 Report on Ohio Mineral Industries, Ohio Department of Natural Resources – Division of Geological Survey, Columbus, Ohio.

30 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

7 LIST OF ACRONYMS AND ABBREVIATIONS

AASHTO American Association of State Highway and Transportation Officials ACAA American Coal Ash Association ACI America Concrete Institute AEP American Electric Power Al aluminum AMC ash modifying components AMD acid mine drainage AML abandoned mine land AMLIS Abandoned Mine Land Inventory System AMP American Municipal Power-Ohio ASME American Society of Mechanical Engineers AST Ashtabula plant ASTM American Society for Testing and Materials AVN Avon Lake plant BA bottom ash BRG Burger plant BS boiler slag Btu British Thermal Units BYS Bay Shore plant C&DD construction and demolition debris facility Ca calcium CAR Cardinal plant CCE calcium carbonate equivalency CCP coal combustion product CDF controlled density fill CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CHM Champion Hamilton Mill plant CIN Cinergy CLSM controlled low strength material CO2 carbon dioxide COH City of Hamilton plant CON Conesville plant CPG Comprehensive Procurement Guideline CRF capital recovery factor CY cubic yards DMR Division of Mines and Reclamation DO District Office DOE Department of Energy DOV Dover plant DPL Dayton Power and Light DSIWM Division of Solid and Infectious Waste Management DSW Division of Surface Water EIA Energy Information Administration ELK East Lake plant EPA Environmental Protection Agency EPRI Electric Power Research Institute EU electric utility FA fly ash FBC fluidized bed combustion Fe iron FE FirstEnergy FGD flue gas desulfurization material

31 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

FHWA Federal Highway Administration GAV Gavin plant GIS geographical information system GPP Goodyear power plant HUT Hutchinson plant I interstate highway IAWMP Interim Alternative Waste Management Program IM industrial mine IR interstate highway JMS J.M. Stuart plant KIS Killen Station kPa kilo pascals kST kilo short tons KY Kentucky KYG Kyger Creek plant LFA lime-fly ash-aggregate LIMB lime injection multistage burner LKS Lake Shore plant LOI loss on ignition LTAWMP Long Term Alternative Waste Management Program MCO Medical College of Ohio plant MDC Mead Corporation plant Mg magnesium MIF Miami Fort plant MPa mega pascals MST million short tons MUS Muskingum River plant NLS Niles plant NORM naturally occurring radioactive material NOx nitrogen oxides NRCS Natural Resources Conservation Service NUPP non-utility power producer OAC Ohio Administrative Code OARDC Ohio Agricultural Research and Development Center OCDO Ohio Coal Development Office ODNR Ohio Department of Natural Resources ODOD Ohio Department of Development ODOT Ohio Department of Transportation OEPA Ohio Environmental Protection Agency OMEx Ohio’s Materials Exchange ORC Ohio Revised Code ORR Orrville plant OSM Office of Surface Mining OSU Ohio State University OUP Ohio University plant OVEC Ohio Valley Electric Corporation PFBC pressurized fluidized bed combustion PIC Picway plant PNS Painesville plant psi pounds per square inch PSM pozzolanic stabilized mixture PTI Permit to Install RCRA Resource Conservation and Recovery Act S sulfur Si silica SO2 sulfur dioxide

32 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 1 May 2000.

SML Shelby Municipal Light plant SMR St. Marys plant SMS Sammis plant SR state route ST short tons SY square yards TCLP toxicity characteristic leaching procedure TRI Toxic Release Inventory US United States USC United Stated Congress USDA United States Department of Agriculture USDOE United States Department of Energy USEPA United Stated Environmental Protection Agency USGS United States Geological Survey WCB W.C. Beckjord plant WHG W.H. Gorusch plant ZIM Zimmer plant

MARKET OPPORTUNITIES FOR UTILIZATION OF OHIO FLUE GAS DESULFURIZATION (FGD) AND OTHER COAL COMBUSTION PRODUCTS (CCPs)

Volume 2 – Findings, Recommendations, and Conclusions

Tarunjit S. Butalia, Ph.D., P.E. William E. Wolfe, Ph.D., P.E.

Originally Issued: May, 2000

Department of Civil and Environmental Engineering and Geodetic Science The Ohio State University Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Complete electronic versions of Volumes 1 and 2 of this report may be downloaded from the following internet web sites:

http://ccpohio.eng.ohio-state.edu/ccpohio/ http://www.odod.state.oh.us/tech/coal/

ii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ABSTRACT

Ohio generates approximately 10 million tons of Coal Combustion Products (CCPs) annually, and utilizes about 20% of them in various application technologies. The remaining 80% are typically disposed in landfills or surface impoundments. Ohio generates a significant amount of wet FGD material (3.8 million tons) annually to comply with the Clean Air Act Amendments of 1990, which restricted SO2 emissions from many coal-fired facilities that used high-sulfur coal. Many of these CCPs, if treated and applied properly, can be low-cost substitutes for conventional raw materials in highway and related civil engineering applications, reclamation uses, manufacturing industry, and agricultural applications. The market study presented in this report focuses on CCPs generated in the state of Ohio and their existing and future utilization potential. Potential high volume uses for FGD materials exist in highway and related civil engineering applications throughout the state, reclamation in the eastern third of the state, and wallboard manufacture. High value markets exist for CCP uses in the manufacturing industry. Agricultural uses generally will be low volume and low value uses for the CCP provider. However, they are attractive low cost alternatives that are generating increased interest and demand by the agricultural community. Significant environmental benefits from mine reclamation work can result due to reduction in acid mine drainage and sedimentation problems. The key to the success of CCP utilization will be to maintain and expand the volume of current CCP use application technologies and to develop high volume, high value new innovative uses for FGD and fly ash. The potential large volume utilization of CCPs as raw material substitutes for conventional materials have significant technical benefits, economic advantages for utilities and end users, and environmental as well as social benefits. However, several drawbacks, limitations, and barriers to CCP utilization do exist in the state. The barriers to CCP use in Ohio are regulatory (federal and state), legal, and institutional (economics, marketing, environmental and perception related, and technical). Ten recommendations have been made for the removal / reduction of barriers to CCP utilization. These barriers can be overcome with the synergy and focused attention of government agencies, utility industry, trade organizations, and university research and technology transfer and market development programs. The removal of these barriers and a strong market development program are critical to the future high volume uses of CCPs, particularly FGD and fly ash in the state of Ohio. The long-term successful utilization of CCPs that are technically safe, environmentally sound, socially beneficial, and commercially competitive will allow Ohio coal to remain competitive with other coal sources, and keep the cost of energy production low while protecting human health and the environment.

iii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ACKNOWLEDGEMENTS

The authors express their appreciation to all the respondents of the Ohio CCP survey. The data provided by them on the production and use of CCPs in the state has been invaluable and is included in this study. The help and guidance provided by the national American Coal Ash Association in compiling and providing CCP data relevant to Ohio is valued. Ms. Debra Pflughoeft-Hassett of University of North Dakota provided the authors with several topical reports on barriers to CCP use. These reports were helpful in identifying many of the barriers to CCP utilization. The assistance of Ms. Michelle Tinnel of the Ohio Department of Natural Resources- Division of Mines and Reclamation is appreciated. The resources of The Ohio State University Library, particularly the interlibrary loan division, and the Ohio Department of Transportation Library were helpful in the compilation of this report. The authors express their thanks to the staff of these libraries for their assistance. The input provided by the reviewers of the report contributed significantly towards an enhancement of the technical and economic issues associated with CCP utilization that are presented in this final report. The comments received from the reviewers are appreciated.

iv Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

TABLE OF CONTENTS

Page

ABSTRACT iii

ACKNOWLEDGEMENTS iv

LIST OF FIGURES ix

LIST OF TABLES x

LIST OF ACRONYMS AND ABBREVIATIONS xi

1 INTRODUCTION 1 1.1 Background and Objectives 1 1.2 Outline of Report 1 1.3 Information Sources 2

2 STATUS OF CCP INDUSTRY IN OHIO 3 2.1 Types of CCPs 3 2.2 Regulation of CCPs 5 2.2.1 Federal Regulation 5 2.2.2 State of Ohio Regulation 6 2.2.2.1 Beneficial Use Policy 7 2.2.2.2 Interim Alternative Waste Management Program 8 2.3 Existing and Potential Uses of CCPs 12 2.4 Benefits and Drawbacks of CCP Utilization 14 2.4.1 Benefits of CCP Use 14 2.4.2 Drawbacks and Limitations of CCP Usage 16 2.4.3 The Art of Balancing Issues 18

3 COAL PRODUCTION AND USE 21 3.1 Coal Production 21 3.2 Coal Consumption 21 3.3 Effect of Coal Use on Electric Industry Emissions 23 3.4 Coal-Fired Facilities 23

4 PRODUCTION AND UTILIZATION OF CCPs 29 4.1 Introduction 29 4.2 CCP Production 29 4.3 CCP Utilization 34 4.4 Comparison with National and Regional Data 35

v Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

5 HIGHWAY/ROAD APPLICATIONS 45 5.1 Introduction 45 5.2 Embankment / Structural Fill 45 5.2.1 Life Cycle Assessment Analysis 48 5.3 Flowable Fill 48 5.4 Stabilized Base / Sub-base 49 5.5 Use of Fly Ash in Concrete 51 5.5.1 Effect of NOx Emissions on Fly Ash Use 51 5.6 Manufactured FGD Aggregate 52 5.7 Distribution and Maintenance of Highways in Ohio 53 5.8 Existing Consumption of Natural Resources 56 5.9 Ohio Department of Transportation Specifications 58 5.9.1 Introduction 58 5.9.2 Fly Ash Use in Portland Cement Concrete 58 5.9.3 Fly Ash Use in Low Strength Mortar Backfill 58 5.9.4 Modifications to ODOT Specifications 58

6 MINE RECLAMATION USES 61 6.1 Introduction 61 6.2 Abandoned Mined Land Program Statistics and FGD Use Potential 61 6.3 DMR Related Reclamation Projects 62 6.3.1 Fleming Abandoned Mined Land Site 62 6.3.2 Broken Aro Project 68 6.3.3 Roberts-Dawson Underground Injection Project 68 6.3.4 Rehoboth Phase 1 Reclamation Project 69 6.3.5 Rock Run Reclamation Project 70 6.4 FGD Utilization Cost Benefits for AML Programs 71 6.4.1 Introduction 71 6.4.2 Rehoboth Phase 1 Reclamation Project 71 6.4.3 Rock Run Reclamation Project 72 6.4.4 Potential Savings for Gob Pile Reclamation 72 6.5 Current Mining Uses 74 6.5.1 Division of Mines and Reclamation – Regulatory Program 74 6.5.2 Haulback of FGD Material to Coal Mines 75 6.5.3 Treatment of Coal Refuse With Sulfite-Rich FGD Material 77 6.6 Underground Placement 78 6.6.1 Subsidence Remediation 78 6.6.2 Acid Mine Drainage Mitigation 79 6.6.3 Existing Subsurface Mining Uses 79 6.7 Social Benefits of FGD Reclamation 81

7 AGRICULTURAL APPLICATIONS 83 7.1 Introduction 83 7.2 Livestock Feeding and Hay Storage Pads 83 7.3 Agricultural Liming Substitute and Soil Amendment 86 7.4 Liners for Ponds and Manure Storage Facilities 90

vi Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

8 OTHER CIVIL ENGINEERING AND MISCELLANEOUS USES 91 8.1 Liner for Constructed Wetlands 91 8.2 Landfill Liner and Cap 92 8.3 Wallboard Manufacture 93 8.4 Recovery of Magnesium Hydroxide for Wastewater Treatment 94 8.5 Alloys, Composites, and Ceramics 94 8.6 Carbon Extraction 95 8.7 Cement Clinker 95

9 ECONOMIC ANALYSIS 97 9.1 Cost Issues 97 9.1.1 Material Cost 97 9.1.2 Construction / Installation Cost 99 9.1.3 Life-Cycle Cost 99 9.1.4 Total and Avoided Landfilling Cost 100 9.2 Economic Analysis 101 9.2.1 Social Costs and Benefits 101 9.2.2 Linear Optimization Modeling 102

10 BARRIERS TO CCP UTILIZATION 107 10.1 Background Information 107 10.2 Review of National Barriers Currently Identified 107 10.3 Barriers to CCP Use in Ohio 109 10.3.1 Regulatory Barriers 109 10.3.1.1 Federal Regulatory Barriers 109 10.3.1.2 State of Ohio Regulatory Barriers 110 10.3.2 Legal Barriers 111 10.3.3 Institutional Barriers 112 10.3.3.1 Economic Barriers 112 10.3.3.2 Marketing Barriers 113 10.3.3.3 Environmental and Public Perception Barriers 114 10.3.3.4 Technical Barriers 115 10.4 Recommendations for Removal of Barriers 116

11 SUMMARY AND CONCLUSIONS 119 11.1 Status of CCP Industry 119 11.2 Future of CCP Industry 121 11.3 Conclusions 126

12 REFERENCES 127

13 APPENDICES 133 Appendix A. USEPA Environmental Fact Sheet (EPA530-F-93-014) 134 Appendix B. Beneficial Use of Nontoxic Bottom Ash, Fly Ash, and Spent Foundry Sand, and Other Exempt Waste

vii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

(DSW 0400.007) 137 Appendix C. Historical Review of CCP Research in Ohio 151 Appendix D. ODOT Embankment Draft Specification 164 Appendix E. AMLIS Database Search Results 170 Appendix F. Standard Test Procedures, Specifications, and Guidelines 175 Appendix G. Comparison with Regional States 179 Appendix H. USDOE’s 1994 Report to Congress – Executive Summary 191 Appendix I. OSU Extension Fact Sheet AEX-332-99 198 Appendix J. List of Local and Material Specific Exchange Programs in Ohio 209 Appendix K. Report Review Process 211 Appendix L. USEPA Press Release dated April 25, 2000 217

viii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

LIST OF FIGURES

Page Figure 2-1 Potential for CCP Utilization 19 Figure 3-1 Coal Production - 1997 22 Figure 3-2 Coal-Fired Power Plants in Ohio 26 Figure 4-1 CCP Production for Ohio Plants - 1997 31 Figure 4-2 CCP Production – 1997 32 Figure 4-3 FGD Material Production (Dry Weight Basis) - 1997 33 Figure 4-4 CCP Percent Utilization by Plant – 1997 38 Figure 4-5 CCP Production and Use – 1997 39 Figure 4-6 CCP Use – 1997 39 Figure 4-7 Fly Ash and Bottom Ash Used vs. Disposed – 1997 40 Figure 4-8 Boiler Slag Used vs. Disposed – 1997 40 Figure 4-9 FGD Material Used vs. Disposed – 1997 41 Figure 4-10 All CCPs Used vs. Disposed – 1997 41 Figure 4-11 Fly Ash and Bottom Ash Applications – 1997 42 Figure 4-12 Boiler Slag Applications – 1997 43 Figure 4-13 FGD Material Applications – 1997 43 Figure 4-14 All CCP Applications – 1997 44 Figure 5-1 Cost Estimates for SR 541 Repairs Using PFBC Material 47 Figure 6-1 Funded and Unfunded AML Problems in Ohio (1998 dollars) 64 Figure 6-2 Funded and Unfunded AML Problems in Ohio (1998 dollars) with Potential for FGD Utilization 65 Figure 6-3 Location of Coal Mines and Preparation Plants 76 Figure 6-4 Counties with Abandoned Underground Mines 80 Figure 7-1 Counties with Leading Cattle Inventory 85 Figure 9-1 Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled 105 Figure C-1 Ohio CCP Projects 152

ix Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

LIST OF TABLES

Page Table 2-1 Types of Coal Combustion Products (CCPs) and Their Characteristics 4 Table 2-2 Annual Production of Selected Non-Fuel Mineral Commodities for Ohio 4 Table 2-3 IAWMP Regulatory Guidelines for Engineered Use of CCPs 10 Table 2-4 IAWMP Regulatory Guidelines for Land Application of CCPs 11 Table 2-5 Existing and Potential Uses of CCPs in Ohio 13 Table 3-1 Coal Received at Ohio Electric Utilities (1993-1997) 23 Table 3-2 Estimated Electric Power Industry Emissions for Ohio 23 Table 3-3 Ohio Coal-Fired Facilities Surveyed 25 Table 3-4 Quantity and Quality of Coal Received at Ohio Plants – 1997 27 Table 3-5 Coal Source and Quality for Ohio Plants – 1997 28 Table 4-1 CCP Production – 1997 30 Table 4-2 FGD Material Production – 1997 32 Table 4-3 CCP Utilization – 1997 36 Table 4-4 CCP Production and Use – 1997 37 Table 4-5 Estimated CCP Utilization by Type of Use – 1997 42 Table 4-6 Comparison of CCP Production and Use for Ohio, Regional States, and the United States – 1997 44 Table 5-1 Existing and Potential Uses of CCPs for Highway Applications 47 Table 5-2 Cost Comparison for Pavements with Different Types of Road Bases in Ohio, 1979 50 Table 5-3 Highway and Road Miles in Ohio Counties 54 Table 5-3 Highway and Road Miles in Ohio Counties (continued) 55 Table 5-4 Estimated Cost of Maintenance Per Mile of Road, 1994 56 Table 5-5 Consumption of Mined Natural Resources by Highway Construction and Other Construction Related Activities 57 Table 5-6 Recommended Changes to ODOT Specifications 60 Table 6-1 Cost Data for Ohio AML Projects Reported in AMLIS (1998 dollars) 63 Table 6-2 Potential FGD Use Areas for Uncompleted AML Reclamation Projects 66 Table 6-3 Potential FGD Tonnage for Uncompleted AML Projects 67 Table 6-4 Cost Analysis for Rehoboth Phase 1 Project 73 Table 6-5 Cost Analysis for Rock Run Reclamation Project 74 Table 6-6 DMR Approved Mine Permits with CCP Applications 75 Table 6-7 Ohio County Data for Coal Trucking 77 Table 6-8 Acid Mine Drainage Underground Mine Acreage 81 Table 7-1 Cost Summary for FGD Pads Constructed in Gallia County 84 Table 7-2 Annual Sale of Agricultural Lime, by County (Averaged from 1986-1991) 88 Table 7-3 Potential Annual Sale of Dry FGD as Agricultural Lime Substitute, by County 89 Table 8-1 Comparison of Liner Cost for 16-Acre Constructed Wetland in Licking County, Ohio 92 Table 8-2 Clay Production and Landfill Use, 1996-1997 92 Table 9-1 Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled 106

x Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

LIST OF ACRONYMS AND ABBREVIATIONS

xi Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

EIA Energy Information Administration ELK East Lake plant EPA Environmental Protection Agency EPRI Electric Power Research Institute EU electric utility FA fly ash FBC fluidized bed combustion Fe iron FE FirstEnergy FGD flue gas desulfurization material FHWA Federal Highway Administration GAV Gavin plant GIS geographical information system GPP Goodyear power plant HUT Hutchinson plant I interstate highway IAWMP Interim Alternative Waste Management Program IM industrial mine IR interstate highway JMS J.M. Stuart plant KIS Killen Station kPa kilo pascals kST kilo short tons KY Kentucky KYG Kyger Creek plant LFA lime-fly ash-aggregate LIMB lime injection multistage burner LKS Lake Shore plant LOI loss on ignition LTAWMP Long Term Alternative Waste Management Program MCO Medical College of Ohio plant MDC Mead Corporation plant Mg magnesium MIF Miami Fort plant MPa mega pascals MST million short tons MUS Muskingum River plant NLS Niles plant NORM naturally occurring radioactive material NOx nitrogen oxides NRCS Natural Resources Conservation Service NUPP non-utility power producer OAC Ohio Administrative Code OARDC Ohio Agricultural Research and Development Center OCDO Ohio Coal Development Office ODNR Ohio Department of Natural Resources

xii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ODOD Ohio Department of Development ODOT Ohio Department of Transportation OEPA Ohio Environmental Protection Agency OMEx Ohio’s Materials Exchange ORC Ohio Revised Code ORR Orrville plant OSM Office of Surface Mining OSU Ohio State University OUP Ohio University plant OVEC Ohio Valley Electric Corporation PFBC pressurized fluidized bed combustion PIC Picway plant PNS Painesville plant psi pounds per square inch PSM pozzolanic stabilized mixture PTI Permit to Install RCRA Resource Conservation and Recovery Act S sulfur Si silica SO2 sulfur dioxide SML Shelby Municipal Light plant SMR St. Marys plant SMS Sammis plant SR state route ST short tons SY square yards TCLP toxicity characteristic leaching procedure TRI Toxic Release Inventory US United States USC United Stated Congress USDA United States Department of Agriculture USDOE United States Department of Energy USEPA United Stated Environmental Protection Agency USGS United States Geological Survey WCB W.C. Beckjord plant WHG W.H. Gorusch plant ZIM Zimmer plant

xiii Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

xiv Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

1 INTRODUCTION

1.1 Background and Objectives

Nearly 90% of the electricity produced in Ohio is generated from the combustion of coal, and coal-fired electric utilities account for 90% of the coal consumed annually in the state. Current coal consumption for the state exceeds 50 million tons annually. The combustion of coal leads to enormous quantities (approximately 10 million tons annually) of solid by-products, referred to as Coal Combustion Products (CCPs). CCPs can be recycled, stored or disposed in landfills and surface impoundments. Developing economic and environmentally sound alternatives to expensive and non-productive landfilling of coal combustion products (CCPs) is of vital importance to the state of Ohio. The identification of these materials as acceptable alternatives to existing natural raw materials can result in 1) a decrease in the need for landfill space, 2) conservation of the natural resources of the state, 3) better products, 4) cleaner and safer environment, 5) reduction in the cost of producing electricity, 6) substantial savings for end- users of CCPs, 7) reduced social costs associated with landfilling, and 8) greater economic development.

This report has been prepared as a part of the Coal Combustion Products Pilot Extension Program established at The Ohio State University in January of 1998. The extension program promotes the responsible uses of coal combustion products, including fly ash, bottom ash, boiler slag, and flue gas desulfurization (FGD) material. The study presented in this report focuses on the existing and potential uses of all CCPs, particularly FGD and fly ash, generated in the state of Ohio. It was compiled with the primary objective of understanding the opportunities that exist for innovative uses of these materials as alternatives to conventional materials, the advantages and disadvantages of utilizing CCPs, and to identify barriers to utilization. Opportunities for high-volume and high-value applications receive particular attention.

1.2 Outline of Report

The report has been divided in two volumes. Volume 1 is the executive summary, and Volume 2 includes findings, recommendations, conclusions, and appendices. This section elaborates on the arrangement of Volume 2 of the report and highlights its contents. Chapter 1 summarizes the objectives of the market study and identifies information sources used by the authors to prepare the report. Chapter 2 reviews the status of the CCP industry in the state of Ohio. It includes a discussion on the types of CCPs generated in the state, their regulation at the federal and state level, existing and potential uses, and benefits as well as limitations of utilization technologies. In Chapter 3, a review of coal production and use in the state is presented for a better understanding of the materials obtained from its combustion. The production and utilization estimates of fly ash, bottom ash, boiler slag and FGD in the state were obtained through a survey of Ohio coal-fired power plants. The results of the survey are presented in Chapter 4. The potential highway, mine reclamation, agricultural, manufacturing, other civil engineering, and miscellaneous use applications and their market volumes and geographic distribution are

1 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

presented in Chapter 5 through 8. Chapter 9 presents a discussion of economics of use - the principal technology driving factor. Various types of barriers to CCP utilization across the nation and the state of Ohio are discussed in Chapter 10. Recommendations are made to reduce or eliminate these barriers so as to promote CCP use. Chapter 11 summarizes the current status and future outlook for the Ohio CCP industry and presents the conclusions of this study. Over eighty references cited in the report are listed in Chapter 12 and twelve appendices are attached in Chapter 13.

1.3 Information Sources

The compilation of this report involved reviewing information from a wide range of print and online publications. The primary information sources used by the authors in finalizing this report were: · American Coal Ash Association; · American Concrete Institute; · American Electric Power; · Cinergy; · County Engineers Association of Ohio; · Dayton Power and Light; · Dravo Lime Company (now Carmeuse NA) · Electric Power Research Institute; · Federal Highway Administration; · FirstEnergy; · Ohio Department of Agriculture; · Ohio Department of Development – Coal Development Office, Office of Strategic Research; · Ohio Department of Natural Resources – Division of Geological Survey, Division of Mines and Reclamation; · Ohio Department of Transportation; · Ohio Environmental Protection Agency; · The Ohio State University; · Organization for Economic Co-Operation and Development; · Public Utilities Commission of Ohio; · Transportation Research Board; · United States Department of Agriculture; · United States Department of Energy – Federal Energy Technology Center (now National Energy Technology Laboratory), Energy Information Administration, Office of Fossil Energy; · United Stated Department of Interior - Office of Surface Mining; · United States Environmental Protection Agency; and · United States Geological Survey.

2 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

2 STATUS OF CCP INDUSTRY IN OHIO

2.1 Types of CCPs

The different types of CCPs generated from the combustion of coal and their characteristics, texture, production rate, and major constituents are shown in Table 2-1. Fly ash is the non- combustible particulate matter that is removed from the stack gases. Fly ash is a pozzolanic material, i.e. in the presence of lime and water it forms calcium silicate cementious compounds. The two types of fly ashes generated in Ohio are Class F and Class C fly ash. Class F ash is generated in large quantities in the state. Class F fly ash typically has a calcium oxide content less than 10% and almost no free lime, while Class C ash has a calcium oxide content greater than 20%, contains 1-3% free lime, and is self-cementing in the presence of water. Class C ash is generally obtained by combustion of western sub-bituminous and lignite coals, while Class F fly ash is generated from eastern bituminous and anthracite coals. Since virtually all coal mined in Ohio is bituminous, the plants that use Ohio coal generate Class F fly ash (about 160 pounds of ash per ton of coal). Bottom ash refers to the heavier ash particles collected at the bottom of dry- bottom boilers. Typically, about 40 pounds of bottom ash is generated per ton of coal from dry- bottom pulverized coal boilers. The glassy angular ash particles collected at the bottom of wet- bottom boilers or cyclone units are referred to as boiler slag. Large amounts of Flue Gas Desulfurization (FGD) material or scrubber sludge are generated during the removal of sulfur dioxide from flue gases. FGD may be dry or wet depending on the desulfurization process. The wet scrubbing process, which is commonly used by large electric utilities in Ohio, involves the injection of a reagent (typically hydrated quicklime, limestone, or dolomite) into the flue gases. The wet filter cake generated is a mixture of sulfites and sulfates of the reagent, unreacted reagent, and water. Calcium sulfite content is typically greater than 70% while the calcium sulfate content is approximately 13%, unless the filter cake is oxidized. Fly ash and additional quicklime can be added to stabilize the FGD filter cake. The amount of fly ash and lime to be added to the FGD filter cake depends on the particular use for which the FGD material is intended to be used. Increasing the fly ash and lime content results in increased strength and durability of the stabilized FGD. Typically, stabilized FGD is gray in color and looks like silty clay. Alternatively, the filter cake can be oxidizing to calcium sulfate and dewatered, resulting in FGD gypsum. FGD gypsum can be about 98% calcium sulfate dehydrate and is as good or better than natural gypsum. At present, dry FGD processes are more commonly used in smaller electric generating facilities. The type of FGD material generated at a coal-fired scrubber depends on several factors including, the type of coal and boiler, reagent used for desulfurization, and the FGD process. Ohio utilities generate approximately 3.8 million wet tons (2.7 million dry tons) of FGD annually which is nearly 15% of all FGD material generated across the nation.

The annual production of CCPs in Ohio is approximately 10 million tons. For comparison, Table 2-2 shows the annual production of several non-fuel mineral commodities for Ohio. It can be seen that the total annual tonnage of CCPs generated in the state equals that of portland cement and ranks behind only crushed stone, sand and gravel among all non-fuel mineral commodities. If all the CCPs generated annually in Ohio were placed on top of a football field, the height of the CCP material would be about one mile.

3 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 2-1: Types of Coal Combustion Products (CCPs) and Their Characteristics

* Stabilized FGD is a mixture of filter cake (Ca, S), fly ash (Si, Fe, Al), lime, and water. Major constituents of FGD gypsum are Ca and S. (Source: Butalia et al., 1999a)

Table 2-2: Annual Production of Selected Non-Fuel Mineral Commodities for Ohio

Type of non-fuel mineral Production (million tons/year)

Crushed stone 69 Sand 29.8 Gravel 28.4 Coal combustion products 10 Cement 10

(Sources: Wolfe, M., 1998; ODNR-Division of Geological Survey; CCP survey by authors)

4 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

2.2 Regulation of CCPs

Coal combustion products (CCPs) are regulated under federal and state laws, statutes, and policies. This section describes the governmental regulation of CCPs.

2.2.1 Federal Regulation

The Resource Conservation and Recovery Act, 42nd United Stated Congress §6901-6911 (RCRA) is the principal federal statute under which hazardous and solid wastes are regulated in the United States. RCRA establishes a comprehensive structure for regulating hazardous wastes. Subtitle C of RCRA and its implementing regulations impose restrictions on the generation, transport, storage, treatment, and disposal of hazardous wastes. Wastes not considered to be hazardous under Subtitle C fall under Subtitle D, and are by default subject to regulation by the states as solid wastes. The original RCRA statute did not specifically address whether CCPs were to be regulated under Subtitle C or Subtitle D. In 1980, the Congress enacted the Solid Waste Disposal Act amendments to RCRA. Under these amendments, certain wastes, including CCPs, were excluded from Subtitle C regulation as solid wastes. This exemption, commonly referred to as the “Bevill Exemption” (42nd United States Congress, §6921(b)(3)(A)(i)) meant that CCPs fell under Subtitle D and became subject to state regulations as solid wastes.

The Bevill amendment also directed the United States Environmental Protection Agency (USEPA) prepare a report regarding CCPs and to recommend appropriate regulation (42 U.S.C §6982(n)). USEPA issued its Report to Congress (RTC) in February 1988 (United Stated Environmental Protection Agency, 1988) in which it concluded that CCPs generally do not exhibit hazardous characteristics and that the regulation of CCPs should remain under Subtitle D state authority. Following litigation against USEPA by the Bull Run Coalition, a final regulatory determination by USEPA became effective September 2, 1993 (58 Federal Register 42, 466, August 9, 1993). An environmental fact sheet published by USEPA concluded that “large- volume wastes from coal-fired electric utilities pose minimal risks to human health and the environment” (United States Environmental Protection Agency, 1993). It also found that “it is unnecessary to manage these wastes as hazardous.” A copy of the fact sheet issued by USEPA is attached as Appendix A.

The USEPA exemption applied only to high-volume CCPs generated by coal-fired electric utilities and independent power producers, and did not include CCPs generated at any other industrial activity. Co-managed wastes and Fluidized Bed Combustion (FBC) ash were found to be outside the scope of the 1993 determination. A follow-up study on these remaining wastes was performed and a Report to Congress, Wastes From the Combustion of Fossil Fuels, was issued on March 31, 1999 (United Stated Environmental Protection Agency, 1999). The report concluded that the disposal and most beneficial uses of low-volume utility wastes (when co- managed with high-volume CCPs subject to the 1993 exemption), non-utility CCPs, and FBC wastes should remain exempt from RCRA Subtitle C. The report found that the disposal of these materials generally does not present a risk to human health and the environment, and that current waste management practices and trends as well as existing state and federal statues appear

5 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

adequate. Similarly, no significant risks to human health and the environment were identified or believed to exist for any beneficial uses of these wastes, with the possible exception of agricultural and minefill uses. The concerns relating to agricultural and minefill uses also applied to high-volume electric utility CCPs that previously had been exempted from Subtitle C under the 1993 rulemaking. Based on the March 31, 1999 Report to Congress, public comments and information received on the report, USEPA issued a final regulatory determination on April 25, 2000 (refer to Appendix L). The final regulatory determination for all CCPs was published in the Federal Register of May 22, 2000, Part III, EPA, 40 CFR Part 261. The final regulatory determination concluded that CCPs do not warrant regulation under Subtitle C of RCRA and that USEPA is retaining the hazardous waste exemption for CCPs under RCRA Section 3001(b)(3)(C). However, EPA determined that voluntary Subtitle D (non-hazardous) national standards need to be developed for CCPs disposed in landfills or surface impoundments, and used in filling surface or underground mines. USEPA also determined that no additional regulations were warranted for CCPs that are used beneficially (other than for minefilling). In the determination, USEPA supported increases in beneficial uses of CCPs, such as additions to cement and concrete products, waste stabilization, and use in construction products such as wallboard. More detailed background information and updated documents on USEPA’s determination can be obtained from http://www.epa.gov/epaoswer/other/fossil/index.htm.

The federal government also provides guidelines for the use of CCPs, particularly fly ash. Some of the notable guidelines issued by the federal government are: 1) In 1983 the federal government issued its first CCP procurement guideline that required agencies using federal funds to implement a preference program favoring the purchase of cement and concrete containing fly ash (40 C.F.R., Part 249). 2) The USEPA endorses the use of pozzolans, such as fly ash, as the preferred method of stabilizing certain metal-bearing wastes (52 Federal Register 29992). 3) USEPA published an environmental fact sheet pertaining to use of CCPs for cement and concrete containing fly ash (EPA 530-SW-91-086, January 1992). 4) Executive Order 12784 (Federal Acquisition, Recycling and Waste Prevention) signed by President Clinton on October 23, 1993 directs federal agencies to develop affirmative action programs for environmentally preferable products and requires USEPA to issue guidance to agencies for the purchase of environmentally preferable products. 5) USEPA has proposed a Comprehensive Procurement Guideline (CPG) designating items that can be made with recovered materials including fly ash (59 Federal Register 18852, April 20, 1994). 6) In January 2000, USEPA issued a procurement guideline item for fly ash containing flowable fills (65 Federal Register, SWH-FRL-6524-3, January 19, 2000).

2.2.2 State of Ohio Regulation

Under Ohio regulations, fly ash, bottom ash, boiler slag, and flue gas emission control by- products (FGD material) generated primarily from the combustion of coal or other fossil fuels are exempt from regulation as hazardous wastes (Ohio Administrative Code, §3745-51-04-B-4).

6 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Fly ash, bottom ash, boiler slag, and FGD are regulated as solid wastes. Non-toxic fly ash, bottom ash, and slag are regulated as exempt wastes, i.e., they are excluded from the statutory definition of solid waste. FGD is considered to be an air pollution control waste and is regulated as a residual solid waste (Ohio Administrative Code, §3745-30-01-B-1).

2.2.2.1 Beneficial Use Policy

The reuse of CCPs is not specifically authorized under Ohio law or regulations, but the reuse of non-toxic fly ash and bottom ash is authorized under a policy document (DSW 0400.007) issued by the Ohio Environmental Protection Agency’s (OEPA’s) Division of Surface Water on November 7, 1994 titled “Beneficial Use of Nontoxic Bottom Ash, Fly Ash, and Spent Foundry Sands and Other Exempt Wastes” (Ohio Environmental Protection Agency, 1994). A copy of the policy is attached to this report as Appendix B. Residual wastes such as FGD may be beneficially used in accordance with this policy where noted. The policy allows for the following uses of non-toxic fly ash and bottom ash: · As a raw material in manufacturing a final product, e.g., grout, flowable fill, lightweight aggregate, concrete block, bricks, asphalt, roofing materials, plastics, paint, glass, fiberglass, ceramics, blasting grit and other non-land application products; · As a stabilization/solidification agent for other wastes which will be disposed; · As part of a composting process when the process is performed in accordance with applicable regulations; · In uses subject to USEPA Procurement Guidelines; · As an anti-skid material or road preparation material, if such use is consistent with Ohio Department of Transportation specifications; · For use in mine subsidence stabilization, mine fire control, and mine sealing when authorized by the Ohio Department of Natural Resources; · As an additive in commercial soil blending operations, where the product will be used for growth of ornamentals, when the waste constitutes no more than 50% of the mixture. If the waste exceeds 5 times Ohio's primary drinking water standards, the mixture may not be applied to grazed pastures, home / vegetable/ fruit gardens, on crops or fruit trees; · As daily cover at a landfill if approved by OEPA in the landfill permit; · As structural fill, defined as an engineered use of waste material as a building or equipment supportive base or foundation and does not include valley fills or filling of open pits from coal or industrial mineral mining; · As pipe bedding, for uses other than transport of potable water. Materials used in sanitary sewer projects must comply with OEPA Policy DSW 400.001; · As a construction material for roads or parking lots (subbase or final cover), if approved by a professional engineer, the property owner and the Department of Transportation where necessary; and · Other single beneficial uses of less than 200 tons.

Written notice must be submitted to OEPA before commencement of a beneficial use project involving high volume structural fill applications. A report needs to be submitted by April 1 of

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each year summarizing certain beneficial use projects involving structural fill, road base, and pipe bedding applications completed during the prior calendar year, including a description of the nature, purpose, and location of the project, the type and volume of wastes used, and leachate test results. The above listed uses are divided into four categories. Category 1 use does not require OEPA review or notification. However, a few general requirements apply. Examples of Category 1 projects are anti-skid agent, manufacture of another product, stabilization of other wastes, composting process, and some pipe bedding, roads / parking lots, as well as soil blending ingredients. Category 2 projects do not require prior OEPA review provided isolation distance and other relevant criteria are satisfied. Category 2 projects require an annual report to be submitted to OEPA. Examples of Category 2 projects are low volume structural fills and borrow pits. Category 3 projects relate to higher volume structural fill projects that satisfy isolation distance and other relevant criteria. A 30-day prior notification to OEPA is needed for Category 3 projects. Examples of Category 3 projects are some structural fills with volume use in the range of 600 to 30,000 tons. Proposals for other additional uses not listed in the policy need to be sent to OEPA under Category 4, at least 60 days prior to the commencement of the project. OEPA consent is required before a Category 4 project can be constructed. Under the beneficial use policy, the land application and engineered uses of coal combustion products were regulated mainly through the Division of Surface Water of OEPA.

2.2.2.2 Interim Alternative Waste Management Program

OEPA issued a management directive on June 26, 1997, which effectively replaced the term “beneficial use” with “alternative disposal option” (Ohio Environmental Protection Agency, 1997a). The directive stated that alternatives to traditional landfilling are acceptable to OEPA but they are to be regulated as alternative disposal options. An Interim Alternative Waste Management Program (IAWMP) was put into effect July 1, 1997 under which the alternative management practices were divided into two categories: 1) Engineered Use: The use of a waste material as a substitute for conventional material that would normally be used to support some type of structure. Examples of engineered use include structural fill, pipe bedding, road base, backfill, and other construction uses. Engineered uses at facilities include daily cover, cap material, pond liner, drainage material, frost protection layer, and fire retardant. 2) Land Application – The spreading of waste materials onto or their incorporation into soils for the purpose of increasing nutrient availability of the soil or adding nutrient value, where such use does not endanger human health or the environment. The use of waste material as a substitute for soil does not qualify as land application. The alternative disposal options listed above can be carried out on five general types of locations. These include: 1) Licensed and permitted solid waste facilities; 2) Licensed construction and demolition debris facilities; 3) Exempt waste facilities permitted under Ohio Revised Code 6111; 4) ODNR regulated mine sites (including active surface coal mining operations permitted under Ohio Revised Code 1513 and abandoned mined lands where ODNR-Division of Mines and Reclamation is conducting reclamation work); and 5) Sites other than a landfill or active/inactive mine site.

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Alternative waste disposal at transfer or composting facilities is considered on a case-by-case basis.

In IAWMP, the regulatory procedures depend on the type of the CCP being considered (exempt waste or residual solid waste), and the proposed application use and location. Tables 2-3 and 2-4 show the regulatory procedures for the engineered and land application alternative use of CCPs. In these tables, FGD is considered to be a residual solid waste, while other CCPs are exempt wastes. Under the IAWMP, some of the regulatory authority which earlier was vested mainly in Division of Surface Water (DSW) is now shared with the Division of Solid and Infectious Waste Management (DSIWM). In particular, the program lead for engineered use of residual solid wastes (FGD) has been shifted to DSIWM. Use of CCPs at ODNR regulated coal mining and reclamation operations and abandoned mine lands is regulated by the DMR as per recent changes to ORC 1513 by the Amended Substitute Senate Bill 187 of the 122nd General Assembly.

OAC 3745-27-90(E)(2)(b) requires Solid Waste Management Districts to reduce and recycle at least 50 percent of their industrial solid wastes generated by the year 2000. The alternative disposal use of CCPs counts as credits towards this recycling goal. This reduction / recycling goal of OEPA is commendable, but with the recent OEPA transition from a beneficial use policy governance system to an Interim Alternative Waste Management Program, the recycling efforts for FGD material have received a set back. For many FGD engineered uses (e.g., use of FGD in the construction of a road) authorization from the Director of OEPA would be needed. This may result in non-achievement of the 50% reduction /recycling goal by solid waste districts with significant amounts of FGD generation. A positive move under the IAWMP has been increased review of proposed CCP project plans at the district level, because CCP project based decisions are best made at the local level. Unfortunately not all OEPA district offices have the resources or expertise to adequately review all the pertinent information available for many of the new and innovative use of CCPs, resulting in a wide range of policies. Compounding this problem is frequent turnover of key staff.

The IAWMP proposed that a Long Term Alternative Waste Management Program (LTAWMP) be developed by OEPA and implemented into rules. A Waste Steering Committee was formed in 1998 to review all types of wastes regulated by the agency and to propose a more logical framework than the current IAWMP structure. The LTAWMP was scheduled to be in place by July 1999. While some progress on the issue has been made, the deadline has not been achieved. In the meantime, the IAWMP is being used by OEPA to divide the workload for alternative waste management plan review.

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Table 2-3: IAWMP Regulatory Guidelines for Engineered Use of CCPs

OAC 3745-400-15(A) Exempt waste use Consent of OEPA or PTI ORC 6111-03 (other than drainage and possible facility ORC 6111-04 DSW 0400.007 medium) at C&DD modification DSW Licensing disposal facility authority OAC 3645-31-02(A) DSW 0400.027

OAC 3745-400-15(A) Exempt waste use at Authorization by Director ODNR regulated of ODNR-DMR ODNR-DMR ORC 1513-02-(A)-(7) mine site Category 1 and 2 use require no notification Exempt waste use at site other than solid Category 3 use requires 30 waste facilities, day prior notification ORC 6111-03 DSW 0400.007 other disposal DSW facilities, and Category 4 use requires ORC 6111-04 DSW 0400.027 ODNR regulated OEPA notification of least mine sites 60 days prior to use and consent from OEPA is OAC 3645-31-02(A) necessary FGD use at solid DSIWM Guidance waste facility Alteration from district DSIWM-DO ORC 3734 #0168 and DSIWM office miscellaneous OAC 3745-27 DSIWM guidance documents FGD use at ODNR Authorization by Director ODNR-DMR ORC 1513-02-(A)-(7) regulated mine site of ODNR-DMR FGD use at site other than solid Authorization by Director DSIWM-DO ORC 3734-02- waste facilities, of OEPA Division(G) other disposal facilities, and OAC 3745-27- ODNR regulated 05(A)(4) mine sites

IAWMP: Interim Alternative Waste Management Program C&DD: Construction and Demolition Debris facility DSW: Division of Surface Water DSIWM: Division of Solid and Infectious Waste Management DO: District Office PTI: Permit To Install ODNR: Ohio Department of Natural Resources DMR: Division of Mines and Reclamation ORC: Ohio Revised Code OAC: Ohio Administrative Code

(Source: Ohio Environmental Protection Agency, 1997a; Ohio Administrative Code; Ohio Revised Code)

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Table 2-4: IAWMP Regulatory Guidelines for Land Application of CCPs

Program Statutory and Related guidance, Type of activity Required authorization Program lead support regulatory approval policy, other authority documentation Exempt waste use at Alteration from district ORC 3734 DSW’s Land solid waste facility DSIWM office DSIWM-DO DSW Application of OAC 3745-27 Sludge Manual Exempt waste use at Authorization by Director ODNR regulated of ODNR-DMR ODNR-DMR ORC 1513-02-(A)-(7) mine site Exempt waste use at PTI site other than solid or ORC 6111-03 DSW’s Land waste facilities, PTI modification Application of other disposal or DSW ORC 6111-04 Sludge Manual facilities, and Plan approval and site ODNR regulated concurrence from DSW- mine sites DO OAC 3645-31-02(A) FGD use as in final Alteration from district ORC 3734 DSW’s Land cover soil at solid DSIWM office DSIWM-DO DSW Application of waste facility OAC 3745-27 Sludge Manual FGD use at ODNR Authorization by Director ODNR-DMR ORC 1513-02-(A)-(7) regulated mine site of ODNR-DMR FGD use at site For solids: PTI or PTI other than solid modification ORC 6111-03 waste facilities, ORC 6111-04 DSW’s Land other disposal For sludges: PTI or PTI DSW Application of facilities, and modification or Plan OAC 3745-31-02(A) Sludge Manual ODNR regulated approval and site OAC 3745-31-02(B) mine sites concurrence from DSW- OAC 3745-27- DO 03(H)(3)

IAWMP: Interim Alternative Waste Management Program DSW: Division of Surface Water DSIWM: Division of Solid and Infectious Waste Management DO: District Office PTI: Permit To Install ODNR: Ohio Department of Natural Resources DMR: Division of Mines and Reclamation ORC: Ohio Revised Code OAC: Ohio Administrative Code

(Source: Ohio Environmental Protection Agency, 1997a; Ohio Administrative Code; Ohio Revised Code)

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2.3 Existing and Potential Use of CCPs

Approximately 10 million tons of fly ash, bottom ash, boiler slag and FGD are produced in the state of Ohio every year. The majority (over 7 million tons) of these materials are still being disposed of in landfills and surface impoundments. Identification and promotion of cost-effective alternatives to landfilling, has been one of the important considerations of the energy strategy for Ohio (Ohio Energy Strategy Interagency Task Force, 1994). The recycling of these materials and avoidance of landfill costs are important if high-sulfur Ohio coal is to remain a competitive fuel source in the future.

A review of existing and potential CCP utilization technologies shows that if treated and applied correctly, coal combustion products can have versatile properties that make them suitable raw materials for many applications. Special attention needs to be paid to the potential utilization of FGD material since the greatest improvement in the utilization rates is likely for FGD. Existing and potential uses can be divided into five broad technology categories: highway, reclamation, agricultural, manufacturing, and other civil engineering and miscellaneous uses.

Table 2-5 lists CCP application technologies currently being used or having potential for use in the state. Several different types of application technologies for each broad category are identified. The use of fly ash, bottom ash, boiler slag, and FGD is considered for each category. FGD is divided into dry and wet types. Applications used in Ohio in the past or currently under use except for demonstration projects are indicated with an “O”. Applications that have potential for Ohio are shown with an “X”. Uses currently in research and demonstration phases are indicated with an asterisk (*). It can be seen from the table that existing and past uses of fly ash, bottom ash, and boiler slag are quite diversified. The use of FGD is currently limited to a few applications but research and demonstration projects investigating its potential uses are currently in progress. A complete list of CCP demonstration projects in the state of Ohio is included in Appendix C as Figure C-1.

Table 2-5 shows that wet and dry FGD have potential in many different types of uses. Potential high volume uses exist for highway construction and maintenance, reclamation, agricultural and wallboard manufacture. High-value markets for CCPs are likely in the manufacturing industry. Significant environmental benefits from reclamation can result from the use of FGD to reduce acid mine drainage and sedimentation problems. Economic benefit to utilities would be greater for high-volume and high-value applications. End users benefits for the different types of uses would depend mainly on the cost of competing conventional materials and hauling distance (distance over which the CCP has to be transported from the supplier to project location or facility).

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Table 2-5: Existing and Potential Uses of CCPs in Ohio

13 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

2.4 Benefits and Drawbacks of CCP Utilization

As discussed in the previous section, coal combustion products (CCPs) can be used for many different types of application technologies. Currently, disposal by landfilling is the prevalent option for CCPs in the state. Research has shown that many CCPs, when treated and applied properly, can replace more expensive virgin materials. The benefits and drawbacks of the utilization of CCPs instead of the current practice of landfill disposal are discussed below.

2.4.1 Benefits of CCP Use

The use of fly ash, bottom ash, boiler slag, and FGD for highway, reclamation, agricultural, manufacturing, and other civil engineering uses has several identifiable advantages. The potential benefits of CCP use in Ohio are: 1) Economic Benefits: Significant direct economic savings can be realized by CCP generators, ash marketers, and end users. The economic benefits generally drive the adoption of a new technology or product. CCP generators benefit if costs associated with alternative use are lower than landfilling or other disposal methods. Landfilling costs to utilities in Ohio typically range from $3 - $15 for producers with captive landfills and $10 - $35 for generators without captive landfills. Using an average unit weight of 1800 lb/yd3 and a low unit disposal cost, the cost avoidance amounts to $10 to $30 million for a hundred-acre landfill. With increasing landfilling costs and more stringent emission requirements, the associated disposal costs are likely to increase in the future. The broker (ash marketer) generates some profit per ton of CCP sold to the end user. End user benefits can also be quite significant. In two highway embankment repair studies (refer to Section 5.2), the construction of dry FGD highway embankments saved the Ohio Department of Transportation 25% to 40% of the cost of construction using conventional materials. An FGD-lined pond facility built in South Charleston, Ohio in 1997 cost approximately $50,000, while a similar concrete lined facility constructed by OSU two years earlier cost nearly $200,000. 2) Technical Benefits: Coal combustion products are generally accepted as being non-hazardous and non-toxic. Most CCP uses in the state require that the leachate from these materials meet OEPA Division of Surface Water non-toxic policy criteria, which is 30 times the Ohio primary drinking water standards. Tests conducted at The Ohio State University and elsewhere, and reviewed by OEPA, have shown that the leachate from most CCPs meet the non-toxic criteria (30 times formula). In many cases, the leachate is lower in concentration levels than even the Ohio primary drinking water standards. Fly ash is a pozzolan, i.e. in the presence of lime and water it forms cementious compounds. Similarly, formation of ettrengite results in increased strength of FGD compared to that of soils. The unconfined compressive strength of stabilized sulfite-rich FGD is about 5-10 times that of clay. Most highway applications of FGD utilize the high strength and low permeability characteristics of FGD materials. Reclamation applications take advantage of the alkalinity present in CCPs, particularly FGD. The agricultural uses depend largely on the alkalinity, trace elements, and physical soil improvement characteristics of CCPs. FGD gypsum can supply major nutrients, such as calcium and sulfur, for enhancing soil properties. Fly ash and FBC ashes can be used

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for the treatment of biosolids. The manufacturing industry is motivated to use CCPs as feed stocks to make more durable and inexpensive products. Other uses of CCPs in civil engineering applications depend on the engineering characteristics of fly ash, bottom ash, boiler slag, and FGD. 3) Better Products: The use of CCPs for many applications results in products that are better in quality and more durable than those without CCPs. An example is the use of fly ash as an admixture in concrete. Fly ash enhanced concrete exhibits higher long-term strength, lower permeability, greater resistance to alkali aggregate reaction, increased resistance to sulfate attack, improved workability, and reduced bleeding compared to plain concrete. Fly ash and FGD materials have a high shear strength to unit weight ratio and hence embankments constructed of these materials have higher slope stability factors, steeper permissible slopes, and result in reduced settlement of underlying soils as compared to fills with natural soils. 4) Emphasis on Recycling and Decrease in the Need for Landfill Space: Recycling of CCPs, instead of landfilling them reduces the amount of landfill space needed, reducing the potential environmental problems associated with landfills. High-volume uses of CCPs, particularly for highway, reclamation, and manufacturing industry uses, results in a significant extension of the life of existing landfills and lessens the need for new expensive landfills. The effective use of these materials can result in OEPA taking credit for increasing recycling efforts across the state and reducing amounts of CCPs being landfilled. 5) Conservation of Natural Resources: For many construction and other uses, coal combustion products are suitable substitutes for virgin raw materials. The amount of sand, gravel, crushed stone, and clay mined in the state of Ohio exceeds 100 million tons annually. The use of CCPs as raw material in construction related industries could result in reduced extraction of these materials, thus conserving the life of state natural resources. 6) Avoidance of Destruction Caused by Borrow Areas: The use of CCPs as raw materials in place of conventional virgin materials reduces the amount and type of environmental destruction that is caused at the areas from which these virgin materials are extracted. As an example, good clay needed for reclamation of a gob pile is typically obtained from a borrow area by stripping it clear of vegetation. The ecological destruction caused by such borrow areas could be avoided if compacted FGD is used as a cap material over the gob pile. In such cases, irrespective of the economic considerations, FGD may be the only material of choice. 7) Cleaner and Safer Environment: The use of some CCPs can result in a significant improvement in the quality of degraded environments around the state, most notably at abandoned mined lands. These areas are sources of acid mine drainage, sedimentation, and subsidence problems. Many coal-fired power plants are located in the vicinity of existing and abandoned mines. FGD can be used to reclaim mined areas and improve significantly the acid mine drainage and sedimentation problems caused by these abandoned mined areas on the health of Ohio streams, rivers, and lakes. The manufacture and use of products that reduce landfilling and promote recycling while maintaining quality should be preferred. One of the commonly used environmentally responsible products is fly ash concrete. The use of fly ash as an admixture in concrete to partially replace energy intensive materials like cement, results in a reduction of CO2 emissions, a greenhouse gas. It is estimated that about one ton of CO2 emissions are avoided for each ton of cement replaced by fly ash. Currently about 500,000 tons of CO2 emissions reductions are realized annually in the state due to the use of fly ash as an admixture in concrete, cement, and grout applications.

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8) Reduced Social Costs: Real estate values near a landfill are proportionally related to the distance from a landfill (Stehouwer et al., 1998; Dick et al., 1999a). Studies conducted in Ohio on sanitary landfills and extended to FGD landfills using standard benefit transfer procedures, have estimated that the social costs of FGD landfill disposal ranges from $0.31 to $1.42 per ton (Dick et al., 1999a), with higher costs associated with urban landfills. Unlike sanitary landfills, CCP landfills are not a source of public nuisance issues such as odor, rodents, blowing trash, methane gas, etc. Hence, the social costs estimated by Dick et al. (1999a) for FGD landfills seem too high. The actual statewide average social cost for landfilling FGD is probably between $0.10 and $0.30 per ton. A small amount of social benefit (a few cents per ton of FGD) could also be realized for reclamation of abandoned mined lands due to increase in property values in the vicinity of reclaimed areas. 9) Boost Economic Development: A strong infrastructure is a prerequisite to economic development. The use of CCPs for large-volume highway applications can result in improved and less costly infrastructure maintenance. Reclamation of abandoned mined lands in east and southeast Ohio improves overall environment and aesthetics of an area, eliminating one barrier to new business location in Appalachia, and improved tourism opportunities. Installation of FGD lined pond facilities can result in improved economics for animal husbandry facilities in the Appalachian region. New manufacturing plants, which offer employment, may be located in the vicinity of a fly ash or FGD generating facility to use the CCP as a feedstock for product manufacture.

2.4.2 Drawbacks and Limitations of CCP Usage

The use of coal combustion products can have several potential technical, environmental, economic drawbacks and limitations, if they are not used properly. The potential limitations and drawbacks associated with CCP use and suggestions to overcome them are: 1) Increased Haulage Cost: CCP utilization generally requires the transport of these materials from the production location to project site or manufacturing facility. Trucking is the major means of transportation in Ohio. Currently, it costs approximately $0.10 per ton per mile to transport CCPs by trucks. The trucking cost is the deciding factor in most potential project uses. Some CCP use technologies are commercially competitive only when the provider or someone other than the end user subsidizes the trucking expenses. Government subsidization of trucking is not a long-term solution. Trucking cost share procedures need to be developed by utilities and end-users for promoting CCP use. It is expected that utilities with high disposal costs would be more willing to transport CCPs to distant project sites. In addition, haulback of CCPs to or near coal-mining sites can be a promising option. 2) Variability of Material: The quality of CCPs depends mainly on the type of coal, boiler, combustion phase, desulfurization reagent, and FGD process employed. Startup ash is significantly different than ash produced at full load under continuous operations. Coal-fired facilities need to establish better quality assurance / quality control procedures for CCP production so that the chemical and engineering properties of the generated materials fall within certain acceptable and specifiable bounds. Testing and evaluation of CCPs for project use need to cover the range of CCP compositions. For some applications, job-specific testing of material prior to placement is also recommended.

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3) Opposition from Established Raw Material Marketers: CCPs are low-cost alternatives to many conventional raw materials. Increased use of CCPs may result in slightly reduced sales of conventional materials thus attracting opposition from affected industries. However, it is expected that the impact on conventional markets even for substantial increases in CCP usage will be low. In part because some opposition from established raw material manufacturers can be expected in a free enterprise market, efforts to educate the public of the direct and indirect benefits of recycling CCPs should be continued by CCP stakeholders. 4) Potential Long-Term Effects: Recycled materials, including CCPs, which have not been exposed long-term to the environment have insufficient historical use data to assess the potential for long-term pollution. Although the leachate from CCPs is non-toxic, concerns over the long-term effects of these materials on the environment persist. Demonstration projects have yielded data on short-term pollution potential, but the long-term potential must be evaluated by extrapolation from observed data in conjunction with appropriate numerical modeling. Projects that were constructed in the past need to be evaluated by researchers and engineers, and suitable design and construction recommendations should be implemented if problems are observed at those sites. 5) Design Costs: Designers of conventional construction projects have easy access to standard guidelines and design procedures. More effort is needed for designing projects that use CCPs, for which standard design specifications may not exist. This typically involves evaluating the results of past demonstration projects for the particular application being considered. The increased design costs are expected to be a concern for the designer but not a major cost issue. For this reason, it is important for researchers to educate and involve consultants and designers in the research and development of potential CCP uses. 6) Monitoring Costs: Some minimal site instrumentation and monitoring might be desirable to evaluate the performance of a CCP project during and after construction. In such cases, the additional cost of monitoring can be burdensome depending on the type and scope of monitoring required. It is possible to minimize or eliminate this cost by conducting robust demonstration projects that can be instrumented, and the results of the monitoring program be documented and shared with potential end users, consultants, and regulatory agencies. 7) Bulky Nature of FGD Material: Wet FGD has a moisture content from about 30% to 60%. The transport of wet FGD material thus requires transporting a large quantity of water along with solids particles, adding significantly to the cost. Since the transportation cost is the deciding factor for most CCP uses, the moisture content at time of transport should be optimized. However, an advantage of delivering wet material at the project site is that no additional water needs to be added at the site. 8) Litigation Potential: Due to lack of technical understanding or for other reasons, any failure at the project site may be attributed, whether it is warranted or not, to the unconventional materials used, including CCPs. This may result in costly litigation in which the CCP provider may choose to settle to avoid damage to its reputation among the general public. The concern with potential liability of using recycled raw materials such as CCPs would be best addressed by excluding CCP uses from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Efforts by the industry toward this end have not yet resulted in a change in the act. Since current environmental liability is not fault based, the extensive database of information generated on the non-hazardous and non-toxic nature of CCPs does not provide protection against CERCLA liability.

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9) Durability: Freeze-thaw cycling has the potential of adversely affecting the engineering characteristics of some FGD materials, similar to re-compacted clay materials. However, appropriate laboratory and field-testing procedures can be used to evaluate the potential of temperature cycling on CCP properties. For example, studies conducted at The Ohio State University showed that stabilized FGD (additional lime content of 4-6%) that had been cured for 60 days before being exposed to freezing temperatures exhibited consistently high strengths irrespective of the moisture content at the time of mix compaction. Based on this study, a 60-day curing time is recommended in Ohio as a general rule for FGD use in load- bearing (engineered use) applications which may be exposed to freeze-thaw cycling. While fly ash, bottom ash, and wet FGD materials are not susceptible to swelling, concerns relating to potentially high amounts of swell for some dry FGD materials have been expressed in some parts of the United States. Dry FGD materials used in OSU research demonstration projects exhibited small amounts of swell in the laboratory. Swelling may be a concern in some dry FGD high-volume applications such as embankment or structural fills, but even in those cases, proper laboratory testing, design, and construction procedures can be used to identify and control swell potential. 10) Haulage Disturbance: As with conventional virgin materials, the transport of CCPs over public highways can cause traffic congestion, noise, dust, and material deposition. No general procedure has been developed for evaluating the effect of traffic disturbance due to haulage. However, negative impacts are minimized by using covered trucks, choosing appropriate routes, and transporting during non-peak traffic hours.

2.4.3 The Art of Balancing Issues

For each potential use of a CCP, the benefits and drawbacks need to be given due consideration in a subjective as well as quantified manner. Most of the drawbacks can be minimized or overcome as discussed in Section 2.4.2.

In general, the various issues relating to CCP utilization have been divided into three categories, technical, environmental, and economic factors. A fourth issue that has been neglected in the past, but can be important to the successful promotion of CCP utilization is societal factors. Social factors contributing towards CCP utilization include quality of life and property value impacts, safety and health hazard, site visibility and aesthetics, involvement of government agencies and special interest groups. In particular, the political climate and attitude of citizen groups need to be considered. Societal factors are a public perception issue caused to a large extent by the classification of CCPs as “wastes”.

Figure 2-1 shows the four factors listed above that play a role in CCP utilization decisions. For a CCP marketing implementation program to be effective, all these factors need to be in balance. Trade-offs on certain issues may be made as long as all four factors are considered and the “big picture” is kept in mind (Organization for Economic Co-Operation and Development, 1997).

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Economical factors

Environmental factors

Technical factors

Societal factors Greatest potential for use of CCPs

Figure 2-1: Potential for CCP Utilization

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20 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

3 COAL PRODUCTION AND USE

3.1 Coal Production

The coal reserves of Ohio are a part of the Appalachian coal basin and lie on the northwestern edge of a large geologic structure called the Main Bituminous Coal Basin. This basin extends from North-Central Pennsylvania through Eastern Ohio, West Virginia, Western Maryland, and southward into Alabama. Coal deposits underlie approximately the eastern third of the state covering an area of about 11,000 square miles. Ohio coal fields are approximately 180 mile long along the Ohio River, have an average width of approximately 60 miles, and are oriented along a northeast-southwest axis (United States Department of Agriculture, 1985). Ohio coal seams include the Lower and Upper Brookville, Winters, Clarion, Lower and Middle Kittanning, Strasburg, Lower and Upper Freeport, Mahoning, Harlem, Pittsburgh, Pomeroy-Redstone, Meigs Creek, and Waynesburg seams. Most of the coal mined in the state is high-sulfur bituminous coal. A detailed history of the coal mining industry in Ohio has been published by the Division of Geological Survey, Ohio Department of Natural Resources (Crowell, D.L., 1995).

In 1997, approximately 29.4 million short tons (MST) of coal was mined in the state of Ohio from sixteen coal seams covering 18 counties (Figure 3-1, Energy Information Administration, 1997a). Counties leading in coal production include Belmont (6.7 MST), Meigs (6.4 MST), Monroe (3.2 MST), Harrison (2.1 MST), Vinton (1.8 MST), Tuscarawas (1.3 MST), Perry (1.2 MST), and Jackson (1.1 MST). About 57% of Ohio coal was obtained by underground mining, and the rest was recovered by surface mining. An additional 29.5 MST of coal was imported into the state in 1997 from West Virginia, Kentucky, Indiana, Pennsylvania, Virginia, Wyoming, and Montana (Energy Information Administration, 1997a).

3.2 Coal Consumption

Approximately 87% of Ohio’s electricity is generated by coal-fired power plants (Public Utilities Commission of Ohio, 1996). Coal-fired electric utilities use approximately 90% of the coal consumed in the state. In 1992, Ohio ranked first in coal-fired electricity generation capacity and third in coal consumption among all the states of the US (Energy Information Administration, 1996). Table 3-1 lists the average quantity and quality of coal received at Ohio electric utilities from 1993 to 1997. Total coal consumption increased 2.6% from 1993 to 1997. During this period, the average Btu of coal decreased slightly (1%). The average sulfur content of coal increased over the same period from 1.40 to 1.90, and average ash content of coal received at Ohio coal-fired electric utilities increased from 7.10% to 8.52% (Energy Information Administration, 1997a). The increased coal utilization by Ohio electric utilities along with the steady increase in the sulfur and ash content of the coals received at these plants, has led to an increase in the amount of CCPs generated in the state - particularly fly ash and FGD.

21 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ASHTABULA

LAKE WILLIAMS FULTON LUCAS OTTAWA WOOD GEAUGA TRUMBULL HENRY CUYAHOGA DEFIANCE SANDUSKY ERIE LORAIN PORTAGE HURON SUMMIT SENECA PAULDING MEDINA PUTNAM HANCOCK MAHONING

VAN WERT WYANDOT STARK COLUMBIANA ALLEN WAYNE HARDIN 0.5 MST 0.8 MST MERCER MARION AUGLAIZE HOLMES CARROLL 0.1 MST 0.1 MST LOGAN KNOX SHELBY UNION MORROW COSHOCTON 1.3 MST HARRISON DARKE DELAWARE 0.4 MST 2.1 MST

CHAMPAIGN LICKING MIAMI MUSKINGUM GUERNSEY BELMONT FRANKLIN 0.5 MST 6.7 MST CLARK 0.7 MST PERRY PREBLE NOBLE MONROE FAIRFIELD 1.2 MST GREENE MADISON PICKAWAY MORGAN 0.8 MST 3.2 MST FAYETTE HOCKING WASHINGTON WARREN BUTLER CLINTON ROSS ATHENS VINTON 1.8 MST HAMILTON HIGHLAND PIKE MEIGS JACKSON 6.4 MST

1.1 MST GALLIA BROWN ADAMS SCIOTO 0.3 MST 0 10 20 30 40 miles

0 10 20 30 40 50 kilometers LAWRENCE

(Source: Energy Information Administration, 1997a)

Figure 3-1: Coal Production - 1997

22 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 3-1: Coal Received at Ohio Electric Utilities (1993-1997)

Category (units) 1997 1996 1995 1994 1993 Percent change (1993-1997) Coal consumption (MST) 52.8 53.5 49.7 49.3 51.4 2.6 Btu 12,348 12,415 12,424 12,429 12,476 -1.0 Sulfur content (%) 1.90 1.82 1.69 1.60 1.40 26.3 Ash content (%) 8.52 8.27 7.79 7.66 7.10 16.6

(Source: Energy Information Administration, 1997a)

3.3 Effect of Coal Use on Electric Industry Emissions

The increased use of higher sulfur coal in the past several years by Ohio electric power industry has not resulted in an increase in the SO2 or CO2 emissions due to the implementation of Clean Air Act Amendments of 1990 (Energy Information Administration, 1996). The estimated emissions of SO2 and CO2 in 1986 by the electric power industry were 2.1 MST and 145 MST, respectively (refer Table 3-2). In 1996, the SO2 emissions had dropped to 1.4 MST (a 33% reduction), and the CO2 emissions reduced slightly to 144.3 MST (a 0.5% reduction). On the other hand, estimated NOx emissions are reported to have increased from 0.53 MST in 1986 to 0.57 MST in 1996 (a 7.5% increase). It is likely that in the future, Ohio will design and implement a plan for reducing NOx emissions from coal-fired facilities due to regulatory action by USEPA. The implementation of NOx control at coal-fired plants will have a significant effect on the by-products generated from the combustion of coal and their existing and potential uses.

Table 3-2: Estimated Electric Power Industry Emissions for Ohio

Emission type (units) 1996 1986 Percent change (1986-1996) SO2 (MST) 1.4 2.1 -33.3% CO2 (MST) 144.3 145.0 -0.5% NOx (MST) 0.57 0.53 7.5%

(Source: Energy Information Administration, 1996)

3.4 Coal-Fired Facilities

Coal-fired facilities in the United Stated can be divided into two categories – electric utilities, and non-utility power producers (Energy Information Administration, 1998a). In general, an electric utility is a corporation or legal entity that owns and/or operates facilities for the generation, transmission, distribution, or sale of electric energy primarily for use by the public. On the other hand, a non-utility power producer is a corporation or legal entity that owns power

23 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

generating capacity and is not an electric utility. Non-utility power producers include co- generators, small power producers, and other non-utility generators such as industrial boilers producing steam for heating.

The authors conducted a survey of thirty-three coal-fired facilities operational in the state of Ohio in 1998. Of these, twenty-seven were electric utility plants and six were non-utility power producers. A list of surveyed coal-fired facilities, their abbreviations as used in this report, ownership, and location information is presented in Table 3-3. Figure 3-2 shows the location of each coal-fired power plant in the state. Eleven coal-fired plants are located on or near the Ohio River, while seven are located on or near the shoreline of Lake Erie.

The quantity and quality (sulfur and ash content) of coals received at Ohio plants in 1997 are listed in Table 3-4. The source and quality of coals received at Ohio plants are given in Table 3- 5. The net quantity of coal received at Ohio plants (electric utility and non-utility power producers) was 53.6 MST. The average sulfur content of the coal was approximately 2% and the ash content was 11.5%. While Table 3-1 listed the aggregate coal quantity and quality for electric utility plants in the state for 1997, Table 3-4 contains detailed information on coal quantity and quality for electric utility and non-utility power producers. Plants which utilized coal with an average sulfur content higher than 3% include WHG, ZIM, PIC, GAV, ORR, SML, AST, and MDC, while those with less than 1% sulfur content were JMS, KIS, HUT, COH, LKS, BYS, CHM, and MCO. Table 3-5 shows that plants using Ohio coal had higher average sulfur contents than those importing coal from outside the state.

24 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 3-3: Ohio Coal-Fired Facilities Surveyed

25 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

0 10 20 30 40 50 kilometers JMS LAWRENCE

Note: Refer to Table 3-3 for plant name abbreviations (Source: CCP survey by authors)

Figure 3-2: Coal-Fired Power Plants in Ohio

26 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 3-4: Quantity and Quality of Coal Received at Ohio Plants - 1997

Plant Coal Average Sulfur Average Sulfur Average Ash designation Received, Content, 1997 Content, 1997 Content, 1997 1997 (% by weight) (pounds per (% by weight) (1000 ST) MM Btu)

WHG 737 5.06 4.37 15.16 CAR 4,066 1.91 1.57 11.58 MIF 3,034 1.07 0.89 12.31 ZIM 3,252 3.82 3.13 9.54 WCB 2,629 1.24 1.02 11.09 CON 4,235 2.73 2.31 8.97 PIC 180 3.41 2.97 10.26 JMS 6,058 0.83 0.72 14.36 KIS 1,716 0.63 0.52 13.72 HUT 352 0.75 0.6 11.36 DOV 44 2.2 3.42 8.87 COH 151 0.72 1.11 9.37 GAV 7,061 3.46 3.05 11.87 MUS 2,678 2.34 1.96 12.17 KYG 2,840 1.99 1.53 7.5 ORR 190 3.97 3.68 11.85 PNS 94 2.51 2.02 7.4 SML 49 4.03 10.98 SMR 28 2.16 7.86 AST 539 3.66 2.94 9.06 AVN 1,535 1.01 0.8 9.48 ELK 2,396 2.34 1.82 8.12 LKS 94 0.31 0.33 4.84 NLS 502 2.93 2.43 12.53 BRG 851 2.32 2.03 15.94 SMS 6,027 1.1 0.93 14.6 BYS 1,539 0.43 0.43 5.91 CHM 120 0.85 5.5 OSU 14 2.73 7.27 OUP 18 2.25 7.61 MCO 14 0.85 7.54 GPP 136 2.48 3.9 10.92 MDC 400 3.86 10.26 Total coal received, 1997 = 53.6 MST Average sulfur content, 1997 = 2.03 % by weight of coal Average sulfur content, 1997 = 1.70 pounds per MM Btu Average ash content, 1997 = 11.50 % by weight of coal

(Sources: Energy Information Administration, 1998c; CCP survey by authors)

27 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 3-5: Coal Source and Quality for Ohio Plants – 1997

Plant States (Ohio counties) from which coal received Average Sulfur Average Ash designation Content Content (% by weight) (% by weight)

WHG Ohio (Noble) 5.06 15.16 CAR Ohio (Belmont, Gallia, Jackson, Moroe, Vinton), Kentucky, West 1.91 11.58 Virginia, Wyoming MIF Ohio (Belmont, Harrison, Jackson, Jefferson, Lawrence, Monroe, 1.07 12.31 Vinton), Indiana, Kentucky, Pensylvannia, West Virginia

ZIM Ohio (Belmont, Harrison, Jefferson, Lawrence, Monroe, Vinton), 3.82 9.54 Kentucky, Pennsylvania, West Virginia WCB Ohio (Belmont, Harrison, Lawrence, Monroe, Vinton), Kentucky, 1.24 11.09 Pennsylvania, West Virginia CON Ohio (Belmont, Coshocton, Harrison, Holmes, Jefferson, Perry, 2.73 8.97 Tuscarawas) PIC Ohio (Perry) 3.41 10.26 JMS Kentucky, West Virginia 0.83 14.36 KIS Kentucky, West Virginia 0.63 13.72 HUT Kentucky, West Virginia 0.75 11.36 DOV Ohio (Tuscarawas) 2.2 8.87 COH Kentucky 0.72 9.37 GAV Ohio (Belmont, Gallia, Jackson, Meigs, Vinton) 3.46 11.87 MUS Ohio (Jefferson, Muskingum, Noble, Perry), West Virginia 2.34 12.17 KYG Ohio (Belmont, Jackson), Kentucky, Pennsylvania, Virginia, West 1.99 7.5 Virginia ORR Ohio (Holmes) 3.97 11.85 PNS Ohio (Columbiana) 2.51 7.4 SML Ohio 4.03 10.98 SMR Ohio (Tuscarawas) 2.16 7.86 AST Ohio (Belmont, Columbiana, Tuscarawas) 3.66 9.06 AVN Ohio (Columbiana), Kentucky, Pennsylvania, Virginia, West 1.01 9.48 Virginia, Wyoming ELK Ohio (Belmont, Columbiana, Tuscarawas), Pennsylvania, West 2.34 8.12 Virginia LKS Kentucky, Montana, Wyoming 0.31 4.84 NLS Ohio (Columbiana, Harrison, Mahoning, Tuscarawas), 2.93 12.53 Pennsylvania BRG Ohio (Belmont, Harrsion, Jefferson), Kentucky, Pennsylvania, 2.32 15.94 West Virginia SMS Ohio (Carrol, Harrison), Kentucky, Pennsylvania, West Virginia 1.1 14.6

BYS Kentucky, West Virginia, Wyoming 0.43 5.91 CHM Kentucky 0.85 5.5 OSU Ohio (Perry) 2.73 7.27 OUP Ohio (Jackson) 2.25 7.61 MCO Ohio, Kentucky 0.85 7.54 GPP Ohio (Columbiana) 2.48 10.92 MDC Ohio (Jackson, Vinton) 3.86 10.26

(Sources: Energy Information Administration, 1998c; CCP survey by authors)

28 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

4 PRODUCTION AND UTILIZATION OF CCPs

4.1 Introduction

A CCP survey of electric utility and non-utility power producer plants in Ohio (listed in Table 3-3) was conducted by the authors to evaluate the types and quantities of CCPs generated and utilized at each facility for 1997. The results of this survey, additional information on different types of uses obtained from the American Coal Ash Association, and the information collected from Energy Information Agency and United Stated Geological Survey, are presented in this chapter.

4.2 CCP Production

Coal-fired facilities operating within the state of Ohio generated approximately 9.23 million short tons (MST) of CCPs in 1997 (refer Table 4-1). This consisted of 4.76 MST of fly ash, 0.97 MST of bottom ash, 0.35 MST of boiler slag, 2.68 MST of FGD (on a dry weight basis), and 0.47 MST of mixtures of fly ash, bottom ash, boiler slag, and cenospheres. Electric utility plants accounted for more than 99% of all CCPs generated in the state, while non-utility power producers (CHM, OSU, OUP, MCO, GPP, and MDC) generated less than 1% of CCPs. Figure 4- 1 shows the amount of CCPs generated at each facility. It should be noted that FirstEnergy did not report survey response for individual plants, but instead provided aggregate information by combining the statistics from eight of its facilities. The amount of FGD generated at the Niles facility (NLS) was not provided and instead has been estimated by the authors to be 75,000 dry tons, based on the annual quantity of coal and limestone used by the plant, and the design sulfur content. A similar estimate has been made for the FGD generated at the Zimmer plant (ZIM). The Gavin plant (GAV) produced 25% of all CCPs and accounted for nearly 60% of FGD generated in the state. The largest generator of fly ash and bottom ash was the J.M. Stuart station (JMS), and the Muskingum River plant (MUS) generated 42% of all the boiler slag produced in the state. Some of the utilities reported CCP data by combining fly ash and bottom ash. Fly ash and bottom ash combined account for nearly 67% of CCP production, while FGD generated in the state was 29% of all CCPs produced in 1997 (refer Figure 4-2).

The state has five FGD generating facilities. Four of these facilities (ZIM, CON, GAV, and NLS) employ a wet scrubbing process, while the OSU plant generates a spray dryer ash. Table 4- 2 lists these plants, amount of FGD generated at each facility, the quantity of coal and lime/limestone used in 1997, and the design sulfur content for the scrubbers. Removal of SO2 from the flue gases at these five plants required approximately 0.73 MST of lime / limestone sorbent. This resulted in the generation of more than 2.6 MST (dry weight) of FGD. The NLS plant generates FGD gypsum, and the ZIM plant that currently produces stabilized FGD is expected to start generating FGD gypsum in year 2000. Figure 4-3 shows the different FGD generating plants across Ohio and the amount of FGD generated by each facility. The moisture content of wet FGD typically ranges from 30% to 60%. Hence, the amount of wet FGD

29 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

generated in the state for 1997 ranged between 3.4 MST and 4.2 MST, with an average annual production rate of approximately 3.8 MST per year.

Table 4-1: CCP Production - 1997

Plant Fly ash Bottom Boiler FGD Material Mixtures or CCP totals designation (1000 ST) ash slag (Dry 1000ST) others (1000ST) (1000 ST) (1000ST) (1000ST)

WHG 96 24 120 CAR 392 98 490 MIF 342 60 402 ZIM 313 55 750** 1118 WCB 382 67 449 CON 276 66 34 272 648 PIC 17 4 21 JMS 700 175 1.5 876.5 (Cenospheres) KIS 200 (FA+BA) 200 HUT 195 (FA+BA) 195 DOV 4.4 (FA+BA) 4.4 COH 10.6 3.5 14.1 GAV 625 156 1578 2359 MUS 235 35 145 415 KYG 98 121 219 ORR FA+BA - PNS 6.5 1.4 7.9 SML 6 (FA+BA+BS) 6 SMR 3.3 (FA+BA+BS) 3.3

AST, AVN, 1259 220 48 75** (NLS plant) 1602 ELK, LKS, NLS, BRG, SMS, BYS* CHM 11 (FA+BA) 11 OSU 5.4 (FA+BA+Dry 5.4 FGD) OUP 1.3 1.3 MCO 2.5 (FA+BA+BS) 2.5

GPP 12.6 2.2 14.8 MDC 49.2 (FA+BA) 49.2 Totals = 4764.7 968.4 348 2680.4 472.9 9234.4 * FirstEnergy reported aggregate numbers combining eight Ohio plants. The amount of FGD generated at the Niles (NLS) plant was not disclosed. ** Estimated quantity based on annual coal consumption, sorbent used, and design sulfur content.

(Source: CCP survey by authors)

30 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

PNS (7.9 kST) AST* BYS* ELK* MCO (2.5 kST) AVN* LKS*

NLS* GPP (14.8 kST)

SML ORR (6 kST) (not reported)

SMR (3.3 kST) SMS* DOV (4.4 kST) CON (648 kST) CAR (490 kST)

BRG* OSU HUT (5.4 kST) (195 kST) PIC (21 kST) MUS (415 kST) WHG COH (14.1 kST), (120 kST) CHM (11 kST) MDC OUP MIF (49.2 kST) (1.3 kST) (402 kST) GAV WCB (2359 kST) (449 kST)

KIS KYG ZIM (200 kST) (219 kST) 0 10 20 30 40 miles (1118 kST) 0 10 20 30 40 50 kilometers JMS (876.5 kST)

* FirstEnergy reported aggregate CCP production totals for eight plants (AST, AVN, ELK, LKS, NLS, BRG, SMS, BYS) as 1602 kST

(Source: CCP survey by authors)

Figure 4-1: CCP Production for Ohio Plants- 1997

31 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

FGD Material 29.0%

Fly Ash & Bottom Boiler Slag Ash 3.8% 67.2%

CCP Type Total CCP Production (1000 ST) Fly Ash & Bottom Ash 6206 Boiler Slag 348 FGD Material 2680.4

(Source: CCP survey by authors)

Figure 4-2: CCP Production – 1997

Table 4-2: FGD Material Production - 1997

Plant FGD material Dry/ Wet Quantity of Design sulfur Lime / designation generated FGD coal content (%) Limestone (Dry 1000ST) received sorbent used (1000 ST) (1000 ST)

ZIM 750 (estimated) Wet 3252 4.5 231 CON 272 Wet 4235 7.9 76.2 GAV 1578 Wet 7061 3.5 400.8 NLS 75 (estimated) Wet 502 3 24.1 OSU 5.4 (FGD+FA+BA) Dry 14 3 1.5 Totals = 2680.4 15064 733.6

(Sources: CCP survey by authors; Energy Information Administration, 1998c; United States Geological Survey)

32 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

NLS (75 kST)*

CON (272 kST)

OSU (5.4 kST)

GAV (1578 kST)

ZIM (750 kST)* 0 10 20 30 40 miles 0 10 20 30 40 50 kilometers

* Estimated FGD quantity

(Source: CCP survey by authors)

Figure 4-3: FGD Material Production (Dry Weight Basis) - 1997

33 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

4.3 CCP Utilization

Fly ash, bottom ash, boiler slag, and FGD are used in Ohio as raw materials for many highway, mine reclamation, manufacturing, agricultural, and other applications. Table 4-3 lists the amounts of CCPs utilized in Ohio in 1997. CCP types have been divided into five categories – fly ash, bottom ash, boiler slag, FGD, and mixtures or others. The “mixtures or others” category was created because several utilities reported utilization data by combining fly ash and bottom ash. Hence, the fly ash and bottom ash quantities were combined into a single category and the resulting data are presented for each plant in Table 4-4. The overall percent utilization rates for each of the Ohio plants are shown in Figure 4-4. Quantity of fly ash that was used in the production of landfilled stabilized FGD was excluded from utilization data, since the material was disposed in a landfill (as a mixture of fly ash and FGD filter cake) and not effectively utilized. The COH, CHM, and OUP plants generated small amounts of fly ash and bottom ash and reported utilizing all CCPs generated at these plants. The Miami Fort (MIF) plant of Cinergy reported the highest utilization rate (71.6%) among the large electric utility plants in Ohio. Plants with utilization rates ranging between 50% and 70% were WCB (59.5%), and PIC (52.4%). Facilities with percent utilization from 30% to 50% were CON (35.6%), and MUS (34.9%), and ZIM (32.9%). Plants with utilization rates between 10% and 30% were DOV (22.7%), PNS (17.7%), and KYG (15.1%). First Energy’s AST, AVN, ELK, LKS, NLS, BRG, SMS, and BYS plants had a combined utilization rate of 27.8%. Plants with 1% to 10% utilization rates were GAV (3.9%), CAR (3.0%), and JMS (1.5%). The WHG, KIS, HUT, SML, SMR, OSU, MCO, GPP, and MDC plants reported zero utilization rates.

Figure 4-5 shows the amount of fly ash and bottom ash, boiler slag, and FGD generated and used in the state of Ohio in 1997. Of the 6.2 MST tons of fly ash and bottom ash generated, 1.45 MST (23.4%) was utilized. Approximately 0.35 MST of boiler slag was generated, and 0.26 MST (74.7%) was used. Of the 2.68 MST of FGD generated in the state, 0.225 (8.4%) MST was utilized. Figure 4-6 shows the amount and percentage of types of CCPs used in the state in 1997. Of the total CCPs utilized, fly and bottom ash accounted for 75% of the use, and the rest by boiler slag (13.4%), and FGD (11.6%). Figures 4-7, 4-8, 4-9, and 4-10 show the percent use and disposal of fly ash and bottom ash, boiler slag, FGD, and all CCPs combined, respectively.

The various types of end uses of fly ash, bottom ash, boiler slag, and FGD in the state were also investigated. Data obtained from the American Coal Ash Association (ACAA) and collected from the CCP survey were combined to generate information on the estimated use of CCPs by applications types. The categorization of uses presented in Table 4-5 follows the ACAA format. Figures 4-11, 4-12, 4-13, 4-14 show the percentage use of each of these applications for fly ash and bottom ash, boiler slag, FGD, and all CCPs combined, respectively. For fly ash and bottom ash, over 40% of the use in Ohio was in cement/concrete/grout applications. Structural fills accounted for 32.5% of use. Other major uses included mining applications (9.8%), road construction (5.0%), and snow and ice control (4.8%). Minor uses included flowable fill (1.4%), agriculture (0.4%), mineral filler (0.2%), and other miscellaneous uses (3.4%). For boiler slag utilization, the majority of the use (85.9%) was for blasting grit and roofing granules. Other major boiler slag uses were structural fills (7.1%), and for snow and ice control (4.5%). For FGD material, major uses included wallboard industry consumption (33.3%), mining and reclamation

34 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

applications (24%), and miscellaneous uses (42.7%). Miscellaneous uses included FGD feeding and hay storage pads and material used in various research and field demonstration projects.

4.4 Comparison With National and Regional Data

The production and use of coal combustion products in Ohio were compared with ACAA Region 3 states (Illinois, Indiana, Kentucky, Michigan, Ohio, and Wisconsin), as well as the United States. ACAA Region 3 states include USPEPA Region 5 states and the state of Kentucky. Data for ACAA Region 3 and the United States were obtained from the American Coal Ash Association. Information for Ohio was collected through the CCP survey of Ohio coal-fired plants as summarized in Table 4-4. Table 4-6 shows the production and use of CCPs for Ohio, ACAA Region 3 and United States for 1997. Ohio generates about 8.8% of CCPs produced in the United States and of the total amount utilized across the nation, the state accounts for 6.6% use. Fly ash and bottom ash, boiler slag, and FGD production is 8%, 12.7%, and 10.6%, respectively, of the US national production. Fly ash and bottom ash, boiler slag, and FGD use in Ohio is 5.9%, 10.1%, and 10.3%, respectively, of the US national use. The Ohio CCP utilization rate of 21.0% is lower than the national utilization rate of 27.8% as well as the ACAA Region 3 utilization rate of 25.6%.

35 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 4-3: CCP Utilization - 1997

Plant Fly ash Bottom Boiler FGD Material Mixtures or others CCP totals designation (1000 ST) ash slag (Dry 1000ST) (1000 ST) (1000 ST) (1000ST) (1000ST)

WHG 0 CAR 1 13.7 14.7 MIF 288 (FA+BA) 288 ZIM 368 (FA+BA) 368 WCB 267 (FA+BA) 267 CON 9 38 34 150 231 PIC 7 4 11 JMS 12 0.8 (Cenospheres) 12.8 KIS 0 HUT 0 DOV 1 (FA+BA) 1 COH 10.6 3.5 14.1 GAV 92 92 MUS 145 145 KYG 33 33 ORR - PNS 1.4 1.4 SML 0 SMR 0 AST, AVN, 290 32 48 75 445 ELK, LKS, NLS, BRG, SMS, BYS* CHM 11 11 OSU 0 OUP 1.3 1.3 MCO 0 GPP 0 MDC 0 Totals = 317.6 197.9 260 225 935.8 1936.3

(Source: CCP survey by authors)

36 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 4-4: CCP Production and Use - 1997

Plant Fly ash & bottom ash Boiler slag FGD Material CCP total Percent designation (1000 ST) (1000ST) (Dry 1000 ST) (1000 ST) Uilization

(Source: CCP survey by authors)

37 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

PNS (17.7%) AST* BYS* ELK* MCO (0.0%) AVN* LKS*

NLS* GPP (0.0%)

SML ORR (0.0%) (not reported)

SMR SMS* (0.0%) DOV (22.7%) CON (35.6%) CAR (3.0%)

BRG* OSU (0.0%)

HUT PIC (52.4%) MUS (0.0%) (34.9%) WHG COH (100.0%), (0.0%) CHM (100.0%)

MDC OUP MIF (0.0%) (100.0%) (71.6%) WCB GAV (59.5%) (3.9%) N KYG Z IM KIS (0.0%) (15.1%) (32.9%) 0 10 20 30 40 miles

0 10 20 30 40 50 kilometers JMS (1.5%)

* FirstEnergy reported aggregate CCP utilization percentage for eight plants (AST, AVN, ELK, LKS, NL S, BRG, SMS, BYS) as 27.8%

(Source: CCP survey by authors)

Figure 4-4: CCP Percent Utilization by Plant- 1997

38 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

8000

6000 Production

4000 Use

2000 1000 Short Tons

0 Fly Ash & Boiler Slag FGD Bottom Ash Material

(Source: CCP survey by authors)

Figure 4-5: CCP Production and Use - 1997

FGD Material 11.6%

Boiler Slag 13.4%

Fly Ash & Bottom Ash 75.0%

CCP Type Total CCP Use (1000 ST) Fly Ash & Bottom Ash 1451.3 Boiler Slag 260 FGD Material 225

(Source: CCP survey by authors)

Figure 4-6: CCP Use - 1997

39 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Used 23.4%

Disposed 76.6%

(Source: CCP survey by authors)

Figure 4-7: Fly Ash and Bottom Ash Used vs. Disposed – 1997

Disposed 25.3%

Used 74.7%

(Source: CCP survey by authors)

Figure 4-8: Boiler Slag Used vs. Disposed – 1997

40 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Used 8.4%

Disposed 91.6%

(Source: CCP survey by authors)

Figure 4-9: FGD Material Used vs. Disposed – 1997

Used 21.0%

Disposed 79.0%

(Source: CCP survey by authors)

Figure 4-10: All CCPs Used vs. Disposed – 1997

41 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 4-5: Estimated CCP Utilization by Type of Use – 1997

(Sources: CCP survey by authors; American Coal Ash Association)

Fly ash & bottom Boiler slag FGD Material All CCPs ash Type of Use Quantity Percent Quantity Percent Quantity Percent Quantity Percent (1000 ST) used (1000 ST) used (1000 ST) used (1000 ST) used

Miscellaneous/Other Flowable Fill Agriculture 3.4% 1.4% 0.4% Mineral Filler Snow and Ice Control 0.2% 4.8%

Road Base/Subbase 5.0% Cement/Concrete/Grout Mining Applications 42.6% 9.8%

Structural Fills 32.5%

(Sources: CCP survey by authors; American Coal Ash Association) Figure 4-11: Fly Ash and Bottom Ash Applications – 1997

42 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Cement/Concrete/ Grout 1.8% Snow and Ice Control 4.5% Miscellaneous/Other 0.6%

Structural Fills 7.1%

Blasting Grit/Roofing Granules 85.9%

(Sources: CCP survey by authors; American Coal Ash Association)

Figure 4-12: Boiler Slag Applications – 1997

Mining Applications 24.0%

Miscellaneous/Other 42.7%

Wallboard 33.3%

(Sources: CCP survey by authors; American Coal Ash Association)

Figure 4-13: FGD Material Applications – 1997

43 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Road Base/Subbase 3.8% Flowable Fill Wallboard 1.0% 3.9%

Agriculture 0.3% Snow and Ice Control Mineral Filler 4.2% 0.2%

Cement/Concrete/ Miscellaneous/ Other Grout 7.6% 32.2%

Mining Applications 10.1%

Structural Fills Blasting Grit/Roofing 25.3% Granules 11.5%

(Sources: CCP survey by authors; American Coal Ash Association)

Figure 4-14: All CCP Applications – 1997

Table 4-6: Comparison of CCP Production and Use for Ohio, Regional States, and the United States – 1997

Fly ash & bottom Boiler slag FGD material CCP total Region ash (1000 ST) (1000 ST) (1000 ST) (1000 ST) Production Use Production Use Production Use Production Use

Ohio 6,206 1,451 348 260 2,680 225 9,234 1,936 23.4% 74.7% 8.4% 21.0%

ACAA Region 3* 20,948 6,207 1,494 1,334 10,888 981 33,330 8,522 29.6% 89.3% 9.0% 25.6%

United States 77,169 24,414 2,742 2,579 25,163 2,183 105,074 29,176 31.6% 94.1% 8.7% 27.8%

*: Illinois, Indiana, Kentucky, Michigan, Ohio, and Wisconsin (Region 5 of USEPA and Kentucky)

(Sources: CCP survey by authors; American Coal Ash Association)

44 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

5 HIGHWAY / ROAD APPLICATIONS

5.1 Introduction

CCPs can be used for a wide range of transportation related construction applications. In the past several years, the use of fly ash, bottom ash, boiler slag, and FGD in highway construction and maintenance across the United States has been steadily increasing. Guidelines for the use of fly ash, bottom ash, boiler slag, and FGD for highway applications have been presented by American Coal Ash Association (1995), and the Federal Highway Administration (1997). The existing and potential highway uses of CCPs can be classified into five broad categories, concrete applications, embankments / structural fills, stabilized road bases / sub-bases, flowable fills, and subsidence control (refer to Table 5-1). Class C and Class F fly ashes are commonly used as an admixture in concrete. The use of fly ash and bottom ash for constructing highway embankment and structural fills is gaining momentum. Fly ash is also used in flowable fills, and for stabilization of road bases. FGD can be used in highway embankment construction, stabilization of road bases, and as a component in flowable fill. The potential use of some CCPs, particularly fly ash and FGD material, in remediating subsidence under highways by underground injection of CCP based grouts is discussed in Section 6.6.1. Specific ASTM, ACI, and other standard testing, design, and construction publications for use of CCPs for many uses, including highway related projects, are presented in Appendix F.

Currently, Ohio Department of Transportation (ODOT) specifications allow for limited use of fly ash (loss on ignition less than 3 percent) in portland cement concrete applications between April 1 and October 15, and the use of fly ash in low strength mortar backfill with some proportion adjustments. Use of bottom ash and fly ash in embankments, and lime-fly ash-aggregate (LFA) stabilized road bases is not addressed in current specifications, but is allowed on a project- specific review basis. It should be noted that ODOT establishes the technical specifications which are followed by ODOT, county, municipality, and township engineers in the construction and maintenance of highways and roads across the state.

5.2 Embankment / Structural Fill

CCPs offer several advantages over conventional virgin soils for the construction of highway embankments and structural fills including: · Availability of material in bulk; · Higher slope stability factors of safety compared to naturally occurring soils; · Suitability for construction on low bearing strength soils because of its lower unit weight compared to soil; and · High shear strength to unit weight ratio resulting in ideal placement under foundations · Availability of free draining materials such as bottom ash.

Several fly ash and bottom ash embankments have been constructed in the state. One of the first fly ash projects in the state was constructed in 1979-80 and involved the placement of nearly

45 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

5,700 tons of conditioned fly ash from the Burger Station (BRG) as a backfill for a bridge abutment at the intersection of Route 7 and Route 148 near Powhatan Point (Patelunas, 1988). The ash was placed in 12-inch lifts and compacted to 95 percent of Standard Proctor density. The height of the fill was 27 feet and the width at the base was approximately 80 feet. The construction of the project was carried out from Fall, 1979 through Spring, 1980. No significant settlement was reported to have been observed at the site (Patelunas, 1988). In 1981, fly ash was used to construct a 30,000 ton highway embankment for Interstate 480 in Avon, near Cleveland. A 27,000 ton fly ash embankment was constructed in Gallia county on US Route 35 in 1983. Since then several fly ash and bottom ash embankments have been constructed in the state. The use of Pressurized Fluidized Bed Combustor (PFBC) ash, a type of dry FGD material, was investigated on two demonstration projects by OSU. The SR 541 project, built in 1993, used PFBC material from AEP’s Tidd power plant to repair a failing embankment by building an FGD buttress approximately 100 feet long, 40 feet wide, and 13 to 16 feet in height. It was observed that the FGD yielded excellent strengths over a wide moisture content range. Another embankment using PFBC material from the same power plant was constructed in 1994 to repair a portion of SR 83 near Cumberland. The ash was compacted in much thicker lifts than typically specified for soils. Details on the SR 541 and SR 83 projects can be found in Appendix C. It should be noted that the Tidd PFBC plant was a demonstration project that has been completed and CCPs are not currently available from the Tidd facility.

Costs associated with the SR 83 repairs using PFBC ash were $67,000. ODOT District 5 personnel estimated the cost of conventional repairs to range between $90,000 to $110,000. Therefore, savings from this project were estimated to be between 25% to 40%. The SR 541 FGD repair cost approximately $77,000. The cost breakdown for the project is shown in Figure 5-1. It can be seen that the largest cost item was equipment, which accounted for 58% of the cost. Labor and truck activity costs were 23% and 16% respectively. The material costs were very low (about 3%) because the material was delivered free of cost to the site. The estimated cost of construction of the project using suitable onsite soil was estimated to be in the range of $105,000 to $120,000, and hence the savings for the project were estimated to be from 26% to 36%.

The use of fly ash as a structural or engineered fill material for constructing building and parking lot pads is also common in Ohio. First Energy recently used about 5,000 tons of fly ash from Avon Lake and East Lake plants as an engineered fill material in the construction of its new Northern Division Headquarters in Cleveland, Ohio. A total of 15,000 tons of fly ash from these plants was also used in multiple ways (structural fill, soil drying agent, soil stabilization agent) in the construction of two Home Depot stores in the Cleveland area. In 1998, Cinergy provided over 300,000 tons of fly ash for five structural fill projects. During 1999, eight different sites near Cincinnati used approximately 410,000 tons of fly ash generated by Cinergy plants. These included building pads for Noramco barge facility, East Fork Trace Properties, Three Rivers Development, Northern Kentucky University facilities, storage lockers; parking lots at Northern Kentucky University, Robinson Trucking; and ball fields for Milford High School. Over 650,000 tons of Cinergy fly ash are projected to be used for structural fill applications in and around the greater Cincinnati area in 2000.

46 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 5-1: Existing and Potential Uses of CCPs for Highway Applications

CCP Type Application FGD Fly Ash Bottom Ash Boiler Slag Material Portland cement concrete Cementious material X

Asphalt concrete Hot mix aggregate X X Cold mix aggregate X X Seal Coat aggregate X Mineral Filler X

Embankments & Structural Fill X X X

Stabilized Base/Subbase Aggregate X X Cementious material X X

Flowable Fill Cementious material X X

Subsidence Control Grout X X

Materials ($2,145) 2.8% Truck Activity ($12,000) 15.6%

Labor Equipment ($18,000) ($45,000) 23.3% 58.3%

Total Estimated Project Cost = $77,145

(Source: Nodjomian, 1994) Figure 5-1: Cost Estimates for SR 541 Repairs Using PFBC Material

47 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

5.2.1 Life Cycle Assessment Analysis

Life Cycle Assessment (LCA) is an analytical tool that can be used to quantify (and optionally to interpret) the environmental flows over the entire life cycle of a product or process (Society for Environmental Toxicology and Chemistry, 1993; ISO/DIS, 1996). The environmental flows to and from the environment include air emissions, water effluents, solid waste, and consumption / depletion of energy and other resources. LCA analysis incorporates natural resources acquisition, materials production, intermediate products manufacturing, assembly manufacturing, use, and end-of-life stages which often include multiple parallel paths such as recycling, incineration, and landfilling. LCA is recognized as a tool to assess the environmental performance of products and/or industrial systems.

A study published by the American Coal Ash Association, 1997, quantitatively addressed whether it is environmentally justifiable to promote the use of fly ash in structural fills. The study employed the LCA approach and included three main components: inventory (material and energy inputs and outputs), impact assessment (flows compiled into environmental impacts such as natural resource depletion, global warning potential, etc.,), and improvement analysis/interpretation (evaluation of needs and opportunities to address goal and scope of project). The study concluded that air emissions, solid waste, raw materials consumed, and energy consumed were generally better for a fly ash structural fill than for a soil fill option. The report showed that, by comparison to natural soil, fly ash used in structural fills is always better with respect to raw materials consumed and landfill space conserved. Fly ash allowed for greater haul distance, for the same or lower air emissions, in comparison to soil. In addition, fly ash can be compacted in lift thickness greater than conventional soil resulting is reduced compactive effort or energy consumed by compaction equipment. The report asserted that water effluent effects were inconclusive due to incomplete or highly variable data. The report pointed out that the leachability of both fly ash and soil should be addressed on a case-by-case basis.

5.3 Flowable Fill

Flowable fill is defined by the American Concrete Institute (1994) as a self-compacting cementious material that is in a flowable condition at time of placement, and has a compressive strength of 1,200 psi or less at 28 days. Most flowable fill mixes are designed to have strengths of 150 to 200 psi for ease of excavation at a later time. Flowable fill typically consists of a mixture of fine aggregate or filler, cementious material, and water. Flowable fills are also commonly known by several other terms, including Controlled Density Fill (CDF), Controlled Low-Strength Material (CLSM), unshrinkable fill, flowable mortar, plastic-soil cement slurry, K- Krete, Flash Fill, etc. The performance criteria for flowable fills is outlined in ACI 229R-94 (American Concrete Institute, 1994). The material can be used to fill all voids in an irregular excavation and hard-to-reach places such as under and around pipes in trenches. The material is self-leveling, does not need compaction and hardens in a couple of hours after placement. The material can be placed in freezing temperatures, requires no compactive effort, and improves job safety and labor costs because no workers are needed in the trench being filled. A significant benefit of flowable fill is that it does not need compaction and this results in reduced excavation

48 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

and equipment costs. Typically, most ready mix concrete producers can provide flowable fills using fly ash, since they use the ash as an admixture in concrete. In the state of Ohio, many members of the Ohio Ready Mix Concrete Association provide fly ash enriched flowable fill material. The Ohio Concrete magazine published by the Association provides regular updates on flowable fill projects around the state. Approximately 20,000 tons of fly ash was used in the state for flowable fill applications in 1997. This represents only 1.4% of fly ash use in the state. However, with increasing acceptance of flowable fill by contractors, the percent use of these materials is expected to increase.

Flash Fill developed by American Electric Power is a unique type of fly ash based flowable fill because it contains no cement and yet achieves strength early enough to allow paving operations to be undertaken quickly (American Electric Power, undated). Flash Fill typically has 4-hour, 28- day, and 91-day unconfined compressive strengths of 30 psi, 75 psi, and less than 150 psi, respectively. The resistance to penetration at 4 hours is approximately 400 psi. Field application of Flash Fill to a typical 4 feet x 2 feet x 6 inch trench was investigated by American Electric Power. The material supported the weight of a light-duty pickup truck at 2 hours after placement, and at 4 hours after placement it carried a 27,500lb truck with minor surface deformations. Flash Fill is typically used for filling street excavations, bridge abutments, voids left during building demolition, inaccessible washout areas under streets, and sidewalks, and abandoned tunnel and storage tanks.

Many FGD materials have low unit weight and good shear strength characteristics and hence hold promise for flowable fill applications. Research conducted at The Ohio State University (Lee, 1998; Lee et al., 1999) has investigated the potential of using two types of FGD (spray dryer and wet stabilized FGD) in flowable fill as a replacement for conventional fly ash. Several design mixes were considered. The mixes consisted of varying amounts of FGD, cement, lime, and water. The mixes were tested in the laboratory for flowability, unit weight, moisture content, unconfined compressive strength, erodibility, set-time, penetration, and long-term strength characteristics. Tests were conducted for up to 90 days of curing. The FGD flowable fill without any additives was observed to be as good as a regular (normal set) flowable fill in terms of placeability, unconfined compressive strength, and diggability. FGD flowable fill with additives and admixtures compared favorably with the characteristics of conventional quick set-flowable fills. There remain potential concerns including anchoring of pipes, confinement prior to initial set of material, and corrosion of pipes. Procedures to alleviate these concerns need further laboratory and field investigations.

5.4 Stabilized Base / Sub-Base

Good quality road bases and sub-bases can be prepared by mixing appropriate amounts of fly ash, lime and aggregates. These road bases are referred to as lime-fly ash-aggregate (LFA) or Pozzolanic-Stabilized Mixture (PSM) bases. Fly ash content in LFA base mixtures typically ranges from 12 to 14 percent. The lime content varies from 3 to 5 percent and may be replaced by lime kiln dust and portland cement. The advantages of using LFA bases include high base strength and durability, lowered cost, autogenous healing, increased efficiency, and ease of placement with conventional equipment. The strength development depends on curing time and

49 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

temperature and hence a degree-day curing scheme is typically used. Under this concept, the curing degree days necessary is the product of days cured and curing temperatures in excess of 40O F. The American Coal Ash Association has published the Flexible Pavement Manual (American Coal Ash Association, 1991) to guide pavement design engineers, materials engineers, and construction managers in the design and construction of flexible pavement systems in which the PSM serves as the base layer.

The Ohio Department of Transportation initially used PSM base layers in 1960 on SR 727 in Clermont County (Turner, 1976). The project involved about 2 ½ miles of flexible pavement underlain with a variety of base materials including a PSM mixture of fly ash, aggregate, and lime. The performance evaluation of the PSM base indicated that the surface of the road was in excellent condition and that samples at the base were very hard. However, compressive strengths were not reported. From 1970 to 1985, nearly a million tons of LFA road bases were placed in ten municipal and commercial projects in and around the City of Toledo (Transportation Research Board, 1994b; Federal Highway Administration, 1997). An economic analysis of using LFA road bases in Illinois, Ohio and Pennsylvania was conducted by Hunt et al. (1981). Table 5-2 lists the cost comparison for three types of pavement alternatives for Ohio, including bituminous, aggregate, and LFA bases. The total cost was divided into the cost of the wearing surface and the base course. The LFA base course (9.5 inches thick) is 35% cheaper than a bituminous base (8.4 inches thick), and 20% cheaper than an aggregate base (16.1 inches thick). The thickness of the wearing surface recommended by ODOT for the bituminous, LFA, and aggregate was 3”, 4”, and 5”, and this results in higher wearing course costs for the aggregate and LFA pavements compared to bituminous base pavement. Including the wearing surface and base course costs in the total cost, the LFA base pavement was found to be least expensive and the aggregate base pavement was the most expensive. The LFA base pavement was 20% cheaper than a pavement using an aggregate, and 15% cheaper than a bituminous base pavement. The cost of asphalt has increased significantly since 1979 which has resulted in a decrease in the cost effectiveness of LFA bases to about 5% to 10%. The use of compacted dry and wet FGD material in the construction of road base and sub-base holds promise but needs further investigations.

Table 5-2: Cost Comparison for Pavements with Different Types of Road Bases in Ohio, 1979

Cost of pavement ($ per square yard) Bituminous base Lime-fly ash- aggregate Aggregate base pavement (LFA) base pavement pavement Wearing surface $4.52 $6.03 $7.53 Base course $11.19 $7.29 $9.08 Total cost $15.71 $13.32 $16.61 Least expensive Most expensive

(Source: Hunt et al., 1981)

50 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

5.5 Use of Fly Ash in Concrete

Fly ash is routinely used as a pozzolanic admixture in portland cement concrete. Fly ash added to concrete can replace energy intensive materials such as cement. Cement replacement may vary from 15% to 20%. The weight of fly ash (Class C or Class F) to be added to the mix ranges between 1 to 1.5 times the weight of cement removed from the mix. The advantages of using fly ash in concrete include increased strength gain, lower permeability, improved workability, increased resistance to alkali-silica reactivity and sulfate attack, reduced bleeding, and reduced heat of hydration. A reduction in early strength of fly ash concrete has been observed, but the long-term design strength of fly ash concrete is typically higher than 100% portland cement concrete mixes (American Coal Ash Association, 1995). The mix design of fly ash concrete follows the ACI 211.4R-93 procedures (American Concrete Institute, 1996).

The Ohio plants which have fly ash certification from ODOT for cement and concrete applications include Gavin Plant, W.H. Gorusch Station, Avon Lake Plant, Eastlake Station Unit #5, Miami Fort Station Unit #7 and #8, and W.H. Sammis Plant. Sampling of ODOT certified fly ash is required at the rate of one sample (half gallon) for every 600 tons minimum per month or project. Non-certified ash and partial plant inspection ash, when used, has to be sampled every 100 tons or fraction thereof from cars or trucks.

At the present time, approximately 620,000 tons of fly ash are used annually in Ohio for cement, concrete, and grout applications. This represents the largest use market for fly ash in the state (43% of all fly ash uses). As an example, in 1998 Cinergy provided over 100,000 tons of fly ash to one (of many) ready mix company, and in 1999 the same company used over 90,000 tons of fly ash for concrete applications. Cinergy’s projected fly ash sale to just this one ready mix company is expected to be over 120,000 tons in 2000.

The current use of approximately 620,000 tons of fly ash as an admixture in concrete and replacing cement, results in a significant reduction in CO2 emissions from the state. The manufacture of one ton of portland cement results in about one ton CO2 emissions to the atmosphere due to calcination of limestone and burning of fossil fuels for cement clinker production (Stewart and Kalyoncu, 1999). However, for each ton of manufactured cement replaced by fly ash, a ton of CO2 emission is avoided. Consequently, it is expected that more than 500,000 tons of CO2 emission reductions are realized in the state of Ohio every year due to the use of pozzolanic fly ash as an admixture in concrete/cement/grout applications.

5.5.1 Effect of NOx Emissions on Fly Ash Use

The NOx rules proposed by USEPA will result in an increase in the Loss on Ignition (LOI) and chemical content (particularly ammonia) of some fly ashes generated in the state of Ohio. The increased carbon and ammonia contents of the ash will have a detrimental effect on the properties of fly ash and its marketing in the state. A 1998 survey conducted by the American Coal Ash Association reported that out of 20 responding coal-fired generating facilities from Ohio, 19 are expected to be affected by the proposed NOx guidelines. At the national level, 46% of all responding coal-fired units expect to be affected by the NOx control measures. Utilities

51 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

surveyed across the nation report a potential loss of 2.4 million tons of fly ash use for pozzolan markets and an additional 1.75 million tons loss of fly ash for non-pozzolan markets. It is expected that $39 million ash marketing revenue will be lost across the nation along with an additional $34 million for disposal of the unusable ash. Only two units across the nation plan to install benefaction equipment to process the affected ash.

American Electric Power, which has 8 coal fired plants in the state out of 19 in the Midwest, was reported to have drawn up a budget of $1.2 billion to install new equipment at its coal-fired power plants to reduce NOx emissions (Columbus Dispatch, April 23, 1999). However, a stay was issued on the proposed NOx rules by the U.S. Court of Appeals for District of Columbia on May 25, 1999 until the court rules on an appeal from Midwestern states. A ruling is not expected till the year 2000. American Electric Power later stated that it was not going to make a large financial obligation until emission control requirements were known (Columbus Dispatch, May 27, 1999). Although scientific opinion on the effectiveness of the proposed NOx emission reductions is divided, it is envisaged that some sort of NOx control and or other emission control rules will be implemented by USEPA and OEPA in the next 5 years.

5.6 Manufactured FGD Aggregate

Synthetic aggregates made of sulfite-rich FGD and Class F fly ash can be an economic alternative to conventional natural aggregates for various types of construction applications particularly, high volume road construction aggregates. In 1997, the total production of aggregates in Ohio was more than 140 million tons at a total value of over $600 million dollars (Wolfe, M., 1998). Of these, approximately 26 million tons were used for road construction and resurfacing, asphaltic concrete, dimension stone, construction stone, and lightweight aggregates. The Transportation Research Board (1994b) reported a significant shortage of aggregates for the eastern half of the state. Two of the major sulfite FGD generating facilities in the state (CON and GAV) are located in this region.

CONSOL has been investigating the potential use of synthetic FGD aggregate for several years (CONSOL Energy News, 1999). The process involves mixing of sulfite filter cake with Class F fly ash and subsequent pelletization and curing in a specially designed temperature vessel (United Stated Department of Energy Project Facts, 1999). As a part of a bench-scale project sponsored by the Ohio Coal Development Office, a 1.5-inch thick test patch of asphalt paving material made of manufactured FGD aggregate meeting AASHTO’s M-283 specifications for Class A road aggregates, was constructed in Warren, Ohio in October 1998. The patch was 75 feet long and 11 feet wide. The coarse aggregate in the asphalt mix was prepared by mixing equal parts by weight of FGD aggregate and natural stone. An adjacent control test patch was constructed using only natural coarse aggregates. With funding from USDOE and OCDO, CONSOL is continuing and expanding upon their previous research and demonstration achievements and is in the process of planning the construction and operation of a 500 pound per hour pilot plant at CONSOL’s Research and Development facility in Library, Pennsylvania. The FGD aggregate to be generated by CONSOL is expected to be crushed to meet the coarse aggregate size requirements of AASHTO M-283 as well as to provide the angularity required by several states. The fines obtained from the crushing process can be recycled or may be used as a

52 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

replacement for sand in many applications. Recently CONSOL obtained co-funding from OCDO to investigate the use of Gavin FGD in the generation of synthetic manufactured aggregate.

5.7 Distribution and Maintenance of Highways in Ohio

The state has a total of nearly 113,500 miles of highways and roads that need regular maintenance. In addition, there are about 240 miles of turnpike in the state. In order to understand the scope of highway construction and maintenance work in Ohio, road mile statistics for each county were obtained from ODOT. The road miles for each county were classified as interstate, US route, state route, county road, township road, municipal road, and turnpike (Table 5-3). ODOT is generally responsible for approximately 19,000 miles of Ohio roads (i.e., 17% of road miles in the state). The county road mileage for most counties exceeds the ODOT total mileage. The majority of the roads are in local townships (35%), counties (26%), and municipalities (21%). The maintenance of these county, township, and municipal roads totaling approximately 94,000 miles, is not done by ODOT, but is carried out by local counties, townships, and municipalities on tight budgets.

A report published by the County Engineers Association of Ohio, Ohio’s County Highways 2003, estimates that out of 29,477 county highway road miles, only 31% meet or exceed the 20- foot minimum road width benchmark for driving and passing safety. (County Engineers Association of Ohio, 1997). This report also concludes that of the 26,848 bridges under county maintenance jurisdiction, more than 11,000 are 50 years old or older. The generally accepted life expectancy of a bridge in Ohio is 50 years. Approximately 4,000 are structurally deficient, and more than 8,000 structurally qualify for replacement or rehabilitation. Resurfacing of county roads is currently averaging 17 years statewide, whereas recommended resurfacing period is 10 years. The cost of widening the county roads to 20 feet width in the next 20 years, resurfacing roads every 10 years, and replacing and rehabilitating qualified county bridges in the next 10 years is expected to cost approximately $287 million per year. At the present time, the total monetary resources available to the counties on an annual basis is $116 million. The shortfall of over $171 million will result in non-completion of a majority of the maintenance and replacement projects. Counties can save a significant portion of the dollars available to them and use these for the repair of other projects that need attention by accommodating recycled materials (such as CCPs) in their design and construction procedures. The estimated cost of maintaining an average mile of road depends mainly on the type of road and whether it is in a rural or urban area. Table 5-4 lists the average cost per mile of maintaining different types of roads in the US (Deller and Walzer, 1997). The estimated cost savings for highway applications range from 5% to 40% as discussed in Sections 5.2 – 5.6. A moderate 10% cost savings for Ohio counties could result in at least $10 million per year savings for county maintenance operations. Assuming the savings will be in proportion to highway miles, the estimated savings for ODOT maintained roads could be $6 million per year (excluding savings from new construction incorporating CCPs). The dollar savings for townships and municipalities may be as much as $13 million and $8 million per year, respectively. The total potential savings for road maintenance in Ohio using CCPs is estimated to be approximately $37 million per year.

53 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 5-3: Highway and Road Miles in Ohio Counties

ODOT County IR US SR County Township Municipal State Total Turnpike Total Adams 0.00 29.31 186.83 216.14 382.20 398.69 57.10 1,054.13 0.00 Allen 23.18 24.17 136.86 184.21 338.49 520.58 242.98 1,286.26 0.00 Ashland 16.14 70.52 172.08 258.74 283.80 407.07 107.76 1,057.37 0.00 Ashtabula 28.69 85.76 250.11 364.56 354.40 630.76 237.67 1,587.39 0.00 Athens 0.00 65.34 147.42 212.76 369.51 519.58 115.28 1,217.13 0.00 Auglaize 12.52 29.20 169.64 211.36 351.41 319.83 110.09 992.69 0.00 Belmont 33.66 32.01 216.78 282.45 307.79 720.45 144.79 1,455.48 0.00 Brown 0.00 88.91 118.98 207.89 347.90 428.13 56.34 1,040.26 0.00 Butler 11.25 46.45 173.13 230.83 267.52 643.33 514.17 1,655.85 0.00 Carroll 0.00 0.00 152.50 152.50 306.96 419.24 33.48 912.18 0.00 Champaign 0.00 44.76 165.19 209.95 241.65 340.40 69.11 861.11 0.00 Clark 30.67 57.90 100.23 188.80 302.96 418.78 287.70 1,198.24 0.00 Clermont 13.88 45.10 208.11 267.09 382.65 572.43 76.13 1,298.30 0.00 Clinton 15.33 48.60 141.81 205.74 267.24 288.82 71.54 833.34 0.00 Columbiana 0.00 50.46 252.25 302.71 170.14 869.43 225.73 1,568.01 0.00 Coshocton 0.00 33.59 180.41 214.00 351.13 622.29 80.70 1,268.12 0.00 Crawford 0.00 21.49 177.77 199.26 223.08 442.91 129.09 994.34 0.00 Cuyahoga 113.17 107.46 232.20 452.83 22.40 15.43 3,337.57 3,828.23 18.90 Darke 0.00 50.43 213.23 263.66 520.09 538.81 126.45 1,449.01 0.00 Defiance 0.00 31.54 132.18 163.72 328.05 432.82 76.81 1,001.40 0.00 Delaware 17.23 68.08 125.01 210.32 334.61 450.77 107.65 1,103.35 0.00 Erie 0.00 41.92 114.03 155.95 142.94 255.69 157.04 711.62 26.30 Fairfield 2.38 49.60 143.22 195.20 353.10 561.81 186.40 1,296.51 0.00 Fayette 14.65 68.71 85.82 169.18 305.64 207.98 56.49 739.29 0.00 Franklin 117.62 116.85 128.87 363.34 326.52 340.79 2,387.94 3,418.59 0.00 Fulton 0.00 56.67 84.65 141.32 361.55 386.95 78.66 968.48 26.10 Gallia 0.00 17.87 180.91 198.78 455.71 357.25 23.92 1,035.66 0.00 Geauga 0.00 56.59 137.64 194.23 228.76 553.56 37.45 1,014.00 0.00 Greene 21.75 82.36 68.35 172.46 320.26 324.20 421.69 1,238.61 0.00 Guernsey 51.94 39.59 153.79 245.32 409.78 600.92 90.25 1,346.27 0.00 Hamilton 95.95 118.39 84.31 298.65 504.74 570.34 1,398.18 2,771.91 0.00 Hancock 25.23 60.88 157.66 243.77 431.04 537.41 202.13 1,414.35 0.00 Hardin 0.00 21.81 154.21 176.02 372.19 367.04 84.53 999.78 0.00 Harrison 0.00 55.23 110.45 165.68 259.65 414.05 46.50 885.88 0.00 Henry 0.00 42.83 133.65 176.48 390.75 423.72 79.58 1,070.53 0.00 Highland 0.00 56.30 204.00 260.30 391.77 447.05 57.58 1,156.70 0.00 Hocking 0.00 18.93 149.15 168.08 212.15 413.59 36.19 830.01 0.00 Holmes 0.00 37.17 137.23 174.40 249.87 565.31 21.08 1,010.66 0.00 Huron 0.00 69.78 157.90 227.68 222.94 491.51 126.10 1,068.23 0.00 Jackson 0.00 27.23 141.48 168.71 296.59 370.71 80.40 916.41 0.00 Jefferson 0.00 18.95 153.65 172.60 261.78 455.76 196.91 1,087.05 0.00 Knox 0.00 58.63 139.66 198.29 400.50 621.09 97.75 1,317.63 0.00 Lake 30.96 40.64 135.34 206.94 152.29 191.89 465.95 1,017.07 0.00

(Source: Ohio Department of Transportation – Office of Technical Services: Roadway Information)

54 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 5-3: Highway and Road Miles in Ohio Counties (continued)

ODOT County IR US SR County Township Municipal State Total Turnpike Total Lawrence 0.00 22.62 166.56 189.18 374.79 362.51 92.96 1,019.44 0.00 Licking 29.42 50.78 186.52 266.72 412.98 707.13 363.30 1,750.13 0.00 Logan 0.00 52.12 182.50 234.62 371.51 345.10 104.53 1,055.76 0.00 Lorain 16.02 46.96 222.79 285.77 269.75 316.38 634.52 1,506.42 20.80 Lucas 34.06 65.19 114.11 213.36 287.29 325.19 1,301.28 2,127.12 14.60 Madison 27.26 45.60 123.53 196.39 343.55 127.43 50.66 718.03 0.00 Mahoning 30.83 59.12 174.53 264.48 492.85 475.70 578.88 1,811.91 24.30 Marion 0.00 19.97 180.92 200.89 391.39 265.63 138.44 996.35 0.00 Medina 45.29 39.06 163.62 247.97 332.51 391.47 157.91 1,129.86 0.00 Meigs 0.00 14.79 175.24 190.03 250.94 502.07 46.27 989.31 0.00 Mercer 0.00 44.77 166.05 210.82 390.87 445.37 80.70 1,127.76 0.00 Miami 19.96 28.31 153.60 201.87 433.91 268.38 228.01 1,132.17 0.00 Monroe 0.00 0.00 213.55 213.55 371.82 537.00 25.81 1,148.18 0.00 Montgomery 55.41 41.44 123.37 220.22 320.03 498.05 1,900.53 2,938.83 0.00 Morgan 0.00 0.00 189.04 189.04 346.55 389.03 18.71 943.33 0.00 Morrow 19.93 25.71 130.86 176.50 381.64 337.09 29.18 924.41 0.00 Muskingum 27.33 39.81 199.78 266.92 520.31 700.11 164.07 1,651.41 0.00 Noble 18.92 0.00 197.26 216.18 268.11 464.05 16.66 965.00 0.00 Ottawa 0.00 0.00 138.17 138.17 162.83 305.37 68.09 674.46 4.70 Paulding 0.00 33.57 134.36 167.93 324.95 495.56 50.35 1,038.79 0.00 Perry 0.00 14.27 171.39 185.66 319.74 374.41 69.27 949.08 0.00 Pickaway 3.16 54.76 138.79 196.71 226.58 401.31 74.24 898.84 0.00 Pike 0.00 16.28 134.09 150.37 319.63 256.05 32.40 758.45 0.00 Portage 23.32 23.22 203.59 250.13 371.80 383.72 241.67 1,247.32 20.40 Preble 17.67 60.84 113.30 191.81 255.28 426.48 64.26 937.83 0.00 Putnam 0.00 31.16 178.02 209.18 333.06 618.18 85.91 1,246.33 0.00 Richland 20.64 37.32 203.99 261.95 350.43 581.83 304.45 1,498.66 0.00 Ross 0.00 98.01 121.90 219.91 389.20 491.34 99.63 1,200.08 0.00 Sandusky 0.00 62.68 112.44 175.12 306.97 438.81 146.27 1,067.17 27.30 Scioto 0.00 60.91 140.56 201.47 415.89 507.28 93.77 1,218.41 0.00 Seneca 0.00 45.44 177.04 222.48 373.03 634.82 130.40 1,360.73 0.00 Shelby 20.55 0.00 144.20 164.75 388.74 328.36 107.06 988.91 0.00 Stark 18.54 72.42 232.00 322.96 422.39 1,269.79 829.19 2,844.33 0.00 Summit 76.73 5.82 185.10 267.65 224.30 359.60 1,822.36 2,673.91 13.60 Trumbull 12.33 32.15 301.88 346.36 462.15 625.29 408.99 1,842.79 10.80 Tuscarawas 34.97 38.57 140.91 214.45 468.09 605.28 260.27 1,548.09 0.00 Union 0.00 50.76 145.78 196.54 469.67 150.06 55.81 872.08 0.00 Van 0.00 70.56 96.68 167.24 267.94 517.91 94.25 1,047.34 0.00 Vinton 0.00 30.27 127.46 157.73 197.58 320.79 21.36 697.46 0.00 Warren 34.46 44.51 138.03 217.00 270.31 394.87 190.81 1,072.99 0.00 Washington 17.59 10.61 243.83 272.03 341.34 860.14 108.03 1,581.54 0.00 Wayne 7.10 57.56 187.03 251.69 496.53 562.94 222.33 1,533.49 0.00 Williams 0.00 80.57 104.98 185.55 396.90 344.71 93.68 1,020.84 22.30 Wood 43.46 61.32 206.41 311.19 245.54 984.79 284.94 1,826.46 11.10 Wyandot 0.00 45.75 152.09 197.84 333.23 304.30 51.80 887.17 0.00 Total 1,331.15 3,923.59 14,046.54 19,301.28 29,199.40 40,460.85 24,484.87 113,446.40 241.20

(Source: Ohio Department of Transportation – Office of Technical Services: Roadway Information)

55 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 5-4: Estimated Cost of Maintenance Per Mile of Road, 1994

Maintenance cost (dollar/mile) Surface type All Nonmetro Metro counties Gravel $7,103 $11,366 $7,986 Low bituminous $3,514 $3,971 $3,642 High bituminous $4,189 $5,275 $4,579 Paved $7,319 $29,401 $16,579 Concrete $2,873 $16,240 $7,748 (Source: Deller and Walzer, 1997)

5.8 Existing Consumption of Natural Resources

Highway construction and maintenance, and other construction activities in Ohio annually consume over 58 million tons of natural resources, which are mined in the state (Wolfe, 1998). A detailed description of the various types of natural resources mined in Ohio in 1997 and their cost estimate, and the various highway and related construction uses for each of these materials is shown in Table 5-5. The predominant mined natural resources used in highway construction and repair are crushed broken limestone and dolomite, sand, and gravel. Smaller amounts of crushed stone, clay, and shale are also used. The two main uses of these natural resources are for asphaltic concrete and road construction / resurfacing. Over 28 million tons of crushed limestone and dolomite and 10 million tons of gravel were used in 1997 for highway construction and repair. Details on the production and consumption of each of these materials and their specific uses for each county within Ohio can be obtained from Wolfe, 1998. The data presented in Table 5-5 shows that large quantities for natural materials that are mined in the state are consumed in highway and other construction related activities. If used properly, CCPs hold a great potential to displace some of these natural materials in the highway and construction industry across Ohio.

56 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 5-5: Consumption of Mined Natural Resources by Highway Construction and Other Construction Related Activities

Type of natural Amount % of use of total County details resource Application utilized annual available in (Average price in used for (million tons in production Wolfe, 1998 1997) 1997) Crushed and Asphaltic concrete 4.08 5% Yes broken limestone and dolomite Road construction/ 28.68 37% Yes ($4.16 per ton) resurfacing Asphaltic concrete 4.14 14% Yes Sand ($4.26 per ton) Road construction/ 7.34 25% Yes resurfacing Asphaltic concrete 3.00 10% Yes Gravel ($4.26 per ton) Road construction/ 10.06 35% Yes resurfacing Crushed sandstone Aggregate 0.32 13% Yes ($14.50 per ton) Construction 0.24 10% Yes

Clay Construction 0.05 3% Yes ($5.74 per ton) Lightweight 0.24 8% Yes Shale Aggregate ($1.82 per ton) Construction 0.03 1% Yes

(Source: Wolfe, 1998)

57 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

5.9 Ohio Department of Transportation Specifications

5.9.1 Introduction

Because ODOT specifications are generally followed in county, township, and municipal projects, they can have a significant impact on promoting or discouraging the utilization of CCPs across the state. Current ODOT specifications (Ohio Department of Transportation, 1997) only allow limited use of fly ash in portland cement concrete and low strength mortar backfill.

5.9.2 Fly Ash use in Portland Cement Concrete

ODOT Specification # 499 (Ohio Department of Transportation, 1997) details the use of fly ash as an admixture in portland cement concrete. Fly ash to be used for cement replacement must meet ODOT Specification # 705.13, which allows for the use of Class C or Class F fly ash in accordance with ASTM C 618 but with a maximum loss on ignition (LOI) of 3 percent. Up to 15 percent of the cement may be replaced by an equivalent weight of fly ash. The use of fly ash with expansive Type K cement is not permitted. The use of fly ash also is not permitted for high early strength concrete. The specification limits the use of fly ash concrete from April 1 to October 15 unless otherwise approved by the Director of ODOT. The proportioning of fly ash concrete is based on developing an average compressive strength at 28 days of 28 MPa (4000 psi) for Class C, and 21 MPa (3000 psi) for Class F type concrete. Only one source of fly ash is permitted to be used in any one structure. The storage of ash is required to be waterproof.

5.9.3 Fly Ash Use in Low Strength Mortar Backfill

Class C and Class F fly ashes are permitted under ODOT Specification # 613 (Ohio Department of Transportation, 1997) for flowable fill applications to backfill conduits and other appropriate trenches. The recommended mixture of fly ash, cement, and/or sand is expected to obtain a 28 day unconfined compressive strength less than 689 kPa (100 psi). The fly ash used must meet ODOT Specification # 705.13. Class F fly ash ranging from 250 to 1500 pounds per cubic yard of mortar is allowed for different types of mixes. The flowable fill must be placed within 2.5 hours after water is added to the mixture. Placement of other fill material on top of flowable fill may commence soon after surface water is gone or as directed by the ODOT Engineer.

5.9.4 Modifications to ODOT Specifications

The current ODOT specifications limit the use CCPs to fly ash in portland cement concrete and flowable fill applications. A review of available data on freeze-thaw effects may allow the restrictions on the construction season to be relaxed. Year-round construction should result in a significant increase in use of fly ash in portland cement concrete in the state. Concerns with the amount of unburned carbon in fly ash have limited the concrete and flowable fill applications to

58 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ashes with no more than 3 percent LOI, although AASHTO and ASTM specifications allow LOI up to 5% and 6%, respectively. The proposed NOx control rules when implemented in the state will have the largest impact on concrete applications due to increased LOI. Detailed studies are needed to evaluate the effect of NOx control on LOI of fly ashes, develop procedures to overcome high carbon problems, and incorporate them into ODOT specifications.

The existing ODOT specifications do not cover most of the potential uses of fly ash, bottom ash, boiler slag, and FGD in highway related applications. In order to effect a positive impact on the use of CCPs in the state of Ohio, changes in ODOT specifications are needed. It is recommended that ODOT develop additional specifications for CCP uses identified in Table 5-6. A specification for the use of non-toxic fly ash and bottom ash in embankment construction is being prepared by ODOT under supplemental Specification # 880 for recycled materials. The March 2000 draft of the specification is attached as Appendix D. Specifications for use of FGD materials (particularly dry FGD) in structural fill / embankment applications also need to be encouraged. This and all other engineered uses of FGD will require appropriate prior authorization from OEPA. The use of fly ash, bottom ash, boiler slag, and FGD in asphalt concrete needs to be addressed. Several Midwest states specify the use of CCPs in hot and cold mix asphalt concrete. While lime-fly ash stabilized base and subbase applications have been implemented in the state, a standard specification is lacking. It is recommend that language addressing fly ash and FGD stabilization be added to the ODOT Specification items # 205 (Lime Modified Soils), and # 206 (Lime Soil Stabilized Subgrade). Research conducted at The Ohio State University has shown the potential for using wet and dry FGD material as a replacement for fly ash in flowable fill applications (Lee, 1998; Lee et al., 1999). Based on the results of testing in progress and future demonstration projects, ODOT may also want to consider reviewing the flowable fill specification to allow for the use of FGD. Fly ash based grouts have been used by ODOT to remediate underground mine subsidence under highways (refer to Section 6.6.1). The use of fly ash and FGD for underground injection to remediate subsidence due to abandoned underground mines below highways may require modifications to ODOT specifications to allow for increased use of CCP based grouts.

59 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 5-6: Recommended Changes to ODOT Specifications

CCP Type Application Fly Ash Bottom Ash Boiler Slag FGD Material Portland cement concrete Cementious material X

Asphalt concrete Hot mix aggregate * * Cold mix aggregate * * Seal Coat aggregate * Mineral Filler *

Embankments & Structural Fill * * *

Stabilized Base/Subbase Aggregate * * Cementious material * *

Flowable Fill Cementious material X *

Subsidence Control Grout * *

X: Existing ODOT specifications. Modifications should be investigated. *: ODOT specifications need to be developed.

60 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

6 MINE RECLAMATION USES

6.1 Introduction

Ohio has over 200,000 acres of unreclaimed strip mined lands which can contribute as much as 250 tons per acre per year of sediments into streams and lakes. It is estimated that over 500 miles of streams in the state are choked with sediments from strip mined lands. In addition, about 350 acres of acid pits, over 600 miles of streams impacted by acid mine drainage (with 250 miles having no fish), and over 4,000 abandoned underground mines with 600,000 underlying acres are known to exist in the state. The reclamation of many of these areas is imperative to improve the quality of the environment of impacted regions, particularly in east and southeast Ohio. FGD and fly ash can be used in mine reclamation applications for the abatement of acid mine drainage (AMD), reduction of offsite sedimentation, and subsidence control. Many coal-fired power plants are located in the vicinity of existing and abandoned mines. In many instances, CCPs can be used to reclaim these mined areas and improve significantly the environmental problems caused by these unreclaimed areas.

6.2 Abandoned Mine Land Program Statistics and FGD Use Potential

The potential use of FGD in reclamation of abandoned mine lands was evaluated using the Abandoned Mine Land Inventory System (AMLIS) database. The U.S. Department of Interior, Office of Surface Mining (OSM)-Reclamation and Enforcement Department has developed this database to inventory abandoned mine land problems. The AMLIS database contains cumulative information regarding costs, quantities, and types of problems/hazards for AML programs across the United States.

Two queries of the AMLIS database were carried out to help determine how much reclamation has been completed in Ohio, how many problems remain unreclaimed, and which of the unreclaimed problems have the potential for FGD utilization during reclamation. During the AMLIS queries, the items considered relevant to the search were the number of problem areas, problem types, size, and costs for all Abandoned Mine Land (AML) program areas and types of mining. The information was sorted and printed by county and by problem type according to whether the problem had been unfunded, funded but not reclaimed, or completed. An unfunded problem is one that has been documented by a state employee as a mining related problem or hazard and recorded in the AMLIS database. An unreclaimed problem is moved from unfunded to funded when it is placed in a federal grant as a project. The life of each federal grant is typically three years. Upon project reclamation, the problem is moved from funded to completed.

Problems potentially amenable to solution using FGD were extracted from the AMLIS data search on a county basis. The complete list is presented in Appendix E. Reclamation cost data obtained from the AMLIS database was complied by county for AML projects and the results are shown in Table 6-1. More than 70% of the estimated cost of Ohio projects inventoried under AMLIS are unreclaimed (i.e., unfunded or funded but not reclaimed). Over $209 million (1998

61 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

dollars) of reclamation work is still needed in the State of Ohio. In a typical year, Ohio Department of Natural Resources – Division of Mines and Reclamation (DMR) funds approximately $2.5 million of reclamation. The cost distribution for reclamation needs for Ohio is shown in Figure 6-1. Table 6-1 and Figure 6-2 also show, by county, the funding required to solve the AMLIS documented problems that have the potential for FGD utilization. These figures only reflect potential usage. Over $100 million worth of reclamation work to be done on AML has potential for FGD utilization. This information is provided to show that there are extensive reclamation needs in Ohio and that a substantial portion of AML problems have the potential to be reclaimed by using FGD as part of the solution.

The AMLIS database information was further refined on a county basis for the areas to be reclaimed and categorized under potential FGD uses such as gob piles, spoil areas, dangerous piles and embankments, and pits (refer Table 6-2). Approximately 22,000 acres of spoil areas, 800 acres of gob piles, 350 acres of pits, and 29 acres of dangerous piles and embankments inventoried in AMLIS may need reclamation. Applications rates for reclamation of each of these problem areas were chosen with due consideration to past estimates and projects recently completed. Table 6-3 indicates that approximately 8.3 MST of FGD may have potential of being used for AMLIS inventoried problems. A majority of the potential FGD use by DMR is expected to be in the reclamation of gob piles and spoil areas in Perry, Meigs, Jackson, Noble, Gallia, Belmont, and Athens counties.

6.3 DMR Related Reclamation Projects

A number of surface and underground reclamation related projects have been carried out in Ohio in cooperation and consultation with the Ohio Department of Natural Resource – Division of Mines and Reclamation (DMR). Detailed description of some of these projects is presented below.

6.3.1. Fleming Abandoned Mined Land Site

The Fleming Site is located in Franklin Township of Tuscarawas County. This site consisted of approximately 45 acres of unreclaimed spoil and 5 acres of refuse. The primary project concerns were downstream flooding and offsite sedimentation at an estimated rate of 450 tons/acre/year.

In the summer of 1994, test plots were constructed at the site to study the response of the surface water, spoil, and vegetative cover to the addition of agricultural limestone, PFBC ash, or a combination of yard compost and PFBC ash. Local concerns were raised about potentially elevated dioxin levels, but testing of the FGD materials applied at the site showed dioxin levels lower than normal or baseline levels for environmental samples. During the ash application, regulated trace elements remained below drinking water standards in the surface water (arsenic levels, however were high enough to warrant further study). The surface water had a pH of approximately 7. The concentration of boron in the leachate was below phytotoxic levels, and all of the plots provided good vegetative cover.

62 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 6-1: Cost Data for Ohio AML Projects Reported in AMLIS (1998 dollars)

Cost of all Cost of all Cost of projects Projects needing Unfunded and projects constructed within pads (funded construction funded costs for (constructed, projects and unfunded) percentage of projects that have County funded, needing construction total cost FGD utilization unfunded) potential

($) ($) ($) (%) ($) Athens 10,214,356.00 2,646,088.00 7,568,268.00 74 5,727,462.00 Belmont 25,748,955.00 8,567,819.00 17,181,136.00 67 2,232,228.00 Carroll 2,929,151.00 148,809.00 2,780,342.00 95 607,342.00 Columbiana 3,136,633.00 815,923.00 2,320,710.00 74 1,356,867.00 Coshocton 2,764,272.00 303,784.00 2,460,488.00 89 1,232,801.00 Gallia 35,011,496.00 11,861,201.00 23,150,295.00 66 8,102,376.00 Guernsey 1,985,288.00 948,750.00 1,036,538.00 52 639,809.00 Harrison 6,600,418.00 1,744,472.00 4,855,946.00 74 2,821,149.00 Hocking 3,155,483.00 368,248.00 2,787,235.00 88 2,787,233.00 Holmes 208,725.00 208,725.00 0.00 0 0.00 Jackson 14,213,903.00 2,004,624.00 12,209,279.00 86 9,644,661.00 Jefferson 11,521,471.00 5,053,474.00 6,467,997.00 56 3,992,495.00 Lawrence 5,986,518.00 3,329,134.00 2,657,384.00 44 1,392,728.00 Mahoning 3,156,396.00 1,877,557.00 1,278,839.00 41 1,140,839.00 Medina 93,603.00 0.00 93,603.00 100 40,000.00 Meigs 32,253,938.00 10,615,891.00 21,638,047.00 67 13,529,269.00 Morgan 633,056.00 462,030.00 171,026.00 27 106,683.00 Muskingham 5,304,085.00 666,549.00 4,637,536.00 87 2,361,612.00 Noble 46,815,119.00 7,770,523.00 39,044,596.00 83 19,378,559.00 Perry 37,046,972.00 7,819,756.00 29,227,216.00 79 18,126,690.00 Portage 1,771,867.00 50,086.00 1,721,781.00 97 1,313,200.00 Scioto 220,586.00 220,586.00 0.00 0 0.00 Stark 7,336,102.00 1,876,545.00 5,459,557.00 74 4,635,057.00 Summit 77,698.00 13,448.00 64,250.00 83 64,250.00 Trumbull 2,422,110.00 398,175.00 2,023,935.00 84 2,010,160.00 Tuscarawas 16,246,719.00 3,565,681.00 12,681,038.00 78 6,301,455.00 Vinton 3,204,538.00 850,829.00 2,353,709.00 73 1,593,500.00 Washington 5,089,363.00 1,212,913.00 3,876,450.00 76 792,850.00 Wayne 122,469.00 91,969.00 30,500.00 25 28,500.00 Total 285,271,290.00 75,493,589.00 209,777,701.00 74 111,959,775.00

(Source: AMLIS database) Note: FGD cost data has been evaluated by the authors

63 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ASHTABULA

LAKE WILLIAMS FULTON LUCAS OTTAWA WOOD GEAUGA TRUMBULL HENRY CUYAHOGA DEFIANCE SANDUSKY ERIE LORAIN PORTAGE HURON SUMMIT SENECA PAULDING MEDINA PUTNAM HANCOCK MAHONING

VAN WERT WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN MERCER MARION AUGLAIZE HOLMES CARROLL

LOGAN KNOX SHELBY UNION MORROW COSHOCTON HARRISON DARKE DELAWARE

HAMILTON HIGHLAND PIKE MEIGS JACKSON

GALLIA BROWN ADAMS SCIOTO

0 10 20 30 40 miles

0 10 20 30 40 50 kilometers LAWRENCE

Less than $500,000 $3,000,000 to $10,000,000 $500,000 to $2,000,000 $10,000,000 to $20,000,000

$2,000,000 to $3,000,000 $20,000,000 to $30,000,000

Greater than $30,000,000

(Source: AMLIS database)

Figure 6-1: Funded and Unfunded AML Problems in Ohio (1998 dollars)

64 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ASHTABULA

LAKE WILLIAMS FULTON LUCAS OTTAWA WOOD GEAUGA TRUMBULL HENRY CUYAHOGA DEFIANCE SANDUSKY ERIE LORAIN PORTAGE HURON SUMMIT SENECA PAULDING MEDINA PUTNAM HANCOCK MAHONING

VAN WERT WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN MERCER MARION AUGLAIZE HOLMES CARROLL

LOGAN KNOX SHELBY UNION MORROW COSHOCTON HARRISON DARKE DELAWARE

HAMILTON HIGHLAND PIKE MEIGS JACKSON

GALLIA BROWN ADAMS SCIOTO

0 10 20 30 40 miles

0 10 20 30 40 50 kilometers LAWRENCE

Less than $100,000 $2,000,000 to $5,000,000

$100,000 to $1,000,000 $5,000,000 to $10,000,000

$1,000,000 to $2,000,000 $10,000,000 to $20,000,000

(Source: AMLIS database) Note: FGD cost data has been evaluated by the authors

Figure 6-2: Funded and Unfunded AML Problems in Ohio (1998 dollars) with Potential for FGD Utilization

65 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 6-2: Potential FGD Use Areas for Uncompleted AML Reclamation Projects

Dangerous Piles County Gobs Spoil Area & Pits Embankments (Acres) (Acres) (Acres) (Acres) Athens 92.0 769.0 0.0 30.0 Belmont 141.0 350.0 3.0 4.0 Carroll 0.0 70.0 1.0 10.0 Columbiana 39.0 20.0 0.0 0.0 Coshocton 39.0 0.0 0.0 0.0 Gallia 0.0 3,028.0 0.0 0.0 Guernsey 4.0 15.0 0.0 0.0 Harrison 44.0 1,300.0 0.0 0.0 Hocking 47.0 464.0 0.0 0.0 Jackson 54.5 2,111.0 0.0 140.0 Jefferson 59.0 7.0 0.0 1.0 Lawrence 0.0 374.2 0.0 0.0 Mahoning 0.0 322.0 0.0 5.0 Medina 0.0 0.0 0.0 0.0 Meigs 29.0 3,479.0 0.0 0.0 Morgan 30.0 0.0 0.0 0.0 Muskingham 106.0 325.0 25.0 0.0 Noble 3.0 2,770.0 0.0 0.0 Perry 53.0 3,872.4 0.0 150.0 Portage 0.0 0.0 0.0 0.0 Stark 0.0 1,062.0 0.0 0.0 Summit 0.0 0.0 0.0 0.0 Trumbull 0.0 0.0 0.0 0.0 Tuscarawas 41.0 827.5 0.0 9.5 Vinton 16.0 378.0 0.0 0.0 Washington 0.0 449.0 0.0 0.0 Wayne 0.0 0.0 0.0 0.0 Total 797.5 21,993.1 29.0 349.5

(Source: AMLIS database) Note: FGD data has been evaluated by the authors

66 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 6-3: Potential FGD Tonnage for Uncompleted AML Projects

Dangerous Piles & Total for each County Gobs Spoil Area Pits Embankments county

Assumed FGD application rates: Gobs: 3500 tons/acre Spoil Area: 240 tons/acre Dangerous piles & embankments: 500 tons/acre Pits: 500 tons/acre

(Source: AMLIS database) Note: FGD data has been evaluated by the authors

67 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

6.3.2 Broken Aro Project

The Broken Aro Mine site is located approximately seven miles west of Coshocton, Ohio on State Route 541. The site is part of the abandoned Davis Mine #1 and #2 complex. The current landowner is DMR. AMD drains from the underground mine and discharges into Simmons Run.

R & F Coal Company wanted to remine the Broken Aro site without inheriting the clean-up responsibility for the AMD problem. Remining is usually an attractive prospect to DMR since the mining takes place in a previously disturbed area, and DMR would benefit from the post- mining reclamation by R & F Coal Company. In response to R & F Coal’s remining request, AEP and DMR proposed placing a continuous underground FGD mine seal along the highwall where the AMD seeps were present. The intent was to trap the water in the mine, resulting in complete inundation within the complex and limiting the oxygen availability, thus reducing the production of AMD.

During remining, R & F Coal exposed the coal seam and multiple portals along the highwall. AEP’s Conesville plant provided the 26,000 tons of stabilized FGD required to construct the seal in the highwall pit and fill any portals encountered along the length of the highwall. A backhoe and a dozer were used to excavate the overburden and place the FGD in 4-foot uncompacted lifts. Any material compaction was due to the weight of the construction equipment. The first lift covered the coal seam and the second lift ensured inundation of the mine complex. After the seal was constructed, the highwall was backfilled with spoil material. Construction of the FGD seal was completed during the summer of 1997. R & F Coal recovered a total of 18,900 short tons of coal during remining. The performance of the underground FGD seal is currently being monitored by the Ohio Research Institute for Transportation and the Environment Center for Geotechnical and Environmental Research, Ohio University.

Sampling data through July 1998 reflects an increase in the water level within the mine complex. In general, the water levels are 8-10 feet above the pre-mining levels and approximately 15 feet above the dewatered levels in the mine. There have not been significant changes in the water quality in the mine complex or surface waters. The site has developed a few seeps that are being monitored to determine what affect they will have on the long-term success of the project.

6.3.3 Roberts-Dawson Underground Injection Project

The American Electric Power’s Roberts-Dawson Mine is located approximately 1.5 miles south- southwest of the town of Wills Creek on the border of Coshocton and Muskingum counties. The mine is approximately forty years old and covers approximately 14.6 acres. The mine operated in the mid-1950s, during which approximately 2 million cubic feet of coal was removed from it. Later the mine came under the ownership of AEP. AMD from the Roberts-Dawson Mine drains from the underground workings and discharges into Wills Creek. The reclamation project involved injecting high and low-strength FGD grout into the mine voids to inundate the mine complex, reducing the availability of oxygen, and abating AMD production.

68 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Construction began October 1997 and was completed by January 1998. FGD grout was mixed at the AEP’s Conesville Plant and transported to the site in dump trucks where a contractor injected the grout into the underground mine complex. Over 23,700 cubic yards of grout were injected through 318 vertical drilled grout holes and the site is currently being monitored. The project site is being monitored by American Electric Power and The Ohio State University.

6.3.4 Rehoboth Phase 1 Reclamation Project

The Rehoboth Phase 1 Reclamation Project site is a 65-acre gob pile located southeast of the intersection of State Route 345 and County Road 48, just south of the Village of Rehoboth and approximately 1.5 miles north of New Lexington. The site has an extensive history that includes contour strip mining, underground mining, coal tipple operations with a railroad load-out, coal preparation/wash plant operations, portland cement manufacturing and storage, explosives manufacturing and testing, and fertilizer manufacturing. This extensive use of the land has left an abandoned mine site that contains many environmental, health and safety issues.

Erosion was the primary concern associated with the Rehoboth site. Studies have shown that the Rehoboth site contributes over 2,000 tons/acre/year of sediments to an unnamed tributary of Rush Creek that passes through the site. In recent years, State Route 345, adjacent farmland and cemetery have frequently experienced flooding during storm events. The primary sediment source was determined to be the unreclaimed gob pile which was left from surface mining operations. The Rehoboth site is also a significant source of acid mine drainage. The pyrite and sulfur in the mineral substrate are responsible for the formation and subsequent leaching of AMD from the site.

The primary objective of the reclamation project was to control flooding at State Route 345 by regrading and vegetating the gob pile. A secondary objective was the elimination of AMD effluent from the site. In 1994, DMR hired a consulting company to incorporate the two project objectives into a design for the Phase 1 site. The use of FGD was included in the design. The final design included constructing a sediment pond using a two-foot thick compacted layer of FGD as a liner. After pond construction, the 43.1 acre gob pile was regraded to a slope no steeper than 5:1 (horizontal : vertical). This was followed by a two-foot thick layer of Conesville FGD, which was placed over the gob within 10 days from the time of production of FGD. The low permeability FGD cap was included in the design to keep runoff from percolating into the regraded spoil material. Then a two-foot thick layer of buffer material consisting of a mixture of fifty-percent coal refuse and fifty-percent FGD was placed over the cap. This buffer zone was designed to protect the FGD cap from freeze-thaw and to help provide a loose rooting medium for vegetation. The design also required nine inches of resoil over the buffer to provide the proper nutrients for successful vegetation growth. The resoil was comprised of a mixture of four inches of aged FGD, four inches of spoil, and one inch of cured yard waste compost. The final component of the design was revegetating the entire site.

Construction proceeded from August 1997 to October 1998. Over 250,000 tons of wet FGD were used. The FGD was supplied by the Conesville plant, Monday through Friday, at an average of over 1,500 tons per delivery day. The contractor, Trans-Ash, used typical pond construction

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equipment. The pond was shaped using dozers, and the FGD liner was placed in two 12-inch lifts, compacted with a smooth drum vibratory roller. After the pond construction, the contractor used dozers to perform the earthwork and regrade the gob pile in preparation for FGD placement. The FGD cap was placed over the gob in one two-foot lift as soon as the earthwork was completed. There were no compaction requirements for the FGD cap. The two-foot buffer material was placed over the cap by alternating six inches of coal refuse with six inches of FGD. A disc plow was used to mix the coal refuse and FGD after placing the first foot of buffer and again after the final foot was placed. A disc plow was also used to mix the resoil material (mixture of four inches of FGD, one inch of yard waste, and four inches of spoil).

DMR and AEP are currently monitoring the site. The FGD pond liner and cap are performing effectively. To date, vegetative growth over the cap has been limited. Possible reasons for poor germination of seeds could be the drought which followed the seeding of the site, quality of seeding used, and elevated levels of Boron and soluble salts. DMR will continue to monitor the growth and perform soil testing to determine why the site has not realized the expected vegetation growth. According to laboratory and field tests by AEP and The Ohio State University, wet FGD is an effective amendment for revegetation of hyper-acidic coal refuse. AEP is continuing a water quality sampling program that started at the beginning of the Phase 1 construction.

6.3.5 Rock Run Reclamation Project

The Rock Run Reclamation site is located immediately west of County Road 41, approximately 1.5 miles north of New Straitsville in Perry County. Along the eastern bank of Rock Run was a gob pile approximately sixty feet high. The gob pile filled a valley, covering approximately fourteen acres of the original valley floor. Water entered the gob pile through two tributaries and from an abandoned underground mine. The mine drainage had a pH of 3.29 and the water seeping from the toe of the gob pile and discharging into Rock Run had a pH of 2.77.

DMR partnered with USDA-Forest Service and Monday Creek Restoration Project/Rural Action, Inc. to reclaim the Rock Run site by reducing the discharge of acidic water and offsite sedimentation. The final scope of the Rock Run Reclamation project included re-contouring the coal refuse pile and the construction of a five acre, two foot FGD cap over the regraded refuse using FGD from Conesville power plant. The low permeability cap was constructed to eliminate percolation of surface water into the regraded coal refuse, reducing AMD production. Project construction began during the Summer of 1998 and was completed in Fall of 1999. Approximately 15,000 tons of stabilized FGD material was utilized for the reclamation of the Rock Run gob pile.

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6.4 FGD Utilization Cost Benefits for AML Programs

6.4.1 Introduction

Cost saving is usually the most attractive reason for using FGD in reclamation project construction. In some cases, conventional materials may not be available and by process of elimination, FGD may be the best or only material available as a substitute. When FGD is the only material available, a cost analysis does not seem relevant. However, in this section the cost savings realized when making a choice between available conventional materials and FGD utilization are reviewed and discussed. For this cost comparison, the Rehoboth and Rock Run projects were selected. The cost analysis presented in this section does not include the cost of FGD transportation to the site since FGD material was delivered to the project site by the generator for both the reclamation projects. Only items that included FGD were incorporated into the analysis since other construction items were not dependent on FGD application.

6.4.2 Rehoboth Phase 1 Reclamation Project

Cost comparison data for the Rehoboth Phase 1 project are presented in Table 6-4. The data presented as Rehoboth Phase 1 are actual construction costs for the project. Alternative 1 and Alternative 2 were designed to meet the project objectives of reducing off-site sedimentation and AMD production, and reflect the two most likely alternatives to FGD utilization. These figures were obtained by using cost data from similar projects located in the same geographical area.

The information presented for Rehoboth Phase 1 was taken from DMR construction documents. An outline of the Phase 1 construction can be found in the previous section. In summary, a non- compacted two-foot FGD seal was placed over the regraded gob pile and a 2 foot compacted FGD liner was constructed in the sediment pond. For resoil, a 2 foot buffer of 50% FGD and 50% spoil was placed over the FGD seal followed by a 9 inch layer comprised of a mixture of 4 inches of FGD, 4 inches of mineral spoil, and 1 inch of yard compost.

Alternative 1 requires placing 1 foot of compacted clay in the sediment pond and over the gob pile to form a seal. The cost for the compacted clay includes the cost of purchasing the clay and the cost for labor and materials required for construction. To ensure an adequate rooting zone, Alternative 1 includes 1 foot of resoil material over the entire site. On-site and local (within ¼ mile) borrow is available. The resoil costs also include incorporating lime into the resoil material at the rate of 25 tons per acre. The lime quantity is an estimate that reflects a typical incorporation rate for borrows in the same geographical area. Actual testing would be required to determine the lime requirement for borrow material.

Alternative 2 was designed to eliminate off-site sedimentation but will not reduce AMD production as effectively as the Rehoboth Phase 1 design or Alternative 1. Alternative 2 includes placing a 2-foot layer of compacted, limed spoil over the gob pile. With proper compaction, the 2-foot layer of spoil will reduce infiltration into the gob pile, resulting in less AMD production.

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Thick, compacted spoil is not an alternative for the pond since it does not provide a low permeability seal so the pond still requires the 1-foot clay seal detailed in Alternative 1. Only 8 inches of limed resoil would be required for this design.

It can be observed from Table 6-4 that the use of FGD for Rehoboth Phase 1 project cost approximately $382,000, while traditional Alternative 1 which would remediate AMD and offsite sedimentation would have an estimated cost of $925,000. This results in saving of approximately $8,350 per acre of gob pile reclaimed. Further, it can be observed that Alternative 2, which would remediate sedimentation problems but not resolve the AMD production effectively, would still cost 29% more than FGD use.

6.4.3 Rock Run Reclamation Project

An analysis of the costs of the Rock Run Reclamation Project is presented in Table 6-5. The data shows that the 2-foot FGD seal over the 5-acre gob pile was the most economical solution. Alternative 1 includes replacing the FGD seal with 1 foot of clay liner and increasing the resoil from 8 inches to 1 foot. Alternative 2, with 2 feet of spoil, would only reduce AMD production, which may not meet the project objective. Using FGD for Rock Run project will cost approximately $25,000, while Alternative I with traditional materials, will cost approximately $88,000. Estimated saving were calculated as to be approximately $12,600 per acre of gob pile reclaimed. Alternative 2, which would remediate the sedimentation problem only, would cost 52% more than FGD use.

6.4.4 Potential Savings for Gob Pile Reclamation

In many cases, conventional construction materials like clay and resoil material may not be available and by the process of elimination FGD may be the best or the only suitable material to be used for reclamation. For projects in which FGD and conventional materials both are available and being considered, a cost comparison is necessary. The Rehoboth and Rock Run cost analyses in Table 6-4 and 6-5 show that using FGD for gob pile reclamation can result in savings ranging from $8,350 to $12,600 per acre. With approximately 800 acres of gob piles identified as being unreclaimed in Ohio, the potential savings could be as high as $8 million for just this one type of reclamation.

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Table 6-4: Cost Analysis for Rehoboth Phase 1 Project

Rehoboth Phase 1 (Sedimentation and AMD remediation) Item Quantity Unit Cost/Unit Total Cost Labor Material Total Gob Cap FGD Seal 139,200 C.Y. $ 0.61 $ - $ 0.61 $ 84,912.00 Pond Liner FGD liner 8,310 S.Y. $ 0.58 $ - $ 0.58 $ 4,819.80 Resoil Buffer 139,200 C.Y. $ 0.54 $ - $ 0.54 $ 75,168.00 Resoiling 65 Acre $ 903.50 $ - $ 903.50 $ 58,727.50 Alternative Organic Resoil 2,145 Dton $ 24.00 $ 50.00 $ 74.00 $ 158,730.00 Total $ 382,357.30 Alternative 1 (Sedimentation and AMD remediation) Item Quantity Unit Cost/Unit Total Cost Labor Material Total Gob Cap Clay Seal 69,600 C.Y. $ 9.10 $ 633,360.00 Pond Liner Clay Seal 8,310 C.Y. $ 9.10 $ 75,621.00 Resoil Resoiling 65 Acre $ 2,827.50 $ 183,787.50 Lime 1,625 Dton $ 20.00 $ 32,500.00 Total $ 925,268.50 Alternative 2 (Sedimentation remediation only) Item Quantity Unit Cost/Unit Total Cost Labor Material Total Gob Cap Borrow 139,200 C.Y. $ 1.75 $ 243,600.00 Lime 1,625 Ton $ 20.00 $ 32,500.00 Pond Liner Clay Seal 8,310 C.Y. $ 9.10 $ 75,621.00 Resoil Resoiling 65 Acre $ 1,885.00 $ 122,525.00 Lime 975 Dton $ 20.00 $ 19,500.00 Total $ 493,746.00

(Source: Ohio Department of Natural Resources – Division of Mines and Reclamation)

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Table 6-5: Cost Analysis for Rock Run Reclamation Project

Rock Run (Sedimentation and AMD remediation) Item Quantity Unit Cost/Unit Total Cost Labor Material Total Gob Cap FGD Seal 16,133 C.Y. $ 0.93 $ - $ 0.93 $ 15,003.69 Resoil Resoiling - 8" 5 Acre $ 2,000.00 $ - $ 2,000.00 $ 10,000.00 Total $ 25,003.69 Alternative 1 (Sedimentation and AMD remediation) Item Quantity Unit Cost/Unit Total Cost Labor Material Total Gob Cap Clay Seal 8,067 C.Y. $ 9.10 $ 73,409.70 Resoil Resoiling - 12" 5 Acre $ 3,000.80 $ 15,004.00 Total $ 88,413.70 Alternative 2 (Sedimentation remediation only) Item Quantity Unit Cost/Unit Total Cost Labor Material Total Gob Cap Borrow 16,133 C.Y. $ 1.75 $ 28,232.75 Resoil Resoiling - 8" 5 Acre $ 2,000.00 $ 10,000.00 Total $ 38,232.75

(Source: Ohio Department of Natural Resources – Division of Mines and Reclamation)

6.5 Current Mining Uses

6.5.1 Division of Mines and Reclamation - Regulatory Program

Many different types of by-products and waste materials are currently approved by DMR regulatory program for use at active mining sites. A search of active mining permits showed that coal refuse and slurry, and fly ash were among the materials approved for use in the reclamation of these sites. Table 6-6 lists active mining permits approved by DMR in which use of fly ash is permitted. In most circumstances in the past, DMR has been given approval by OEPA to review the utilization of fly ash on mining permits. Often, operators have an interest in fly ash utilization since disposal is a part of the contractual agreement with a utility company. If an operator agrees to dispose the fly ash produced by the utility company, this company will in return purchase coal from the mine operator.

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Table 6-6: DMR Approved Mine Permits with CCP Applications

Permit Operator County Township Notes D-0347 Sands Hill Coal Vinton Clinton Fly ash disposal IM-0288 Tri-State Asphalt Belmont Mead Fly ash disposal IM-1059 Mitchell Transport Lake Painesville Fly ash disposal D-0852 Kimble Clay & Limestone Tuscarawas York Fly ash disposal D-1085 Miller Mining Tuscarawas Auburn, Bucks Fly ash disposal

(Source: Ohio Department of Natural Resources – Division of Mines and Reclamation)

Currently, mine operators do not utilize FGD on active permits as they do fly ash. The only DMR regulatory program approved project that has incorporated FGD utilization on active mining sites is the Broken Aro project. The lack of utilization may be attributed to the ready availability of conventional materials and the limited exposure to the potential benefits of FGD use. As FGD utilization becomes more common, operators may choose to incorporate FGD into site reclamation. FGD utilization, particularly the use of dry FGD materials, will become more attractive to operators hauling coal to plants from which FGD can be brought to the project site as haulback. In addition, sewage sludge treated with FBC ash is currently available from N-Viro International for use at existing surface mining sites.

6.5.2 Haulback of FGD Material to Coal Mines

In order to evaluate the haulback potential of FGD to operating coal mines, it is necessary to know the location of the mines (surface and underground) in the state and the number of trucks involved in transporting coal from mines to plants. Figure 6-3 shows the various power plants in Ohio and coal mines (surface and underground) in operation in the state. Almost a dozen Ohio plants including SMS, CAR, BRG, WHG, OUP, MDC, GAV, KYG, MUS, CON, DOV, and ORR are in the vicinity of surface and underground coal mines. A detailed list of surface and underground mines operational in the state is contained in the 1997 Report on Ohio Mineral Industries (Wolfe, M., 1998). The use of CCPs, particularly FGD and fly ash in the reclamation of the surface mines and injection into underground coal mines has the potential for significant savings to CCP generators and coal mining operations.

Trucking is the primary means of coal transport in the state. In 1997, truck disposition accounted for 40% of all coal shipped in the state of Ohio. Conveyor belts carried 30%, rails transported 15%, and barges carried 14% of Ohio coal (Wolfe, M., 1998). The trucking data for each county is shown in Table 6-7. Based on a 15 tons per truck capacity of coal, the approximate number of truck loads used annually in each county for transporting coal was estimated. Counties having more than 50,000 truck loads per year were Belmont (116,000), Harrison (97,000), Vinton (97,000), Tuscarawas (75,000), Perry (74,000), Jackson (52,000), and Columbiana (50,000). Meigs, Monroe, and Morgan counties generated approximately 10 MST of coal in 1997, all of which was transported by conveyors (Meigs and Morgan), or barge (Monroe). Transport of FGD and fly ash to active mining sites using conveyor belts and water based transportation systems

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seems to be unrealistic at present. However, haulback to coal mines using the trucks that bring coal to the plants, will be beneficial to CCP generators and coal operations if the haulback can be made a part of the coal purchasing contract. Appropriate permitting concurrence from state regulatory agencies such as DMR and OEPA would be necessary.

PNS AST ASHTABULA BYS ELK WILLIAMS FULTON MCO LUCAS OTTAWA AVN LAKE WOOD LKS GEAUGA HENRY TRUMBULL DEFIANCE SANDUSKY ERIE CUYAHOGA LORAIN PORTAGE HURON SUMMIT NLS SENECA PAULDING MEDINA PUTNAM HANCOCK GPP MAHONING

VAN WERT SML WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN ORR MERCER MARION AUGLAIZE HOLMES CARROLL SMS SMR LOGAN KNOX DOV SHELBY UNION MORROW COSHOCTON HARRISON DARKE DELAWARE CAR CON CHAMPAIGN LICKING MIAMI GUERNSEY FRANKLIN

CLARK MUSKINGUM BRG OSU BELMONT PERRY PREBLE MONROE HUT FAIRFIELD NOBLE GREENE MADISON PIC MORGAN PICKAWAY FAYETTE MUS HOCKING WASHINGTON BUTLER WARREN CLINTON WHG COH,CHM ROSS ATHENS VINTON MDC OUP HAMILTON HIGHLAND MIF PIKE MEIGS 0 10 20 30 40 miles WCB JACKSON BROWN ADAMS GAV 0 10 20 30 40 50 kilometers SCIOTO KYG ZIM GALLIA KIS Coal-fired power plant JMS LAWRENCE Underground coal mine Surface coal mine Coal preperation plant

(Source: Wolfe, M., 1998; CCP survey by authors)

Figure 6-3: Location of Coal Mines and Preparation Plants

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Table 6-7: Ohio County Data for Coal Trucking

Quantity of coal Approximate number of shipped annually by truck loads used County Number of mines trucks from each annually for transporting county (short tons) coal from each county

Belmont 18 1,750,182 116,679 Carroll 5 58,853 3,924 Columbiana 11 752,078 50,139 Coshocton 10 423,877 28,258 Gallia 2 93,156 6,210 Guernsey 7 465,399 31,027 Harrison 8 1,466,090 97,739 Holmes 3 123,890 8,259 Jackson 6 783,569 52,238 Jefferson 8 680,599 45,373 Lawrence 2 7,179 479 Mahoning 1 37,241 2,483 Meigs 2 0 0 Monroe 1 0 0 Morgan 1 0 0 Muskingham 2 685,935 45,729 Noble 6 627,135 41,809 Perry 7 1,115,219 74,348 Stark 9 584,517 38,968 Tuscarawas 28 1,128,822 75,255 Vinton 5 1,463,316 97,554 Washington 1 77,718 5,181 Total 143 12,324,775 821,652

Note: Average coal carrying capacity of a truck is assumed to be 15 tons per load. Actual coal carrying capacity may vary.

6.5.3 Treatment of Coal Refuse with Sulfite-Rich FGD Material

Calcium sulfite rich FGD holds promise for mitigating acid mine drainage from coal refuse generated at coal preparation plants. Co-mixing of FGD with coal refuse can reduce the amount of oxygen and ferric iron available to oxidize pyrite because calcium sulfite is a strong reductant and hence may mitigate acid production in coal refuse. (Hao et al., 1998). Presently there are about 20 coal preparation plants in the state. All these plants are concentrated in the east and southeast part of the state along operational coal mines (Figure 6-3). Because several of these plants are located close to coal-fired power plants, there is an opportunity to co-mix coal refuse generated at the preparation plants with FGD from the power plant. If trucking is used as the mode of transportation for the washed coal from the preparation plant to the power plant,

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haulback of FGD to the coal refuse disposal site can be an attractive economical solution to mitigating acid production from coal refuse piles.

Approximately 21 million tons of coal was washed in the state of Ohio is 1997. Data published in the 1997 Report on Ohio Minerals Industries (Wolfe, M., 1998) shows an average of 35.6% loss on washing of coal in the state. The amount of coal lost in washing in 1997 at Ohio coal preparation plants was approximately 7.5 million tons. Assuming all coal lost ends up as coal refuse, and would require 20% FGD co-mixing at refuse disposal site to mitigate acid formation, approximately 1.5 MST of additional FGD could be used annually to mitigate acid production from coal refuse.

6.6 Underground Placement

Coal combustion products, particularly fly ash and FGD, in combination with other cementious materials or by themselves may be placed underground to solve a variety of underground mining problems including subsidence and acid mine drainage. These materials could be used to remediate existing problems arising from past underground mining activities as well as underground mining in progress. The potential for each of these applications is presented below.

6.6.1 Subsidence Remediation

Most of the approximately 6,000 abandoned underground mines found in Ohio in 38 counties were coal mines. Some of these underground mines are subject to gradual or sudden collapse and can result in damage to buildings, disrupt buried utilities, and may result in potential risk to human life (Crowell, 1997). The collapse of the eastbound lanes of I-70 in March 1995 was caused by subsidence due to roof collapse of an old abandoned mine below the highway. A barrier wall was constructed on the north and south end of the interstate and the mine void between the barrier walls was filled with grout. The remediation scheme involved injecting grout consisting of fly ash, sand, and cement into more than 1800 injection holes drilled at the site. The I-70 repair work cost approximately $3.6 million. Other mine subsidence or collapse projects that have been repaired in the state include I-77 in 1995 and I-470 repairs in 1996 at costs of $4.2 million and $3.0 million, respectively. Due to the potential risk of mine subsidence under highways, the Ohio Department of Transportation has developed a mine inventory and risk assessment manual (Ohio Department of Transportation, 1998). The manual outlines procedures for site investigation, evaluation, monitoring, prioritizing, remediation, and emergency action. Fly ash and FGD based cement grouts could be used for the remediation of emergency collapse projects. In addition, underground mined areas near highways that are prone to subsidence can be pressure grouted as a precautionary measure so as to avoid future potential risk to human life and costly emergency repairs. The Ohio Division of Geological Survey has detailed abandonment maps for 4,138 mines across the state. In addition, the Division estimates that an additional 2,000 mines have yet to be adequately characterized. Currently, a cooperative effort by ODOT and ODNR is underway to digitize the mine maps and put them in a GIS database. Figure 6-4 shows the Ohio counties in which underground mines are located, types of subsidence insurance required for each county, and the various coal-fired power plants in the state. About 15 coal-

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fired power plants are located in the counties that have abandoned mines with the potential of subsidence or collapse. Tuscarawas county has the highest number of known abandoned mines (419). The mandatory mine subsidence insurance counties are the most favorable counties in which FGD and/or fly ash grouts could be placed or injected underground to remediate subsidence. The volume of grout that could be used on each project depends on the extent of mine voids that would need to be filled, and in general will be a high-volume application involving several thousand tons of grout per project.

6.6.2 Acid Mine Drainage Mitigation

Chemical mine drainage pollution from mines has been a concern due to its detrimental effect on the waterways of the state. A study conducted by DMR in 1985 (United States Department of Agriculture, 1985) found that 1,400 stream miles in east and southeast Ohio were polluted with acid mine drainage. The report identified 68,000 acres of abandoned strip mines, 3,000 acres of mine refuse, and 79,000 acres of underground mines, which contributed to the production and transport of acid mine drainage into the affected streams. The various drainage basins contributing to acid production from underground mines and their underground mine acreages are shown in Table 6-8. It can be seen that the acreage of underground mines in Wheeling Creek, Short Creek, Monday Creek, and Moxahala Creek contribute the most to acid mine pollution. These drainage basins lie in Belmont, Harrison, Jefferson, Hocking, Perry, Athens, Muskingum, and Morgan counties. Two acid mine drainage mitigation projects have been carried out in the state using stabilized FGD as a physical barrier to the flow of water from the underground mines. Details on the Broken Aro and Roberts-Dawson project were presented earlier. FGD material can be gravity or pressure injected into underground mines as in the Roberts-Dawson project or may be placed underground as was done at the Broken Aro site. The volume of CCPs that could be used for remediating acid mine drainage from underground mines can be significant (e.g., Roberts-Dawson and Broken Aro projects each used approximately 25,000 tons of FGD).

6.6.3 Existing Subsurface Mining Uses

Limited quantities of CCPs could be used as backfill material in existing subsurface mining operations. Of all the underground mines shown in Figure 6-3, only ten contributed significant amounts of coal in 1997. These include underground coal mines in Belmont (5.1 MST of coal), Meigs (4.6 MST), Monroe (3.2 MST), Vinton (1.8 MST), Harrison (1.6 MST), Columbiana (0.7 MST), and Jefferson (0.5 MST) counties. These active underground mine sites would be potential candidates for using FGD and fly ash. Non-coal underground mining sites could also be suitable provided they are located within a reasonable distance from a CCP generating facility.

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WCB GAV BROWN ADAMS SCIOTO KYG ZIM GALLIA KIS 0 10 20 30 40 miles

0 10 20 30 40 50 kilometers JMS LAWRENCE

Mandatory mine subsidence insurance required Optional mine subsidence insurance recommended

Figure 6-4: Counties with Abandoned Underground Mines

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Table 6-8: Acid Mine Drainage: Underground Mine Acreage

Underground Mine Drainage Basin Acreage Wheeling Creek 15,658 Short Creek 14,821 Monday Creek 14,797 Moxahala Creek 8,484 Stone Creek 4,992 McMohan Creek 3,513 Leading Creek 3,272 Yellow Creek 3,058 Tuscarawas Tributaries 2,385 Sunday Creek 2,012 Racoon Headwaters 1,846 Ohio River Tributaries 809 Lower Wills Creek 747 Conotton Creek 605 Little Raccoon Crek 572 Upper Stillwater 566 Sugar Creek 484 Racoon and Elk Fork 408 Pine Creek 150 Rush Creek 115 Muskingham River Tributaries 21 West Fork Duck Creek 6 Total = 79,321

(Source: United Stated Department of Agriculture, 1985)

6.7 Social Benefits of FGD Reclamation

Abandoned mine lands in east and southeast Ohio have been a significant source of acid mine drainage and sedimentation problems, resulting in a significant detrimental environmental impact on streams and lakes. Many of these areas, which are in vicinity of FGD generating facilities, can be reclaimed using FGD material. In Section 6.4, it was shown that the use of FGD material for abandoned mine land reclamation can result in significant savings ($10,000 per acre) to the Ohio Department of Natural Resources – Division of Mines and Reclamation. Reclamation of abandoned mined lands with FGD material also results in an increase in the value of property located near or impacted by unreclaimed areas.

A study conducted by OSU (Dick et al., 1999a) investigated the social benefits that could be realized by property owners near Piedmont Lake within the Muskingum Water Conservancy District. According to USGS mapping in 1976, one-third of the drainage basin of this lake has

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been mined, two-thirds of which had been reclaimed. The main detrimental impacts were concentrated near one end of the lake with discoloration of water due to acid mine drainage and an unpleasant odor problem due to excessive sulfur in the water. An estimate of the aggregate benefits to property owners of any future FGD reclamation of the mines above Piedmont Lake was carried out. The study concluded that reclamation of the areas impacting the lake would increase aggregate property values by $47,000 to $68,000. Assuming that about 200 tons of FGD would be used to reclaim one acre of unreclaimed land, it was shown that the social benefit of reclamation using FGD material for the lake would be $0.018 to $0.026 per ton. This social benefit (a few cents per ton of FGD for reclamation) only includes the benefits to property owners.

In conclusion, the reclamation of abandoned mined lands can result in social benefits for property owners living in vicinity of impacted areas. The “gainers” from FGD reclamation work are not be limited to state agencies (e.g., ODNR-DMR) and property owners, but will also include recreational visitors as well as merchants in the area who will financially gain more from visitors. Also, those driving by these reclaimed sites will gain a better aesthetic view of the area. Hence, it is recommended that government agencies recognize the societal benefits of reclamation work using CCPs and make available financial and in-kind incentives to promote the greater use of these materials at abandoned and currently mined lands.

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7 AGRICULTURAL APPLICATIONS

7.1 Introduction

CCPs can be valuable raw materials for many agricultural applications. Stabilized FGD is currently being used in more than 10 Ohio counties for constructing livestock feeding and hay storage pads. FGD can be used as an agricultural liming substitute / soil amendment, and as a liner for ponds, weltands, and animal manure storage facilities. Research into these promising applications is in progress, the details of which are provided in Appendix C. Some of the characteristics of FGD, which make its use in agricultural applications attractive, are: · Calcium carbonate equivalency; · Source of trace elements for healthy plant growth; · Increased strength with time (due to pozzolanic reaction) for compacted FGD; · Particle size is such that it can improve the properties of sandy or clay soils; · Presence of gypsum (calcium sulfate).

7.2 Livestock Feeding and Hay Storage Pads

Excessively muddy conditions at livestock feeding and watering areas can have detrimental effects on farm operations. The animals have to expend a considerable amount of energy just to move through mud, resulting in higher feed costs and reduced weight gain by livestock. Hay bales stored on wet ground can take on moisture, leading to early deterioration and as much as 50% spoilage. Avoidance of muddy conditions can result in increased animal performance and significant monetary savings for producers, as well as a cleaner farm environment. Construction of a stable, impermeable, and sloped surface so that water drains off rather than accumulates on the area will avoid these muddy conditions. Concrete or stone aggregate typically have been used for constructing livestock feeding pads. Recently, FGD has been successfully demonstrated as an inexpensive and reliable product in the construction of cattle, milk cow, and sheep feeding pads. It is also being used in the installation of hay bale storage pads. Pads constructed of FGD are not as strong, hard, or durable as concrete, but for these applications, FGD pads improve conditions of the area substantially at a cost that is usually far less than concrete.

Fly ash and lime-enriched FGD filter cake, when mixed at the power plant in proper proportions, will undergo a chemical reaction that, upon adequate compaction in a fairly fresh state (moisture content of 40-55%), gains strength and durability. The beneficial use of lime-enriched FGD product for livestock feeding or hay bale storage pads is not subject to additional OEPA review when used in accordance with the statewide permit-to-install (PTI) issued by OEPA (Application No. 07-0037, dated June 25, 1997). In the summer of 1997, twenty-four livestock feeding and hay bale storage pads, ranging in size from 1,500 square feet to 15,000 square feet, were constructed in eastern and southeastern Ohio. In 1998, more than 150 FGD pads were constructed in 12 counties in Ohio. The Ohio State University Extension Service has published a Fact Sheet on the use of FGD in the construction of livestock feeding and hay storage pads (Butalia, 1999b) and it is included in this report as Appendix I.

83 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

The cost of using the FGD material for constructing livestock feeding and hay bale storage pads compares favorably with conventional materials such as concrete or rock aggregate. A cost analysis was carried out for six FGD pads constructed in Gallia county in 1997 (Gallia County NRCS, 1997). The cost summary comparison is listed in Table 7-1. Estimates were prepared using cost guidelines developed by NRCS and local prices for equipment operators, materials, and transportation in the Gallia County area. On average, an FGD pad constructed in Gallia County cost approximately $2,750 with approximately half of the cost for trucking of FGD and the rest for site work and material placement. The total cost of the FGD pads was about 26% less than the estimated cost for construction using aggregate and about 65% less than the estimated cost for concrete pads. For Coshocton County, where the FGD may be delivered free to the site, the projected savings compared with aggregate and concrete would be 63% and 83%, respectively. This represents a significant amount of monetary savings over concrete and aggregate pads for farmers installing these pads using the FGD product.

The potential use of FGD pads in the state is much greater than the current utilization in east and southeast Ohio. According to 1997 agricultural data (Ohio Department of Agriculture, 1998), Ohio has more than 40,000 livestock farms. The majority of these are cattle farms (33,000). There are approximately 6,000 milk cow farms in the state and about 4,000 sheep farms. Ohio cattle inventory is nearly 1,440,000 heads. The total value generated from cattle in the state was $936 million. Milk cows in Ohio number approximately 280,000, while sheep and lamb inventory is 117,000. The counties leading in cattle inventory along with the locations of FGD generating power plants in the state is shown in Figure 7-1. It can be seen that the Conesville power plant (CON) is ideally located to provide FGD for the construction of cattle feeding pads. Many of the other FGD generating facilities are also in vicinity of major cattle inventory counties.

Table 7-1: Cost Summary for FGD Pads Constructed in Gallia County

Project ID Area (ft2) Actual FGD cost Estimated aggregate Estimated concrete cost cost 1 11,350 $4,542 $7,143 $15,507 2 3,008 $1,272 $1,959 $4,001 3 7,980 $4,300 $5,174 $10,489 4 5,400 $2,499 $3,147 $7,150 5 2,100 $951 $1,374 $2,903 6 5,424 $2,888 $3,563 $7,073 Average cost $2,742 $3,727 $7,854 Ratio to FGD cost 1 1.36 2.86 FGD savings as % 26.4% 65.1%

(Source: Gallia County NRCS, 1997)

84 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

ASHTABULA

WILLIAMS FULTON LUCAS OTTAWA LAKE WOOD GEAUGA HENRY TRUMBULL DEFIANCE SANDUSKY ERIE CUYAHOGA LORAIN PORTAGE HURON SUMMIT SENECA NLS PAULDING MEDINA PUTNAM HANCOCK MAHONING

VAN WERT WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN MERCER MARION AUGLAIZE HOLMES CARROLL

LOGAN KNOX SHELBY UNION MORROW COSHOCTON HARRISON DARKE DELAWARE CHAMPAIGN CON MIAMI LICKING MUSKINGUM GUERNSEY BELMONT FRANKLIN CLARK OSU PERRY PREBLE NOBLE MONROE FAIRFIELD GREENE MADISON MORGAN PICKAWAY FAYETTE HOCKING WASHINGTON BUTLER WARREN CLINTON COH* ROSS ATHENS VINTON OUP* HAMILTON HIGHLAND PIKE MEIGS JACKSON GAV BROWN ADAMS SCIOTO ZIM GALLIA 0 10 20 30 40 miles

0 10 20 30 40 50 kilometers LAWRENCE

Greater than 27,000 21,000 to 27,000 * Installation of FGD scrubber in progress 12,000 to 21,000 Less than 12,000

(Source: Ohio Department of Agriculture, 1998)

Figure 7-1: Counties With Leading Cattle Inventory

85 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

7.3 Agricultural Liming Substitute and Soil Amendment

FGD may be used to improve soil quality and productivity by substituting for agricultural lime, some commercial fertilizers, and other soil amendments. Many FGD materials are alkaline and hence can be used as substitutes for conventional agricultural lime for adjusting the pH of acidic agricultural soils. The neutralizing potential of many FGDs is due to the presence of calcium carbonate and calcium hydroxide. Rates for application of FGD can be determined by matching the lime requirement of the soil with the total neutralizing potential of FGD. Once a pH adjustment has been made for the soil, the fly ash in the FGD can result in a large buffering capacity providing resistance to further changes in pH. Tests conducted at OSU have shown yield increases of alfalfa to be above those obtained using agricultural limestone (Dick et al., 1999a), probably due to the presence of trace elements in the FGD, which results in healthier plants. Experiments conducted at Ohio Agricultural Research and Development Center (OARDC) in Wooster have shown significant increases in alfalfa yields treated with FGD compared to untreated soil. Additional laboratory and field tests have shown that FGD with low boron and soluble salt content, and high acidic neutralizing potential can be used in place of agricultural limestone as a soil amendment. Dry FGD by-products, particularly FBC ash, and FGD gypsum would be a beneficial substitute for agricultural lime. Concerns with regard to the presence of heavy metals and their potential uptake and accumulation in plants, animals, and humans persist.

Limestone and dolomite were produced or sold by 77 companies at more than 120 mining operations in 52 Ohio counties in 1997 (Wolfe, M., 1998). Total sale of limestone and dolomite for the state was approximately 77.5 million tons. The leading limestone and dolomite generating counties, Ottawa, Erie, Delaware, Wyandot, and Franklin, accounted for 37% of all sales in the state. The average sale price of these materials at the mining location was $4.16 per ton. The 1997 agricultural lime sales were 1.2 million tons. In general, agricultural lime is a low-cost commodity at the generating facility and the bulky nature of the material results in high transportation cost. Consequently, agricultural lime is generated in the vicinity of consumption areas.

The average annual sale of agricultural lime for each county is shown in Table 7-2 and is based on 1986-1991 data (Stehouwer et al., 1995). The northeast and northwest parts of the state account for nearly 60% of agricultural lime use in Ohio. About 34% of all agricultural lime used in the state is consumed by the northwest region of the state, while 26% percent is used by the northeastern region. In order to estimate the potential FGD use in each county, it was assumed that 25% of the agricultural lime used in each county would be replaced by dry FGD and that 1 ton of agricultural lime is equivalent to approximately 1.67 tons of dry FGD. The potential estimated dry FGD annual sale for each county on the basis of these assumptions is shown in Table 7-3. The total potential dry FGD use for the state would be approximately 365,000 tons per year. Counties with potential dry FGD use greater than 10,000 tons per year include Coshocton, Defiance, Highland, Huron, and Wayne. On the other hand, 1 ton of agricultural lime is equivalent to approximately 5 tons of wet FGD. The usage potential across the state for wet FGD material is approximately one million tons per year. A study conducted at OSU (Stehouwer et al., 1995) that assumed the end user paying for trucking of the FGD, concluded that the use of

86 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

FGD as an agricultural lime substitute could be economical for farms in the northeastern part of the state. FGD use in the northwest region of the state did not compare favorably with agricultural lime due to longer transportation distances. However, if subsides are available to cover cost of transportation, the use of FGD all over the state could be competitive with agricultural lime.

Other soil amendment uses of FGD, such as sulfur and/or Ca:Mg ratio enhancer, are expected to have similar market potential and constraints as the agricultural lime substitute uses. However, the use of dry FGD as a fertilizer could have better marketing potential due to a much higher value associated with the product, as is being proposed by Sorbtech using the Fluesorbent FGD (Nelson, et al., 1999). FGD gypsum is a promising source of major soil nutrients such as calcium and sulfur, and can result in increased plant yields of deep rooted, acid sensitive crops during drought years by increasing root depth (Bigham et al., 1999). Only one gypsum producing mine is in operation in the state this time (Wolfe, M., 1998). The 1997 sale price of gypsum at this mine was $9 per ton. If FGD gypsum is made available to the agricultural community across the state, it could be marketed well. However, the success of these materials on farms and fields may require subsidization of a portion of the cost associated with the transport of FGD.

Fly ash can be potentially used as a commercial fertilizer, topsoil ingredient, and soil blend for horticultural applications. Addition of fly ash to soils can result in improved soil fertility, mineralogical value, color, and improved moisture control. Fly ash and FBC ash have been used for several years by N-Viro International, Toledo, as an alkaline admixture in the pasteurization of municipal biosolids for generating soil blends. N-Viro plants based in Toledo and Galion utilize fly ash and FBC to generate soil blends. These N-Viro based soil blends have been used for agriculture, reclamation, and horticulture applications. Delphi Automotive Systems, which has 5 plants in Ohio, has successfully recycled 50,000 tons of fly ash in the generation of topsoil products (PRNewswire, 1999). The topsoil is made of up to 20% fly ash. Fly ash has been used in the eastern United States for treatment of biosolids and this use is expected to increase nationally (including Ohio) as biosolid regulations become more stringent. Additionally, some CCPs may be effective in treatment of livestock manure and other organics.

87 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 7-2: Annual Sale of Agricultural Lime, by County (Averaged from 1986-1991)

County Lime sold (tons) County Lime sold (tons) Adams 16,120 Licking 12,945 Allen 12,216 Logan 2,421 Ashland 6,716 Lorain 10,181 Ashtabula 13,435 Lucas 11,446 Athens 3,019 Madison 1,708 Auglaize 20,938 Mahoning 5,850 Belmont 11,808 Marion 4,566 Brown 15,652 Medina 11,707 Butler 4,849 Meigs 278 Carroll 4,897 Mercer 6,080 Champaign 9,713 Miami 5,442 Clark 7,664 Monroe 888 Clermont 11,993 Montgomery 1,466 Clinton 16,801 Morgan 1,507 Columbiana 16,444 Morrow 2,563 Coshocton 27,016 Muskingum 13,593 Crawford 16,454 Noble 955 Cuyahoga 9,572 Ottawa 14,565 Darke 15,093 Paulding 14,805 Defiance 26,433 Perry 2,978 Delaware 22,073 Pickaway 7,069 Erie 15,803 Pike 12,146 Fairfield 23,333 Portage 8,358 Fayette 13,466 Preble 6,383 Franklin 5,706 Putnam 6,001 Fulton 22,565 Richland 9,884 Gallia 9,399 Ross 3,911 Geauga 751 Sandusky 7,244 Greene 10,601 Scioto 1,089 Guernsey 6,783 Seneca 13,298 Hamilton 1,531 Shelby 4,708 Hancock 8,583 Stark 5,713 Hardin 17,893 Summit 3,702 Harrison 1,094 Trumbull 9,229 Henry 13,785 Tuscarawas 6,467 Highland 35,976 Union 4,674 Hocking 1,197 Van 2,675 Holmes 7,767 Vinton 367 Huron 40,751 Warren 4,127 Jackson 262 Washington 4,710 Jefferson 3,295 Wayne 27,503 Knox 20,427 Williams 15,369 Lake 3,693 Wood 16,852 Lawrence 355 Wyandot 13,735 Total = 875,086

(Source: Stehouwer et al., 1995)

88 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 7-3: Potential Annual Sale of Dry FGD as Agricultural Lime Substitute, by County

County FGD (tons) County FGD (tons) Adams 6,730 Licking 5,405 Allen 5,100 Logan 1,011 Ashland 2,804 Lorain 4,251 Ashtabula 5,609 Lucas 4,779 Athens 1,260 Madison 713 Auglaize 8,742 Mahoning 2,442 Belmont 4,930 Marion 1,906 Brown 6,535 Medina 4,888 Butler 2,025 Meigs 116 Carroll 2,045 Mercer 2,539 Champaign 4,055 Miami 2,272 Clark 3,200 Monroe 371 Clermont 5,007 Montgomery 612 Clinton 7,015 Morgan 629 Columbiana 6,865 Morrow 1,070 Coshocton 11,279 Muskingum 5,675 Crawford 6,869 Noble 399 Cuyahoga 3,996 Ottawa 6,081 Darke 6,301 Paulding 6,181 Defiance 11,036 Perry 1,243 Delaware 9,216 Pickaway 2,951 Erie 6,598 Pike 5,071 Fairfield 9,741 Portage 3,489 Fayette 5,622 Preble 2,665 Franklin 2,382 Putnam 2,506 Fulton 9,421 Richland 4,126 Gallia 3,924 Ross 1,633 Geauga 314 Sandusky 3,024 Greene 4,426 Scioto 455 Guernsey 2,832 Seneca 5,552 Hamilton 639 Shelby 1,966 Hancock 3,583 Stark 2,385 Hardin 7,470 Summit 1,546 Harrison 457 Trumbull 3,853 Henry 5,755 Tuscarawas 2,700 Highland 15,020 Union 1,952 Hocking 500 Van 1,117 Holmes 3,243 Vinton 153 Huron 17,014 Warren 1,723 Jackson 109 Washington 1,967 Jefferson 1,375 Wayne 11,483 Knox 8,528 Williams 6,417 Lake 1,542 Wood 7,036 Lawrence 148 Wyandot 5,734 Total = 365,348 Assumptions: 1 ton of agricultural lime = 1.67 tons of dry FGD 25% of agricultural lime used in each county (averaged 1986-1991) will be replaced by FGD

(Source: Stehouwer et al., 1995)

89 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

7.4 Liners for Ponds and Manure Storage Facilities

The low permeability and high strength of some FGD materials make them potentially very useful in the construction of low permeability liners for water holding ponds, manure storage facilities, and wetlands in place of conventionally used clay or synthetic liners, all of which can be quite expensive. FGD material does not require any special handling and can be compacted in the field using equipment traditionally used for compacting clay. Livestock operations generating liquid or semi-liquid manure can use these lined structures as temporary holding facilities. The manure and wastewater can then be applied to fields at times that are more environmentally appropriate as well as convenient to farmers. Researchers at The Ohio State University’s Department of Civil and Environmental Engineering and Geodetic Science built a full-scale FGD-lined facility (capacity 1 million gallons) at the Western Branch of the Ohio Agricultural Research and Development Center near South Charleston. An outline of this full-scale demonstration facility can be found in Appendix C. Monitoring of the facility is in progress and it is hoped that approval from OEPA for the construction of FGD-lined ponds and manure storage facilities is forthcoming.

There are approximately 0.5 million acres of reclaimed strip mined lands in eastern and southeastern Ohio which could be but are not presently used productively. However, since much of this portion of the state has no significant ground water supply (a typical well might produce at most one gallon per minute), surface impoundments are the only viable sources of water. Additionally, agricultural operations often require collection and storage of animal manure and rainfall runoff. Both water and waste impoundments require a low permeability barrier to separate the liquid in the pond/manure containment facility from the surrounding environment. The reclaimed sites typically do not have sufficient natural clays suitable for lining a constructed impoundment. Currently available alternatives to on-site clays are commercial clays, synthetic (plastic) membranes, or concrete, all of which come at a very high cost.

The principal direct economical benefit arising from FGD lined ponds would be the savings in the construction costs of liquid retention facilities that must now rely on select borrow material to be water tight. If an FGD product could be used instead of clay or geomembranes, the savings would be as much as $2-3 per square foot based on current prices for the alternatives. As an example, the FGD-lined full-scale facility in South Charleston was constructed in 1997 at a cost of approximately $50,000. A similar concrete lined facility constructed by The Ohio State University two years earlier cost more than $200,000. A significant reduction in the cost of lined facilities will make some projects feasible, which may result in an increase in the agricultural activity within the state, particularly livestock operations. With the development of surface impoundments lined with a low-cost alternative to clay or concrete, a variety of animal prep facilities could become financially viable, increasing substantially the economic base of affected counties in the Appalachia region.

90 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

8 OTHER CIVIL ENGINEERING AND MISCELLANEOUS USES

In Chapters 5, 6, and 7, the market potential for highway, mine reclamation, and agricultural uses of coal combustion products, particularly FGD, was discussed. In this chapter, the market potential for other civil engineered and miscellaneous uses are presented. These include the potential use of CCPs for wetland and landfill liners, gypsum feed for wallboard industry, treatment of wastewater sludge, production of alloys, ceramics, and composites, carbon extraction, and cement clinker.

8.1 Liner for Constructed Wetlands

Wetlands have been an attractive low-cost method for controlling water pollution from both point and non-point sources. They have been especially effective in controlling nitrogen and phosphorus from municipal wastewater, farm runoff, and acid mine drainage (AMD). Constructed wetlands generally require a low permeability liner, usually clay or bentonite, under the wetland basin to prevent or at least minimize seepage loss. The idea of using FGD products for liners for constructed wetlands has several possible advantages: · FGD could provide a good seal below constructed wetlands at an economically attractive price, particularly under wetlands being used for municipal wastewater treatment and AMD treatment; · The alkalinity of the FGD will contribute towards the neutralization of acid mine drainage for mine reclamation applications; and · The high concentration of calcium in the FGD could possibly enhance water quality by helping to retain phosphorus and by helping to accelerate anoxic conditions, thus causing denitrification.

Wastewater treatment plants, agriculture and industries are being required to achieve more stringent water quality standards for municipal wastewater, farm runoff, and mine drainage. An inexpensive liner constructed of FGD would make water quality improvements less expensive for those constructing treatment wetlands. The total cost of building a wetland consists of material (purchase and transportation) and construction costs. Past experience with the FGD- lined pond near South Charleston has shown that a compacted FGD liner requires no special handling or compaction equipment other than what would be needed to properly place a clay liner. Hence, construction costs are expected to remain the same for either a compacted clay or an FGD liner. However, material costs for clay are significantly higher due to non-availability of on-site clay. The economic advantage of using FGD for a 16-acre leaking wetland operated by the Southwest Licking Community Water and Sewer District in Licking County, Ohio was evaluated, and is shown in Table 8-1. It is assumed that the end user will pay for trucking costs as well as the 5% extra lime needed to increase the total lime content to 8%. It can be seen that it would cost the Water and Sewer District about $300,000 in material costs, essentially the cost of additional lime and hauling the material from the nearby Conesville Power Plant. If commercially available clay were used to do the lining of these wetlands, the material costs would be $850,000. The material cost savings to the Water and Sewer District are expected to be approximately $34,000 per acre.

91 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

Table 8-1: Comparison of Liner Cost for 16-Acre Constructed Wetland in Licking County, Ohio ______

Type of Liner Used Material Cost Note ______

FGD product $300,000 1

Recompacted soil liner + Geocomposite clay liner $850,000 2 ______

1. Assumes transportation cost of $.10 per mile per ton, and additional 5% lime cost. Wet bulk density of 1.2 g/cm3 and 2 feet liner depth. 2. Assumes $ 7 per cubic yard and 2 feet liner depth, no on-site clay available.

(Source: William Mitsch, School of Natural Resources, The Ohio State University)

8.2 Landfill Liner and Cap

The low permeability of FGD makes the material suitable for use as liners and caps for industrial and municipal landfills. FGD may be used as a landfill containment liner, daily cover, and final cap, in place of commonly used clay.

Table 8-2 shows the quantity of clay mined in Ohio in 1996 and 1997, the amount used for captive uses in the landfill industry, and the sale price at the mine per ton of clay (Wolfe, M., 1998; Weisgarber, 1997). Approximately 37% of all clay mined in the state in 1996-97 was used for landfill construction, resulting in landfill use of nearly 640,000 tons of clay per year. For an average cost of clay sold at the mine locations for 1996-97 of $6.15 per ton, Ohio landfill operators purchased clay worth nearly $8 million in 1996 and 1997.

Table 8-2: Clay Production and Landfill Use, 1996-1997

Clay mined Percent used for Average price Year Clay used by landfills (tons) (tons) landfills per ton ($) 1996 1,983,225 811,961 40.9% 6.45 1997 1,485,417 467,246 31.5% 5.74 Average 1,734,321 639,604 36.9% 6.15 (Source: Wolfe, M., 1998; Weisgarber, 1997)

The Gavin, Conesville, and Zimmer plants, the three major FGD generating facilities in the state, dispose most of their CCPs in captive landfills. The expected remaining lives of the Conesville, Gavin, and Zimmer landfills based on 1996 data were 12.8, 22.5, and 26.9 years, respectively (Ohio Environmental Protection Agency, 1997b). At closure, these facilities (and other solid

92 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

waste disposal facilities) could use 2 feet of compacted FGD in place of clay for the final cap over the landfill. FGD can also be used as a part of the frost protection layer and vegetative growth medium over the cap layer. The volume utilization for landfill cap application will be very high (more than 500,000 tons of stabilized FGD for a 100-acre footprint). Cost savings at closure of about $5 million can be realized for a 100-acre footprint. These savings are based on 1996-97 as the base cost year and will be much higher when these landfills are closed in 10 to 30 years.

8.3 Wallboard Manufacture

Currently, the majority of the FGD filter cake generated in Ohio is stabilized by adding fly ash and landfilled. The calcium sulfite-rich filter cake could be oxidized to calcium sulfate, dewatered, and marketed as synthetic gypsum. FGD gypsum can be about 98% calcium sulfate dehydrate and is as good or better than natural gypsum. Synthetic FGD gypsum can be used in wallboard and plaster manufacture, as a feed for cement manufacturing plants, and as a soil conditioner.

The conversion of FGD material into gypsum holds promise only for wet scrubber products. The expensive oxidation and dewatering equipment, combined with current high capital investments, have resulted in less than expected enthusiasm in the past. The Niles (NLS) plant scrubber generates FGD gypsum, all of which is used for wallboard manufacture. Recently the Zimmer (ZIM) plant owned jointly by Cinergy, AEP, and DPL announced plans to install oxidation and dewatering equipment at a cost of approximately $20 million to convert FGD filter cake, currently stabilized with fly ash and disposed in a landfill, to synthetic gypsum. The gypsum will be shipped seventeen miles down the Ohio River by barge to Lafarge Gypsum’s new wallboard plant in Silver Grove, Kentucky. The Silver Grove gypsum plant, with a capacity of 900 million square feet per year of wallboard, will be the largest single wallboard production line in the United Stated when it starts operations in the year 2000. Zimmer is expected to supply all the synthetic gypsum for the plant (up to 850,000 tons gypsum annually). Some of the gypsum will also be used by Lafarge at its US cement manufacturing plants. The use of FGD gypsum for wallboard manufacture is expected to save Zimmer approximately $5 million per year in landfill disposal costs (Cincinnati Enquirer, 1999; Power Journal, 1999; Industrial Specialties News, 1999).

In 1997, only one gypsum mine was in operation in Ohio (Wolfe, M., 1998). The mine is located in Ottawa County. Its annual production is about 265,000 tons, with all the gypsum sold for the manufacture of wallboard at an average sale price of $9 per ton (Wolfe, M., 1998). The current demand for wallboard in Ohio and neighboring states is quite high compared to the supply (Columbus Dispatch, July 11, 1999). Existing wet scrubbing FGD plants in Ohio could convert to FGD gypsum but would have to implement several critical programs including separating the fly ash and filter cake product streams, oxidizing and dewatering the filter cake, developing additional uses for fly ash, and finding partners willing to setup a wallboard manufacturing plant in vicinity of the power plant.

93 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

8.4 Recovery of Magnesium Hydroxide for Wastewater Treatment

Some wet scrubbing processes use magnesium-enhanced lime for effective SO2 removal. Examples are the Thiosorbic® and ThioClear® FGD processes developed by Dravo Lime Company (Smith et al., 1998). Both processes use magnesium-enriched lime as the scrubbing reagent. The Thiosorbic process was modified by the addition of oxidation, regeneration, and solids separation units to develop the ThioClear process. The ThioClear process results in the production of gypsum, which can be used as a feed by the wallboard and cement industries, and magnesium hydroxide, which is a desirable waste neutralization reagent. In general, it is possible to economically recover Mg(OH)2 from magnesium-enhanced lime scrubbing systems.

A successful magnesium hydroxide recovery process was developed by Dravo Lime Company at Miami Fort Station (MIF) and was put into operation at the Zimmer plant (ZIM). The Zimmer plant saves approximately $175,000 annually by using recovered magnesium hydroxide. The recovered Mg(OH)2 is being tested for the wastewater sludge treatment. The recovered reagent has potential for neutralization, nitrogen, and phosphorous control, and improved metals removal in wastewater treatment. Currently, University of Cincinnati and Dravo Lime Company are testing the efficiency of recovered Mg(OH)2 for treatment of wastewater at the Mills Creek Wastewater Treatment Plant in Cincinnati, Ohio. Several benefits result from this potentially promising application. First, the utility is able to recover the magnesium hydroxide reagent from the FGD process and generate income from its sales, and at the same time save some of the costs associated with decreased landfill disposal. The end user - wastewater plants - would have access to a cheaper acid waste neutralization reagent which would potentially be as effective as commercially available reagents. The societal benefit would be an improved quality of the environment into which the wastewater is discharged as well as treatment of pollution at its source rather than after it enters the natural environment. The potential markets will be cities and towns within a reasonable distance from magnesium-enhanced lime scrubbers.

8.5 Alloys, Composites, and Ceramics

Steel, which has been traditionally used in the automotive industry, is gradually being replaced by aluminum due to its lower weight advantage. Even more promising are aluminum alloys, metal matrix composites, and plastics. One of the aluminum alloys currently under development is the ash alloy. Ash alloy is typically generated by combining 20% fly ash and 80% aluminum. The addition of fly ash as a filler for aluminum using a patented process, has been shown to result in an increase in the hardness and abrasion resistance of the material, as well as a decreased weight of the product, all of which are desirable properties for automotive and aerospace applications. Fly ash may be combined with recycled aluminum to produce a high value end product that is technically superior, lighter and cheaper than other traditional competing products. The use of fly ash enhanced metal matrix composites also results in a lower coefficient of thermal expansion and increased wear resistance. The potential applications of these materials are not limited to automotive applications but have suitable markets in aerospace and recreational equipment manufacturing industry. These applications are low-volume uses but with a high value attached to them. Fly ash and cenosphere generating power plants, which are

94 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000.

close to automotive, aerospace, plastics and alloy manufacturing industries, may find these technologies to be more economical than other equivalent small-volume uses of these materials. The automotive industry would be able to incorporate a lighter and more durable material for manufacture of vehicles. The public would benefit by increased fuel efficiency, which would result in less use of gasoline and hence reduced exhaust pollution from vehicles. For the aerospace industry, this would allow aircraft and other air transport vehicles to carry greater loads.

The addition of coal-generated carbon nanofibers and fly ash to high-strength (10,000 psi to 25,0000 psi) macro defect free cement can result in increased ductility and strength of the product (Applied Sciences, Inc., 2000). In particular, microcracking can be controlled for structural applications. Such materials have a wide range of structural applications (e.g., bridge repair), mold and die use, low cost armor, automotive components, electro magnetically active cement for building materials, low observables, shipyard facilities, etc.

High carbon fly ash also has the potential of being used as an extender or filler in thermoset plastics for large-scale applications for building cladding or fascia panels. This is due to improvements in the thermoset resin industry (solvent-less system) over the last 5 years or so, in which, the cross-linking problems normally associated with oxides and carbon in fillers seem to have been overcome. By using high carbon fly ash in the preparation of thermoset plastics, the panel product can be cost competitive with other products being used in the building industry.

8.6 Carbon Extraction

Some carbon may be economically recovered from high-carbon fly ashes. This can result in two products, high quality carbon and a low carbon fly ash. The carbon can be marketed for numerous metallurgical processes particularly in the steel industry, which needs additional carbon to adjust steel quality depending on needs of individual customers. The low carbon fly ash can be used for many concrete and structural applications, in which high carbon contents are undesirable. An effective carbon extraction process was developed and patented at the Niles power plant of FirstEnergy. The company, in collaboration with two other companies has formed Carbon Plus LLC, a joint venture to produce and market high-grade carbon and low carbon fly ash (American Metal Market, 1998; Cleveland Plain Dealer, 1998). The existing ash markets for the Niles power plant (NLS), which were currently limited to Ohio and Pennsylvania, will be expanded nationally through this new company. It is expected that this new venture will generate sales of about $ 4 million a year to the steel, foundry and cement industries.

8.7 Cement Clinker

Ash Modifying Components (AMC) added to coal and upon combustion in the boiler can result in reduced SO2 emissions and conversion of fly ash and bottom ash to cement clinker. The cement clinker generated can be used as a feedstock for cement manufacture industry. An AMC- coal combustion process, which is patent protected in the United States, can result in high quality cement clinker (Global New Energy Corporation, 1999). The use of fly ash based cement clinker

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will allow cement generators to reduce conventional rotary kiln operations by purchasing this new source of cement clinker. Cement producers may be able to gain control of significant amounts of CO2 emissions by using the AMC modified cement clinker. Cement manufactured with AMC clinker can exhibit enhanced early compressive and bending strength compared to conventional cement manufactured from common silica clinker. A pilot commercial application of the production of AMC cement clinker in North America is scheduled for March 2000 at a major Canadian power plant. The AMC-coal combustion process is expected to reduce SO2 emissions up to only 90% (Global New Energy Corporation, 1999). Hence, this technology holds promise for Ohio power plants that currently use or in the future intend to switch to low-sulfur coals as compared to a majority of Ohio plants that currently use high-sulfur Ohio coal.

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9 ECONOMIC ANALYSIS

The success of an effective coal combustion products marketing program depends on the technical soundness, environmental safety, social benefit, and economic viability of many different types of CCPs for highway/civil engineering, mine reclamation, agricultural and other high-volume and/or high-value applications. The market evaluation for these applications was presented in Chapters 5,6,7, and 8. The long-term use of CCPs as raw materials in place of conventional products will be driven largely by the economics of using a cheaper material resulting in cost savings while maintaining proper performance criteria. If CCPs are economically competitive with existing products, they will replace conventional construction materials resulting in potentially high volume uses of these materials. Geographical information on the economical distance for CCP transportation on a plant basis cannot be evaluated due to non-availability of plant specific landfilling cost data.

9.1 Cost Issues

If treated and applied properly, CCPs can be useful raw materials in many different types of applications. In some cases (e.g., mine reclamation), CCPs may be the only material of choice by method of elimination because other conventional material options are not available or undesirable. In other cases, prejudice towards certain materials due to their association with “wastes” can result in CCPs being undesirable. A cost comparison between CCPs and conventional materials is valid only when both the materials are available and are desirable. In that scenario, the end user would prefer to choose the most cost-effective use option. The Federal Highway Administration (1997) has presented an excellent evaluation guideline for use of recycled materials in highway construction. In this section, the recycled material is specialized to coal combustion products and the use is generalized to highway and civil engineering, mine reclamation, agricultural, and other application technologies. Evaluation of the cost effectiveness of CCPs involves three types of costs – material cost, construction/installation cost, and life- cycle cost - all of which are inter-related to each other. A description of each of these costs and their relationships are presented below.

9.1.1 Material Cost

Material cost is the cost or price of the CCP delivered to the location of use. The user is the purchaser and could be a public agency, contractor, material supplier, private company, or an individual. The seller is typically the generator of the CCP or the ash marketer. The material cost or delivered price (CDP) of a CCP for a potential use can be defined as:

CDP = PRM + CPR + CST + CLD + CTR + P where PRM is the price of raw or untreated CCP, CPR is the cost of processing or treating it, CST is the cost of stockpiling the material, CLD is the cost of loading, CTR is the cost of transportation, and P is the profit desired by the material provider.

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The price of raw material (PRM) is the value of unprocessed CCP and is determined by the generator. The value of raw CCPs may be positive or negative. Fly ash, cenospheres, and other high demand CCPs have a positive value attached to them. On the other hand, FGD has a very low or zero value attached to it. The raw CCP may have to be treated or processed (CPR) to make it useful for a particular application. For example, many structural uses of FGD require addition of extra cementious materials (typically lime, lime fines, cement) to increase strength and durability. Some applications may require dewatering, drying, crushing etc. before being used. Gypsum production from FGD filter cake requires expensive oxidation, solid separation and moisture reduction, resulting in a high CPR cost per ton. The CCP producer is more willing to absorb the processing cost if the end-product has as high value like cenospheres, gypsum for wallboard, and fly ash for concrete, because the cost spent on processing can be recovered from the sale price of the end product. However for low value end-uses, the processing of the CCP (e.g., addition of extra lime to FGD for constructing livestock feeding pads) can impose a financial burden on the CCP producers. In this latter case, the CCP producer is effectively subsidizing a portion of the CCP use project. For example, the use of stabilized FGD material for constructing feeding pads requires the addition of about 2-3% extra lime (over and above the 2- 3% lime already present in the material to be landfilled) to the material so that adequate strengths can be achieved. The cost of lime addition is approximately $1 per 1% increase in lime content per ton of FGD. This results in utility subsidization of $2 to $ 3 per ton of FGD material used for pads. A typical FGD pad (100 feet x 100 feet x 15 inches) requires approximately 500 to 600 tons of FGD product. The utility subsidization for this FGD pad would be about $1,000 to $1,800. As the amount of additional lime to be added to the product increases beyond 2-3% (as in the case of low permeability liners, an additional 5-6% lime needs to be added to obtain low permeability values), the utility may be unable to subsidize the processing costs. In such scenarios, the end-user should be encouraged to pay for the processing costs.

After the material has been processed, it may require storage for some time before it can be transported to the intended location of use. In particular for large volume applications, if the treated CCP has to be protected from the weather, the cost of stockpiling (CST) can be quite high. The costs associated with storing the CCP include site, equipment and labor costs required to pick up the CCP, transport it to the stockpile area or silo, and to protect it from the elements of weather. FGD intended for a specific high lime application may need to be stored on the production pad for a few days before being shipped to the end user so that it can gain proper consistency to be handled. If the volume of such temporary storage or stockpiling is large, the associated CST cost could be quite high. The cost of loading the material (CLD) into a vehicle for delivery at an intended project site or production location is generally low because the labor and equipment necessary to load the CCP into trucks or other means of transport is generally available at the power plant at little or no extra cost.

The transportation cost (CTR) is the cost incurred in the transportation of the treated CCP to the proposed project location or production site. Transportation of CCPs can be by land or water. Water transportation along the Ohio River and Lake Erie has some promise, but most of the CCP transport is expected to occur by land. Land transportation of CCPs can be done by rail or trucks. Trucking is the most popular land transport mechanism for CCPs. However, trucking costs are quite high ($0.08-$0.12 per ton per mile). The CCP producer may be willing to subsidize the

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transportation cost for high value end-uses. However for lower value uses, transportation costs needs to be borne by the end-user. For most intended CCP uses, the transportation cost is the determining factor as to whether it is practical to use CCP or a conventional material for a specific project site or production facility. The profit (P) to be realized by the producer of the CCP can be evaluated in two ways. The producer of the CCP may want to make some profit on the sale of the material to recover associated costs. On the other hand, the most probable scenario would be that the generator realize most of the value in the CCP by avoiding the landfill disposal costs associated with the material.

9.1.2 Construction/Installation Cost

The end user of a coal combustion product will be interested largely in the total cost of use rather than only the cost of the materials. The total use cost is the sum total of the cost of materials and cost of construction / installation at the intended facility or production site. The installation cost (CI) for a CCP can be defined as:

CI = CDN + CCN + CTI where CDN is the cost of designing the proposed application or project, CCN is the cost of construction, and CTI is the cost associated with testing and inspection of the CCP project or product.

The analysis and design for projects using conventional materials has been streamlined with the establishment of guidelines and design criteria. However, the new use of CCPs to replace these conventional materials may require additional time and effort on part of the project designers to locate and use available design criteria. For certain new applications, established design criteria may not exist. In that case, demonstration projects that have been implemented earlier would need detailed study. The costs associated with the design and safety of the proposed CCP project or product is referred to as the design cost (CDN). The cost relating to the actual construction of the project or the preparation of the product is the construction cost (CCN). In general for construction projects, CCPs do not require any special handling, site preparation, construction or curing procedures and hence the construction costs are similar to those of conventional materials. In some cases, CCPs can be compacted in thicker lifts resulting in a net saving in construction costs. The use of CCPs to replace conventional materials in construction projects may necessitate some additional inspection and testing at the site. The costs associated with the testing and inspection (CTI) of a CCP project result largely from environmental monitoring devices installed on-site to evaluate the long-term leaching potential at the site. However, site monitoring costs should eventually subside as significant data becomes available to show that there is little potential for long-term leaching.

9.1.3 Life-Cycle Cost

The use of CCPs in a project or product may alter the maintenance procedures and or the expected service life of the project. As a result, it is important to develop a life-cost analysis for

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CCP applications. The life-cost analysis can be used to make more informed decisions about CCP use rather than only the installed cost analysis. A variety of economic approaches can be used to develop life-cycle cost models. Based on an annual effective cost approach, the annual life-cycle cost (ALC) of a CCP application can be calculated as follows:

ALC = (CDP + CI) x CRF(i,n) + CAM where CDP and CI are the delivered price and installation cost for CCP use defined earlier, CRF(i,n) is the capital recovery factor, and CAM is the annual maintenance cost.

The total cost of the project, which includes the delivered material price and the construction costs, can be spread over the product life using the capital recovery factor (CRF). The capital recovery factor is a function of a given fixed rate of interest (i) and the life of the product in years (n) and is defined as:

CRF = (i + (1+i)n) / ((1+i)n - i)

The annual maintenance cost (CAM) can be obtained from past demonstration projects or expected minor repairs at the project site over the life of the project. Determination of the annual life-cycle cost of CCP (particularly FGD) applications can be difficult since long-term historical data on their expected service life is not available at this time.

9.1.4 Total and Avoided Landfilling Cost

The discussion presented in Sections 9.1.1 to 9.1.3 focused largely on cost issues related to the end-users of CCPs. However, the interest of CCP producer (typically the utility) is economically driven to a large extent by the avoided landfill cost. The avoided landfill cost is the cost avoided by the utility due to use of the material instead of landfilling it. The total landfilling cost is generally higher than avoided landfilling cost. The total and avoided landfill costs can be significantly different for utilities with and without captive landfills.

CCP generating facilities within the state can be broadly classified into two categories depending on the ownership of the landfill in which CCPs generated at the facility are disposed. CCP producers with existing captive landfills have already made a significant capital investment in the landfills and have low landfill operating costs. CCP generators without captive landfills have no capital invested in the landfill and generally pay high landfilling operating costs depending on the distance from the CCP production facility to the landfill and costly tipping fees. Considering the total landfill cost to be the sum of landfill capital cost and landfill operating cost, it can be observed that for captive landfill CCP producers, the use of any CCP material (instead of landfilling) results in 100% savings of operating costs but only partial savings of the capital cost associated with the new phase of landfill development. Further, the full savings due to future landfill development costs are not realized until the new phase of landfill development is has been budgeted. On the other hand, utilities without captive landfills have zero capital cost investment, but high operational costs. Any material beneficially utilized and not sent to the

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landfill results in much higher cost savings for CCP generators without captive than those with captive landfills.

Current CCP landfilling costs within the state range from about $3 to $35 per ton for CCP producers with and without captive landfills. This represents the total landfilling cost and includes capital and operating costs. CCP producers with captive landfills have low total landfill costs (approximately $3 to $15 per ton). Cost of landfilling FGD material is generally lower than that of fly ash. The landfill operating cost for CCP producers with captive landfills can range from 30% to 90% of total landfilling cost. FGD material, in general, has a higher landfill operating cost as a percentage of total landfill cost compared with fly ash. However, CCP generators without captive landfills generally have much higher total landfilling costs (about $10 to $35 per ton) due to high tipping fees and relatively longer haulage distances.

9.2 Economic Analysis

Since only 8.4% of FGD generated in the state is currently utilized, most of the FGD generated is still landfilled. Landfills in general are viewed as environmental disamenities by the public. Historically, a number of public nuisance issues (e.g., odor, blowing litter, rodents, methane gas) have been associated with sanitary landfills, but these public nuisance issues are not associated with CCP landfills. The perception that landfills are environmental liabilities may result in lower perceived quality of life in vicinity of the landfills and consequently lower real estate values. Typically, the value of real estate in the vicinity of a landfill increases with distance from the facility. CCP landfill disposal costs typically range between $3 to $15 per ton for generators with captive landfills, and between $10 to $35 for generators without captive landfills. These landfilling costs are borne by the utility.

Detailed economic analyses have been carried out at The Ohio State University (Dick et al., 1999a; Dick et al., 1999b) to develop conceptual models and statistical estimates of various FGD utilization procedures for utilities. The economic analysis presented in this section reviews the analyses conducted earlier for FGD generators and discusses the economic factors that could increase CCP utilization in the state. A discussion on the economics of use for generators with and without captive landfills is presented.

9.2.1 Social Costs and Benefits

In the OSU study (Dick et al., 1999a; Dick, et al., 1999b), the hedonic pricing method was used to evaluate the impact of FGD landfilling on the value of private property as well as FGD use for reclamation of surface coal mined areas. The effects of landfills on neighboring private property values were evaluated for Franklin County. Four Central Ohio sanitary landfills (Gahanna, Grove City, Alum Creek, and Obetz), two of which were closed several years ago, were chosen for the analyses. A two-stage model was developed using real estate transaction data, census block group micro data, and household level survey data for 1990. It was found that real estate values increased as distance from the landfill increased. Other factors significantly impacting property values were the expected remaining life of the landfill and the time since closure of landfill. The

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social benefits and costs associated with the urban Franklin County study were transferred to rural FGD landfills in Ohio (Gavin, Zimmer, and Conesville landfills) using standard benefit transfer procedures (which accounted for the difference in property values in urban and rural areas). Accounting for some of the identified variables, including the expected landfill life and total capacity, but excluding differentiation between sanitary and FGD landfills, the OSU study found that landfilling FGD results in welfare loss of $1.42 per ton for Zimmer, $1.27 per ton for Gavin, and $0.31 per ton for Conesville. These estimates take into account population characteristics, density, and landfill life expectancy. However, the model presented by OSU overestimated the welfare loss since it extended data from sanitary landfills to FGD landfills, although FGD landfills are not a source of serious public nuisance such as odor, blowing litter, rodents, methane gas, etc. as compared to sanitary landfills. To account for this discrepancy, the social costs used in this study are 25% of those predicted by earlier OSU studies (Dick et al., 1999a; Dick et al., 1999b). Accounting for all the identified variables, it is estimated that landfilling FGD results in welfare loss of $0.35 per ton for Zimmer, $0.32 per ton for Gavin, and $0.08 per ton for Conesville. Using these estimates, the total welfare loss for Ohio due to landfilling of FGD is estimated to be about $0.8 million annually. Assuming that the social benefit per ton from use of other CCPs (i.e. fly ash, bottom ash and boiler slag) is similar to that of FGD, the annual economic benefit to society will exceed $2.5 million. This represents a significant societal benefit that can be realized from the recycling of CCPs as raw materials instead of the existing practice of disposing of them in landfills. As discussed in Section 6.7, reclamation of abandoned mine lands using FGD material can result in a few cents per ton of social benefit.

9.2.2 Linear Optimization Modeling

A linear optimization model was presented by Dick et al., 1999a, 1999b that considered three main high volume uses of CCPs, highway applications, reclamation of current surface mine and abandoned mine lands. Landfilling was considered as the fourth but least desirable option. A least cost of transportation model was analyzed under three different scenarios, all on an annual basis. Four FGD generating facilities were considered – Gavin, Conesville, Zimmer, and OSU’s McCracken power plants. It was assumed that the highway applications could be used for road construction and repairs in all 88 counties. For reclamation purposes, FGD was considered as a soil amendment in 21 eastern counties and for the landfill option, the four landfills in vicinity of the power plants were considered. A baseline model assuming no social costs associated with landfilling and social benefit from mine reclamation was developed. A second model added the landfilling social costs to tipping fees and subtracted social benefit of mine reclamation from application costs.

Mathematically, the linear optimization problem can be written as (Dick et al., 1999a): Minimize cost function f = cij xij such that xij < ai (i=1,2,….,m) xij = bj (j=1,2,…..,n) xij > 0 (i=1,2,….,m; j=1,2,…..,n) where ai is annual quantity of FGD available (in tons) at power plant i, bj is the maximum annual quantity of FGD (in tons) required at each destination (county) for alternative use, cij is the cost

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of unit transportation and application cost relating source i with destination j, and xij is the quantity of FGD (in tons) shipped from each source i to each destination j. The above set of equations minimize the total distribution costs assuming a linear cost model for shipping, processing, and application of FGD subject to three conditions: (1) the quantity shipped from each source to each destination should be less than or equal to the quantity of material available at source plants; (2) quantity shipped to each destination must equal the maximum annual quantity of material needed at each destination; (3) the quantity of material shipped from a source plant to a destination cannot be negative.

In the linear optimization model outlined in the previous paragraph, it was assumed that CCPs would have an adoption rate of 10% conventional use options. The transportation cost was assumed to be $.10 per ton per mile and was considered to be borne by the utility or FGD supplier. The source destinations were set at the centers of the 88 Ohio counties. Applications rates of $3.50 per ton were assumed for the highway and reclamation uses (Dick et al., 1999a). For mine reclamation, an application rate of 250 tons per acre was incorporated into the analysis.

A sensitivity analysis was presented by Dick et al. 1999a, to determine the effect of landfilling costs on the quantity of FGD that could be potentially used versus landfilled. In the model, a wide range of landfilling costs ($0 to $27.50 per ton) was investigated. Figure 9-1 shows a plot of landfilling costs versus FGD utilization and landfill disposal excluding social costs. The data presented in Figure 9-1 was tabulated for several landfilling cost values and is shown in Table 9- 1. It can be observed from Figure 9-1 that a statewide average landfilling cost of $27.50 per ton would result in 64% of the FGD material generated in the state being utilized and only 36% being landfilled. A reduction of landfilling costs from $27.50 per ton to $20 per ton results in relatively little impact on the amount of FGD that would be utilized since landfilling is still a high cost option. As the landfill costs drop below $20 per ton, FGD use for highway or mine reclamation becomes less attractive than landfilling. At $15 per ton landfilling cost, 43% of the FGD generated would be utilized, whereas at $10 per ton, only 29% of FGD material would be utilized. For landfilling cost less than $10 per ton, the utilization rate falls rapidly (see Figure 9- 1). At a landfilling cost of $5 per ton, only a small amount (3%) of FGD would potentially be used and the rest (97%) would be landfilled. As the cost of landfilling reduces below $3 per ton, there would be no incentive to utilize FGD for highway or mine reclamation uses and all of the material generated would be landfilled.

The landfilling cost for FGD in Ohio ranges from $3 to $10 per ton for generators with captive landfills and varies from $10 to $35 per ton for FGD generators without captive landfills. More than 95% of FGD material generated in the state is produced by CCP generators with captive landfills and hence the average statewide FGD landfilling cost ranges between $3 and $10 per ton with a mean cost of about $6.50 per ton. From Figure 9-1, a statewide mean landfilling cost of $6.50 per ton corresponds to utilization of 0.65 MST of FGD or 16% utilization. This projected utilization rate is almost double the 1997 utilization rate of 8.4% for FGD material (refer to Table 4-4).

It has been shown that there is significant economic incentive for utilities to promote the use of FGD for highway construction and maintenance, and surface mine reclamation. It should be noted that the model presented in this chapter (Dick et al., 1999a) only includes highway and

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surface mine reclamation applications. The linear optimization model can be modified to include potential uses such as soil amendment for agricultural soils and gypsum based products. The model could also incorporate the Niles FGD generating facility of FirstEnergy and proposed FGD generating facilities of Ohio University, City of Hamilton, and Medical College of Ohio. However, the 10% adoption rate used in the current model is quite conservative and hence the results obtained from the economic studies seem reasonable. Furthermore, the current statewide FGD utilization rate of 8.4% can be doubled to 16% in the short term if utilities continue to subsidize the transportation costs up to the breakeven point and the end user pays for the processing costs (e.g., addition of extra lime or other additives to enhance the product). However for the long term, an FGD utilization rate much greater than 16% is needed. This will necessitate that the processing and transportation costs be borne by the end-user in the long run for successful and productive utilization of FGD materials across the state of Ohio.

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15 ($ / ton) 10 Cost of Landfilling 5

0 0 0.5 1 1.5 2 2.5 FGD Alternative Uses (Million Tons)

15 ($ / ton) 10 Cost of Landfilling 5

0 1.5 2 2.5 3 3.5 4 FGD Landfilled (Million Tons)

(Source: Dick et al., 1999a)

Figure 9-1: Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled

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Table 9-1: Effect of Landfilling Cost on Amount of FGD Potentially Used and Landfilled

(Source: Dick et al., 1999a)

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10 BARRIERS TO CCP UTILIZATION

10.1 Background Information

As discussed in Sections 2.4.1 and 2.4.2, the use of coal combustion products has many technical, environmental, social, and economic advantages but also some potential drawbacks and limitations. These drawbacks and limitations can manifest themselves as barriers to CCP use. According to Sondreal et al., (1993), barriers can be classified into three main categories: a) Institutional Barriers: Restrictions on use of CCPs through requirements, standards, specifications, policies, procedures, or attitudes of organizations and agencies involved in CCP use or disposal. These include economic, marketing, environmental and public perception, and technical barriers. b) Regulatory Barriers: Federal and state legislation affecting use of CCPs. c) Legal Barriers: Contract, patent, liability and some regulatory issues.

10.2 Review of National Barriers Currently Identified

In 1982, Hudson et al. conducted an analysis of the institutional barriers to fly ash use in the state of Maryland. They identified storage and transportation of ash as the key institutional issues. More recently, GAI Consultants reviewed and identified the institutional constraints to ash use for the Electric Power Research Institute (Brendel and Kyper, 1992). The report addressed institutional barriers, but issues relating to technical and economic constraints were not addressed.

The Energy and Environmental Research Center at the University of North Dakota prepared a report for the USDOE in 1993 that addressed barriers to the utilization of CCPs in the United States (Sondreal et al., 1993). The report was based on data obtained from a large number of public and private stakeholders of CCP utilization and disposal. The study found that barriers to increased CCP utilization were complex, interrelated, and manifested themselves in numerous constraints.

Based on the study conducted at the University of North Dakota, the USDOE submitted a Report to Congress in July of 1994 (United States Department of Energy, 1994). The executive summary of the Report to Congress in attached as Appendix H. The barriers identified in USDOE’s Report to Congress were (United States Department of Energy, 1994): a) Institutional Barriers: The identified institutional barriers included lack of familiarity with potential uses, lack of data on environmental and health effects of CCP use, restrictive or prohibitive specifications, belief that ash quality and quantity are not consistent, lack of fly ash specifications for non-cementitious applications, belief that natural raw materials are more readily available and more cost-effective, viewpoint of states that EPA procurement guidelines for fly ash in concrete are a rigid ceiling rather than general guidelines. Actions by environmental agencies were seen to normally support beneficial ash uses in principle but frustrate the actual implementation by restrictive regulations (e.g., restrictive regulation of fly

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ash as a solid waste in most states, treatment of CCP structural fills and embankments as disposal, etc.), lack of state guidelines for beneficial ash use, and lack of clear federal direction on regulation of beneficial ash use. b) Regulatory Barriers: The constraints relating to regulations mainly arose as a result of the RCRA designation of CCPs as solid wastes even when they are utilized rather than disposed. Other identified barriers included inconsistency in federal and state regulations for use of by- products resulting in a confusing patchwork of incentives and disincentives. c) Legal Barriers: Legal and regulatory barriers are interrelated. In particular, environmental liability is a strong deterrent to use of any recycled material that is designated and regulated as a solid waste. CCP providers may be exposed to an overwhelming legal and financial liability for cleanup if CCPs are used and later implicated in environmental contamination. Other legal barriers identified include uncertainties in applying commercial and contract law to the sale of CCPs and confusion concerning how patent law applies to CCP applications. d) Other Barriers: These included marketing and environmental compliance constraints. Marketing barriers include low cost of disposal, compositional variability, market diversity, varying local demand, high costs of storage and transportation, lack of information on CCPs possessed by potential users, and the designation of CCPs as wastes. Additional environmental barriers include ignorance on the part of regulators and the public with regard to acceptable environmental risks and a lack of appropriate environmental test protocols.

On the basis of the barriers identified above, recommendations for action were proposed in USDOE’s 1994 Report to Congress. The criteria for making recommendations were that recommended actions should: 1) fall within budgetary and personnel resource constraints imposed by the current federal budget and manpower reduction initiatives; 2) attempt to maximize use of existing federal resources and cooperation among federal agencies; 3) be a cooperative effort of federal and state government agencies and the private sector, including industry, environmental interest groups, and private citizenry; and 4) promote an environmentally protective and beneficial increase in CCP utilization. The process resulted in several recommendations to the US Congress including: · Develop affirmative procurement guidelines for CCPs; · Develop information on advanced coal use process products to be used by EPA in continuing RCRA determinations; · Work with state and local agencies on research, and development and information transfer; · Revise or develop specifications and regulations on CCP utilization; · Demonstrate high-volume CCP utilization applications; and · Promote efforts to make new CCPs more useful. State governments were encouraged to follow the federal lead in specifications and standards in procuring products and services, revise their regulatory standards based on EPA determinations for environmentally safe pre-approved uses, and sponsor development of improved CCP utilization technologies. Private industries were encouraged to respond to increased demand for CCPs with adequate product quality assurance programs, become more involved in activities of standard-setting organizations, provide quality information on product utilization to federal and state government organizations involved in developing new standards and specifications for product use, practice environmentally sound utilization technology, and continue to support research and development work on utilization of CCPs.

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The University of North Dakota recently carried out a review of the progress made since the 1994 Report to Congress (Pflughoeft-Hassett et al., 1999). That report concluded that joint efforts by the industry and government agencies in meeting the 1994 Report to Congress recommendations have resulted in some successes but regional and nationally consistent state regulations are still elusive. Technology changes from Clean Air Act Amendments, NOx control and other emission regulations will result in changes in the quality and quantity of CCPs generated and their utilization, and this will require significant research efforts. Issues relating to quality control / quality assurance testing need to be addressed by the CCP industry. Concerns raised by environmental and public groups are expected to continue to challenge CCP uses. Additional federal procurement guidelines need to be developed to promote high-volume uses. Increased financial commitment and technical efforts are needed by the CCP industry and government agencies in a cooperative manner to continue to improve CCP uses across the nation.

Many of the barriers identified above are applicable to Ohio. In particular legal and federal regulatory barriers are applicable to all states including Ohio. The actual form of state regulatory barriers depends on the progress made in each state. Institutional barriers in general remain a major concern for all states but the types of institutional constraints for each state are quite different depending on agencies involved in CCP use and disposal.

10.3 Barriers to CCP Use in Ohio

National barriers to CCP use and proposed mechanisms for their removal were discussed in Section 10.2. Many of these constraints to CCP utilization are applicable to Ohio. In this section the regulatory, legal, and institutional barriers to CCP utilization particular to Ohio are identified. A description of each of these barriers follows.

10.3.1 Regulatory Barriers

10.3.1.1 Federal Regulatory Barriers

The Resource Conservation and Recovery Act (RCRA) legislation designated CCPs as solid wastes, irrespective of whether they were utilized or disposed in a landfill. Thus, CCPs which are beneficially utilized as well those landfilled are treated alike under federal regulations. This results in treating all end means of disposal of CCPs as the same, although there are significant benefits of utilization. Other laws that can be applied to the use of CCPs include the Clean Water Act of 1972, Safe Drinking Water Act of 1974, Toxic Substance Control Act of 1976, and Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) or the Superfund Act.

The Toxic Release Inventory, which requires non-utilized CCPs to be reported, is expected to result in negative publicity about coal-fired facilities and could have potentially damaging effect

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on markets for CCPs. Emission control restrictions that may be implemented in the future by USEPA include NOx control and additional SO2 reductions. Other regulatory programs on the horizon may include restrictions on mercury and naturally occurring radioactive material (NORM) in CCPs. These regulations, when implemented, will directly affect the quality and quantity of CCPs generated in Ohio. Markets for some of the most promising uses of CCPs may be reduced or lost. As an example, the proposed NOx rules are expected to increase the carbon and chemical content (particularly ammonia) in fly ash, resulting in potentially large quantities of ash being rendered unusable as an admixture in concrete.

Regulations of CCPs by state EPAs have resulted in each state adopting its own set of regulatory guidelines for the use and disposal of CCPs. A patchwork of conflicting state regulations has ensued. Thus, transport of CCPs across state boundaries even when the proposed use is clearly beneficial is hindered. As can be seen from Appendix G, the regulations in the states neighboring Ohio are quite diverse with the result that markets are limited mainly to the state producing the CCP. The development of regional and national regulations governing CCPs needs to be explored to expand markets beyond state boundaries.

A recent report, Wastes From the Combustion of Fossil Fuels, by USEPA to the US Congress (United States Environmental Protection Agency, 1999) is a step forward because it reaffirms the position that most uses of CCPs are protective of human health and the environment. However, concerns about agricultural and mine filling applications were raised. A final regulatory determination is expected to be made by USEPA by March 10, 2000.

10.3.1.2 State of Ohio Regulatory Barriers

Ohio Environmental Protection Agency (OEPA) regulates non-toxic fly ash, bottom ash, and boiler slag as exempt wastes, i.e., they are excluded from the statutory definition of solid wastes. However, FGD material is regulated much more restrictively as a residual solid waste. FGD is typically made up of fly ash, sulfites and/or sulfates of the reagent, unspent reagent (mostly lime or limestone), and water. Research conducted at The Ohio State University (Stehouwer et al., 1995) has shown that elements regulated by OEPA for solid waste materials reside primarily in the fly ash fraction of FGD and the trace elements of concern to OEPA are generally lower in concentration in FGD than in the exempt fly ash because of the presence of sulfites and sulfites of the reagent, and unspent lime. Thus, although the concentration levels of most elements of concern for solid wastes are less in the FGD and its leachate compared to fly ash and its leachate, FGD is nevertheless regulated more stringently than fly ash. This is one of the major barriers restricting the increased utilization of FGD in Ohio.

The utilization of many CCPs in highway and construction related, mine reclamation, agricultural, and manufacturing applications has shown to result in better products, decrease in need for landfill space and emphasis on recycling, conservation of natural resources of the state, avoidance of disturbance caused by borrow areas, cleaner and safer environment, reduced social costs, and potential for economic development. Irrespective of whether these materials are utilized or landfilled, they are currently viewed from a regulatory perspective as “wastes.” A

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more rational approach would be a regulatory recognition of CCPs in established markets as produced co-products rather than wastes.

Construction projects utilizing high volumes of CCPs may in the future be modified, reconstructed, or even removed and be transported to other locations. A factor presently restricting the use of FGD in highway construction may be the lack of regulatory guidance by OEPA on the secondary use of FGD materials.

The 1997 transition of CCP regulation from a beneficial use policy to an Interim Alternative Waste Management Program (IAWMP) has resulted in beneficial uses taking a step backward and categorized as alternative disposal options. The IAWMP management directive seems to imply that the use of CCPs is an alternative disposal option, without much regard for its benefits. This has resulted in more stringent regulation of FGD for engineered uses than seems to be scientifically warranted. Under current IAWMP guidelines, for many FGD engineered uses the authorization of the Director of OEPA needs to be obtained. The transition from the interim program to a long-term waste management program has been significantly slower than expected and potential end users have been left with few options but to wait until the long-term program is in place. In the meantime, FGD use projects are approved on a case-by-case basis. Frequent personnel changes and increased workloads at OEPA have made this procedure unpredictable.

Regulatory authority for CCP use at ODNR-approved mine sites has historically been shared by OEPA and ODNR. Recent changes to ORC 1513, by the Amended Substitute Senate Bill 187 of the 122nd General Assembly, have transferred regulatory authority to the Director of ODNR- DMR for use of CCPs at coal mining and reclamation operations and abandoned mine lands that are regulated by DMR. This should result in increased use of CCPs, particularly FGD material, for reclamation of abandoned and currently mined lands.

An increasing number of CCP related projects are now referred to OEPA district offices for review. Since opinions on CCP use vary from one district to another, an inconsistent project approval process results. Approval often depends on the technical expertise of the local officials reviewing the proposed CCP application technology. There also appears to be a general lack of technical exchange and information review between OEPA and the state’s research community.

10.3.2 Legal Barriers

The principal legal barrier to CCP use is environmental liability. Although most CCPs uses have been determined by USEPA to be non-hazardous and placed under Subtitle D of RCRA, this does not exempt CCPs from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. Since environmental liability is not fault based, the extensive database of information generated on the non-hazardous and non-toxic nature of CCPs does not provide protection against CERCLA liability. Other federal legislation that may cover CCP use include the Clean Water Act of 1972, Safe Drinking Water Act of 1974, and Toxic Substance Control Act of 1976.

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Other major issues that act to slow CCP use are existing commercial, contract and patent laws. Currently, there is a lack of technical specifications and environmental criteria that can be applied to many CCP uses. Therefore difficulties result in applying commercial and contract law to the sale of these materials. Many CCP patents (such as flowable fill uses) that are currently held involve general broad claims, which may not be much different from common public practices, resulting in potentially unnecessary restrictions on certain types of CCP applications.

10.3.3 Institutional Barriers

The institutional barriers to CCP utilization in Ohio can be classified into four categories: economic, marketing, environmental and public perception, and technical. A detailed description of each of these barriers is presented below.

10.3.3.1 Economic Barriers

The driving force of any new technology or product use is the economics of utilization. Hence, economic barriers are the key barriers to CCP use. For coal-fired facilities in Ohio, CCP landfilling costs typically range from $3 - $15 and $10 - $35 for producers with and without captive landfills, respectively. From Figure 9-1 it can be seen that as disposal costs drop below a certain amount ($10 per ton), the incentive for utilization of FGD for highway and mine reclamation uses reduces and landfilling is the preferred option. High volume CCP producers with captive landfills, particularly those that generate FGD, currently have low landfill disposal costs due to capital expenditures that have already been committed towards existing landfills. Thus the advantages to CCP utilization are viewed as marginal savings in operational costs. CCP sale revenues are much less compared to electricity revenues, and hence there isn’t enough commitment of manpower and resources to promoting the utilization of CCPs as a preferred option over landfill disposal. As the capacity of existing landfills and their residual life expectancy reduce, and tipping fees increase for CCP producers without captive landfills, there will be a strong impetus towards utilization of CCPs by generators with and without captive landfills.

The transportation of CCPs from the production site to the intended utilization site are added costs that must be borne by the CCP provider, marketer, and / or the end user. Wet FGD that is produced in large quantities in the state has a high moisture content resulting in a bulky material that needs to be transported. At the present time, FGD use by the end users is economical in many parts of the state if the producer absorbs some or all of the transportation costs. This results in additional costs to the generator, which has to balance this expenditure for transportation with savings from avoiding landfill disposal and decide under what terms it is willing to provide the material for use at the project site or at the generating facility. While fly ash and bottom ash have some value attached to them, FGD currently has a low or zero value attached to it. Thus it would be virtually impossible for an FGD marketer to exist unless the end use has a high volume and / or high value attached to it.

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The design and site monitoring costs for projects using CCPs are expected to be higher than those involving conventional materials. The lack of availability of industry accepted technical specifications and design criteria results in higher design costs because much of the information needed for the design of the project has to be researched and obtained from demonstration projects. In order to alleviate concerns relating to potential long-term pollution, many end users, particularly state agencies, may require site monitoring for high volume uses of CCPs. This involves the installation of potentially expensive site devices and their regular monitoring. The costs involved with site monitoring reduce the economic viability of using recycled and new materials such as CCPs.

10.3.3.2 Marketing Barriers

The use of a CCP in an existing market displaces some of the conventional materials currently being used. Many end users believe that conventional materials are cheaper and more readily available than recycled or non-traditional materials. This is not always true. The market volume taken over by CCPs will be replacing some of that other raw material, and this can result in opposition from marketers of the conventional materials. The opposition can manifest itself as negative publicity campaigns and political lobbying against CCP utilization.

The existing uses of FGD in the state are generally low-volume, low-value applications. High- volume and high-value uses are currently lacking. Mine reclamation uses which can be high- volume technologies with significant environmental benefits are currently being implemented. The use of FGD for reclamation applications occurs in the eastern one-third of the state, while agricultural uses potentially are promising mainly for the northern part of Ohio. Highway applications are equally applicable to all parts of Ohio. This results in varying demands across different regions of the state. Marketing issues are further compounded by the fact that some FGD engineered applications require longer curing time (60 days) before being exposed to freezing temperatures compared to conventional materials. This results in FGD use in Ohio being non-uniform across the state and non-continuous throughout the year.

The variability in the composition of CCPs has been a particular concern that has far reaching marketing impacts. End users generally expect a consistent quality of the product for use in a proposed project. Inconsistent quality of CCPs delivered to a site can result in a degradation of the facility constructed or product manufactured, and potential problems relating to rejection of unusable material. Assurance of delivery rates by CCP generators has been identified as another barrier to usage in many potentially large-volume CCP projects. Project construction can be significantly delayed if the materials are not delivered on time and if the quality of the delivered material varies widely.

The Ohio Chapter of the American Coal Ash Association was formed in 1989 to promote the use of CCPs across the state through research and development, technology transfer, education, and awareness programs. Membership includes coal ash producers, marketers, and other suppliers of coal-ash related goods and services. The Ohio Chapter works with the Ohio Coal Development Office, Ohio State University, ACAA national, and others in its promotional activities. The Ohio Chapter has experienced reorganization changes due to the consolidation of the CCP producers

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industry and the marketers, and staff reductions. Currently, the chapter is restructuring and will continue to be effective in promoting CCP uses, particularly in highway and civil engineering related construction and repair activities. Several statewide and county as well as material specific recycling organizations exist in Ohio. The Ohio’s Materials Exchange (OMEx) formed in 1998 promotes the use of recycled materials (including CCPs) within the state and is a cooperative effort of OEPA, ODNR, ODOD, Association of Ohio Recyclers, and Ohio Waste Alternatives Inc. The OMEx recycling newsletter, which advertises materials available and wanted for recycling, has experienced continuing funding problems. A list of local and material specific exchange programs (including the CCP Pilot Extension Program) in the state is included as Appendix J. Efforts by statewide and local recycling and marketing organizations need to be intensified so that they are more effective in promoting the use of recycled materials.

The existing technology transfer / market development program currently in place at The Ohio State University is a pilot program that works to promote the responsible uses (technically sound, environmentally safe, and commercially competitive) of CCPs in the state. The program coordinator acts as liaison among CCP stakeholders in the state, produces information sheets, provides expertise in the field to those who wish it, sponsors and co-sponsors seminars, meetings, workshops, and speaking at these events, and generally works to promote knowledge about the productive and proper applications of CCPs as useful raw materials. The pilot program has been very effective in promoting CCP uses as a part of the extension mission of the university and is viewed by regulators, CCP producers, end-users, trade groups, and other stakeholders as a voice of trust. Continuing financial commitment and technical resources for the program at the university are lacking. If the activity is to continue, it will need to find resources in conjunction with government and private sector organizations and industry.

Procurement guidelines issued by the federal government for use of fly ash have had little or no impact on CCP use in Ohio. In fact, compliance with the federal procurement initiatives has been ineffective in many states across the nation because of the lack of incentives to end users to use recycled materials in federally co-funded construction projects.

10.3.3.3 Environmental and Public Perception Barriers

Coal combustion products are perceived by many in the general public as “wastes.” This is one of the primary negative connotations associated with CCPs that also manifests itself in the regulatory structure. Contrary to scientific evidence, some in the environmental and public sector believe CCPs should be treated as hazardous wastes even though the amounts of various chemical constituents in CCPs do not warrant this designation under laws and regulations. This position can result in unnecessarily restrictive regulation of these materials and negative campaigns by citizen groups. Some environmental groups are concerned with the potential long- term effects of pollution at proposed CCP application sites. Working with influential environmental groups in the state and locally to educate their memberships and thereby obtain acceptance for proposed uses is necessary.

The general public is either unaware about CCPs or has unwarranted negative opinions regarding these materials. There exists confusion among the public and regulators about coal fly ash being

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similar to incinerator ash, although the chemical, physical, mineralogical, and engineering characteristics of the two materials are vastly dissimilar. This lack of CCP education is also known to exist among engineers, architects, contractors, state, county, and local public agencies. In the absence of accurate information, stakeholders such as engineering and consulting firms, who design most construction related projects, are uncomfortable in recommending CCP-related projects due to the technical and liability issues involved. Lack of information about new materials generally manifests itself in continued use of existing materials even though new non- conventional materials may be cheaper and more readily available.

Many members of the public view many industries, such as chemical companies and coal-fired power plants, to be sources of pollution. Any material generated at such a facility is by implication a pollutant or hazardous material. Such a perception is unwarranted and can result in potentially damaging effect on CCP uses. An example is the expected effect of the Toxic Release Inventory (TRI) on the CCP industry. It has been projected that the information released by coal- fired utilities under TRI may hurt CCP utilization efforts but the extent of the impact of TRI is currently unknown.

The impact of CCP use on the environment has been evaluated in the laboratory using the Toxicity Characteristics Leaching Procedure commonly referred to as the TCLP test (Code of Federal Regulations, 1991), ASTM D 3987 leaching procedure (American Society for Testing and Materials, 1992), and the Synthetic Precipitation Leaching Procedure commonly referred to as the SPLP test (United States Environmental Protection Agency, 1988). All these leaching tests are short duration tests (18 to 24 hours). The TCLP procedure specified by RCRA was developed for identification of hazardous wastes when co-disposed in a sanitary landfill. The validity of these leaching procedures for monofills has recently been questioned (Hassett, 1991; Hassett and Pflughoeft-Hassett, 1993). Additionally, most regulations impose mandatory leachate testing on the CCP as a raw material for a proposed product but rarely require leaching results for the final product. The chemical and mineralogical characteristics of the final product may reduce the availability of potential contaminants by binding them in a new cementious matrix.

In many cases, regulation of CCPs is implemented based on the perception of a potential problem, and not on actual research information available in literature. A large database of technical information on CCP characteristics and their response to as well as effect on a variety of environmental conditions is available for review to regulatory agencies. However many regulatory agencies do not have the resources to review the available data. This can result in unnecessarily restrictive regulations based on perceived potential problems and not on scientific data.

10.3.3.4 Technical Barriers

A major technical drawback to CCP use is the lack of engineering specifications and standards for the testing, design and construction of CCP related projects. Specifications and guidance documents for several uses have been prepared nationally and are presented in Appendix F. However, the scope of most of these specifications is limited to certain types of uses of fly ash. Reliable standard guidance documents need to be prepared for all CCPs that are currently in use.

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In particular, ODOT’s current specifications allow only the use of fly ash in concrete and flowable fill applications (refer to Sections 5.9.2 & 5.9.3). This has resulted in reduced use of CCPs by county, township and municipal engineers, all of which follow the specifications set forth by ODOT for the construction and repair activities within their jurisdiction. Recommendations to broaden and augment ODOT specifications for safer and greater uses of CCPs have been presented in Section 5.9.4 and Table 5-6.

Some of the technical concerns relating to engineering properties of CCPs are the durability of some of these materials under harsh environmental conditions. The effect of freeze-thaw cycling on the strength of FGD can be detrimental if the FGD does not contain a certain minimum amount of lime. Additionally, it must be cured for 60 days before being exposed to freezing temperatures. For fly ash, bottom ash, and wet FGD, the swell potential is quite low and similar to common soils. However, some dry FGD materials may be more prone to swelling than others and could result in them being less suitable for large-volume embankment or structural fill applications. Potential swell problems relating to CCP use in structural fills can be identified in the laboratory using test procedures ASTM E1861-97 (American Society of Testing and Materials, 1997a) and ASTM D3877 (American Society of Testing and Materials, 1997b). Concerns relating to bio-accumulation of trace elements, boron toxicity, and soluble salt content of some CCPs persist for agricultural applications. In general, the long-term behavior of FGD in the environment has been investigated but consensus on this issue has not been achieved. Studies on the effect of high carbon and ammonia content on fly ash uses due to proposed NOx control regulations are not yet fully understood.

Moving from the research and demonstration phase to the marketplace involves the implementation of a technology transfer program. Such a program is critical to the development of standard procedures based upon the large amount of information learned from the many Ohio field studies and trials so that end users may benefit from the results and recommendations of completed research. The lack of CCP technology transfer programs across the nation is a major institutional barrier to CCP use in the United States. Ohio has been one of the first states in the nation to establish a CCP Pilot Extension Program at The Ohio State University in collaboration with state and federal agencies, utility and related industries, and trade organizations.

10.4 Recommendations for Removal of Barriers

In Section 2.4.2 the drawbacks of using CCPs and suggestions to overcome these barriers were discussed. The national barriers to CCP utilization and proposed mechanisms to reduce and / or eliminate these barriers were presented in Section 10.2. Barriers specifically relating to CCP use in Ohio were discussed in Section 10.3. In this section, recommendations are presented for the removal of the barriers identified in this report. In developing these recommendations, the following basic criteria were considered: · Recommendations must be environmentally protective; · Recommendations must increase the amount and type of CCP uses in Ohio; · Recommendations should encourage the use of CCPs across the state and not be limited to certain geographical regions or counties;

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· Recommendations should not involve significant increase in budgetary and personnel resources currently available to state and federal agencies; · Recommendations should account for the diverse nature of CCPs generated in Ohio, particularly fly ash and FGD; and · Recommendations with long-term solutions should be preferred over those resulting in only short-term gains.

Based on the drawbacks and barriers to CCP use identified earlier and the recommendation criteria presented above, the following specific actions are recommended:

Recommendation No. 3: ODOT should review its current specifications with regard to fly ash, bottom ash, boiler slag, and FGD, and incorporate the additional uses of CCPs into ODOT specifications. (Refer to Sections 5.9 and 10.3.3.4)

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beneficial reclamation uses, durability issues, effects of new emission restrictions (e.g., NOx control), chemical forms of elements of concern in CCPs and their solubility and mobility in the environment, and long-term effects. (Refer to Section 10.3.3.4)

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11 SUMMARY AND CONCLUSIONS

11.1 Status of CCP Industry

Current coal consumption for Ohio exceeds 50 million tons annually, with almost half of this coal being mined in the state. Coal-fired electric utilities account for 90% of the coal consumed and supply nearly 90% of the state’s electricity. The combustion of such a large quantity of coal leads to enormous amounts of coal combustion products (CCPs). CCPs, which include fly ash, bottom ash, boiler slag, and flue gas desulfurization (FGD) material, can be utilized, or disposed in landfills or surface impoundments. The annual production of CCPs for the state is nearly 10 million tons. Total annual tonnage of CCPs generated in Ohio equals that of portland cement and ranks behind only crushed stone, sand, and gravel among all non-fuel mineral commodities.

Currently, CCPs are exempt from Subtitle C of the Resource Conservation and Recovery Act (RCRA), and are regulated by most states as solid wastes. A recent decision by USEPA (Federal Register, Part III, EPA, 40 CFR Part 261, dated May 22, 2000) has reinforced the non-hazardous nature of CCPs. Ohio regulates fly ash, bottom ash, boiler slag, and FGD as solid wastes through the Ohio Environmental Protection Agency (OEPA). In particular, non-toxic fly ash, bottom ash, and slag are regulated as exempt wastes, i.e., they are exempt from the statutory definition of solid waste. FGD is considered to be an air pollution control waste and is regulated as a residual solid waste. The regulation of FGD as a residual solid waste, as compared to non-toxic fly ash as an exempt waste, has resulted in increased regulatory restrictions on the use of FGD materials. The beneficial use policy of OEPA was replaced with an Interim Alternative Waste Management Program (IAWMP) in 1997, which effectively replaced beneficial use with alternative disposal option. Under IAWMP, two types of alternative disposal options were made available, engineered use, and land application. The IAWMP regulatory procedures currently followed by OEPA depend on the type of CCP and its intended use as well as the proposed use of the facility. The beneficial use policy developed in 1994 by the Division of Surface Water is still regarded as a guidance / policy document. The Long Term Alternative Waste Management Program (LTAWMP) was scheduled to be in place by July 1999. While some progress on the issue has been made, the deadline has not been achieved.

The advantages of using CCPs instead of the current practice of landfilling them include, 1) emphasis on recycling and decrease in the need for landfill space, 2) conservation of natural resources of the state, 3) better products and significant technical benefits, 4) reduction in the cost of energy production for utilities, 5) substantial savings for end-users, 6) continued economic competitiveness of high-sulfur Ohio coal, 7) cleaner and safer environment, 8) reduced social costs, and 9) greater economic development. The potential drawbacks and limitations of CCP utilization are - 1) increased haulage cost and associated disturbance, 2) variability of material, 3) opposition from established raw material marketers, 4) potential for long-term effects, 5) increased design and monitoring costs, 6) bulky nature of FGD, 7) litigation potential, and 8) durability concerns. These technical, environmental, social, and economic issues need to be in balance for the effective use of a CCP for a particular application. Successful CCP uses will

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be those that are technically safe, environmentally sound, socially beneficial, and commercially competitive, as with any other raw material or product of commerce.

Thirty-three coal-fired facilities operating in the state of Ohio were surveyed. These facilities generated approximately 9.23 million short tons (MST) of CCPs in 1997 (on a dry weight basis). This consisted of 4.76 MST of fly ash, 0.97 MST of bottom ash, 0.35 MST of boiler slag, 2.68 MST of FGD (dry weight basis), and 0.47 MST of mixtures of fly ash, bottom ash, boiler slag, and cenospheres. The FGD production in the state is high due to the use of high-sulfur coal by FGD scrubbers complying with Clean Air Act Amendments of 1990. The Gavin plant (GAV) produced 25% of all CCPs and accounted for nearly 60% of FGD generated in the state. The largest generator of fly ash and bottom ash in the state was the J.M. Stuart station (JMS). The Muskingum River plant (MUS) generated 42% of all boiler slag produced in Ohio. Fly ash and bottom ash combined account for nearly 67% of CCP production, while FGD generated in the state was 29% of all CCPs produced in 1997. The state has five FGD generating facilities. Four of these facilities, Zimmer, Conesville, Gavin, and Niles, employ a wet scrubbing process, while the OSU McCracken plant generates a spray dryer ash. The moisture content of wet FGD typically ranges from 30% to 60%. Hence, the amount of wet FGD generated in the state for 1997 ranged between 3.4 MST and 4.2 MST, with an average annual production rate of approximately 3.8 MST per year.

Of the CCPs generated in Ohio, 21% were utilized. Approximately 23.4% of combined fly ash and bottom ash generated, 74.7% of bottom ash generated, but only 8.4% of FGD generated in the state was utilized. Of the total CCPs utilized, fly and bottom ash accounted for 75% of the use, boiler slag (13.4%), and FGD (11.6%). For fly ash and bottom ash, over 40% of the use was in cement / concrete / grout applications while structural fills accounted for 32.5% of use. About 86% of the boiler slag utilized was for blasting grit and roofing granules. Other boiler slag uses were structural fills, and snow and ice control. For FGD material, major uses included wallboard industry consumption (33.3%), mining and reclamation applications (24%), and miscellaneous uses (42.7%). Miscellaneous uses included FGD feeding and hay storage pads and material used in various research and field demonstration projects.

The interest of the CCP producer (typically the utility) towards utilization instead of landfill disposal is economically driven to a large extent by the avoided landfill cost. The avoided landfill cost is the cost avoided by the utility due to use of the material instead of landfilling it. The total landfilling cost is generally higher than avoided landfilling cost. The total and avoided landfill costs can be significantly different for utilities with and without captive landfills. CCP producers with existing captive landfills would have made a significant capital investment in their landfills and generally have low landfill operating costs. CCP generators without captive landfills have no capital invested in any landfill and generally pay high landfilling operating costs depending on the distance from the CCP production facility to the landfill and costly tipping fees. Considering the total landfill cost to be the sum of landfill capital cost and landfill operating cost, it can be observed that for captive landfill CCP producers, the use of any CCP material (instead of landfilling) results in 100% savings of operating costs but only partial savings of the capital cost associated with the new phase of landfill development. On the other hand, utilities without captive landfills have zero capital cost investment, but high operational costs. Any material beneficially utilized and not sent to the landfill results in much higher cost

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savings for CCP generators without captive than those with captive landfills. Current CCP landfilling costs (capital and operating) within the state range from about $3 to $35 per ton for CCP producers with and without captive landfills. CCP producers with captive landfills have low total landfill costs (approximately $3 to $15 per ton). Cost of landfilling FGD material is generally lower than that of fly ash. The landfill operating cost for CCP producers with captive landfills can range from 30% to 90% of total landfilling cost. FGD material, in general, has a higher landfill operating cost as a percentage of total landfill cost compared with fly ash. However, CCP generators without captive landfills generally have much higher total landfilling costs (about $10 to $35 per ton) due to high tipping fees and relatively longer haulage distances.

11.2 Future of CCP Industry

Traditionally, the majority of coal combustion products (CCPs) generated in Ohio have been disposed in landfills or stored in surface impoundments. Identification and promotion of cost- effective programs for the use of these raw materials (particularly FGD and fly ash), instead of storage and disposal, has been one of the cornerstones of the energy strategy for Ohio (Ohio Energy Strategy Interagency Task Force, 1994). The recycling of these raw materials is important to help maintain the economic competitiveness of high-sulfur Ohio coal.

Many coal combustion products are separated from other product streams. If treated and applied correctly, they can have versatile properties that make them suitable raw materials for many applications. The potential uses are divided into - highway, reclamation, agricultural, manufacturing, other civil engineering and miscellaneous uses. Several different types of application technologies for each broad category are identified and are listed in Table 2-5. It can be observed from Table 2-5 that wet and dry FGD have promising applications for many different types of uses. The potential high-volume uses for FGD are in highway construction and maintenance all over the state and related civil engineering applications, reclamation in the eastern one-third of the state, and wallboard manufacture. High-value markets exist for CCP uses in the manufacturing industry. Agricultural uses will generally be low-volume and low-value uses for utilities but are increasing in demand by the agricultural community. Significant environmental benefits from reclamation can result due to reduction in acid mine drainage, offsite sedimentation, and subsidence problems. Economic benefit to utilities will be greater for high-volume and high- value applications compared to low-volume and value products. Economic benefits for end users can be significant and depend mainly on the cost of competing conventional materials, processing of CCPs (if any needed), haulage distance and its associated costs.

The maintenance of nearly 113,550 miles of Ohio roads and highways means that highway / road applications of CCPs are potentially the highest volume uses with markets all over the state. The various existing and potential uses of CCPs for highway applications include portland cement and asphalt concrete, embankment and structural fill, stabilized base / sub-base, flowable fill, and subsidence control grout (refer Table 5-1). Potential savings of about $37 million per year can be realized by Ohio Department of Transportation (ODOT), county, townships and municipalities by using CCPs in the maintenance of highways and roads across the state. Cost savings of 25% to 40% are expected for the use of FGD in highway embankments. The current

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use of about 620,000 tons of fly ash for cement/concrete/grout applications is expected to increase provided the ash is not impacted significantly by high LOI or ammonia. Currently, state CO2 emissions are reduced annually by more than 500,000 tons because the use of fly ash admixtures replaces cement in concrete and grout applications. Increased use of fly ash concrete will result in greater CO2 emission reductions, thus making fly ash concrete an environmentally preferable product. The NOx rules proposed by USEPA will result in an increase in the Loss on Ignition (LOI) and / or chemical content (particularly ammonia) of some fly ashes generated in the state of Ohio. The increased carbon and ammonia content of the ash is expected to result in a detrimental impact on the properties of fly ash and its marketing. A 1998 survey conducted by the American Coal Ash Association reported that out of 20 responding coal-fired generating facilities from Ohio, 19 are expected to be affected by the proposed NOx guidelines. A court stay was recently issued on the proposed NOx rules and a ruling is not expected till the year 2000. However, some sort of NOx control and or other emission control regulations are expected to be implemented by USEPA and OEPA in the next 5 years. Manufactured aggregate from FGD could be used in large volumes for road construction applications. The successful implementation of high-volume CCP uses in Ohio will require a significant initiative on the part of ODOT to review and revise its specifications (refer Table 5-6), particularly for fly ash and bottom ash, and vigorous technology transfer educational efforts aimed at ODOT, county, local township, and municipal project engineers and personnel, and other regulatory agencies.

Mine reclamation uses can be potentially high-volume applications. These markets will be concentrated in east and southeast Ohio. The potential for FGD and fly ash use in reclamation work exists for abatement of acid mine drainage, sedimentation control, and subsidence control and repairs. Surface reclamation (abandoned and current mined lands) as well as underground placement of CCPs are promising uses. Of the $209 million uncompleted reclamation work documented under the Abandoned Mined Land Inventory System (AMLIS), over $100 million worth of reclamation work has potential for FGD utilization. In a typical year, Ohio Department of Natural Resources – Division of Mines and Reclamation (DMR) funds approximately $2.5 million of reclamation work. The major use of FGD for abandoned mine lands is expected to be for reclamation of gob piles and spoil areas. Reclamation of gob piles was shown to result in savings ranging from $8,350 to $12,600 per acre for DMR. The potential economic saving to DMR for reclamation of unreclaimed gob piles across the state using FGD is estimated to be about $8 million. In many cases conventional construction materials like clay and resoil material may not be available and by the process of elimination FGD may be the best or the only suitable material to be used for reclamation. The current lack of utilization of FGD in existing surface mining operations permitted by DMR may be attributed to the sufficient availability of conventional materials and the limited exposure to the potential of FGD utilization. As FGD use in other reclamation applications becomes more common, operators may choose to incorporate FGD into site reclamation. FGD utilization will become more attractive to operators hauling coal to plants from which FGD can be brought to the project sites as haulback. Haulback potential from CCP generating facilities to operating mining operations using trucks as the means of transport exceeds 12 million tons per year across the state. Co-mixing of sulfite rich FGD with coal refuse to mitigate acid mine drainage has a potential annual market volume of about 1.5 million tons. Underground placement of FGD and fly ash based grouts to control and avoid subsidence is of interest to DMR and ODOT. About 6,000 abandoned underground mines are found in 38 Ohio counties. Mine subsidence problems related to highway repairs can be

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expensive (in the range of several million dollars). Due to the potential risk of mine subsidence under highways, ODOT has developed a mine inventory and risk assessment manual (Manual for Abandoned Underground Mine Inventory and Risk Assessment) outlining procedures for site investigation, evaluation, monitoring, prioritizing, remediation, and emergency action. Fly ash and FGD based cement grouts could be used for the cost-effective remediation of emergency collapse projects. In addition, underground mined areas near highways that are prone to subsidence can be pressure grouted as a precautionary measure so as to avoid future potential risk to human life and costly emergency repairs. The volume of grout that could be used on each subsidence project depends on the extent of mine voids that would need to be filled, and in general will be a high volume application involving several thousand tons of grout per project. CCPs can also be potentially used to mitigate acid mine drainage from underground mines.

Other agricultural uses such as FGD livestock feeding and hay storage pads are 25% to 60% cheaper than stone aggregate pads, and 65% to 80% cheaper than concrete livestock pads installed at Ohio farms. Many FGD generating facilities are in vicinity of major livestock inventory areas. The use of FGD for constructing lined ponds and livestock manure holding facilities instead of clay or geomembranes, could result in savings of as much as $2-3 per square foot. A significant reduction in the cost of lined facilities will make some projects feasible, which may result in an increase in the agricultural activity within the state, particularly livestock operations. With the development of surface impoundments lined with a low-cost alternative to clay or concrete, a variety of animal prep facilities could become more financially viable, increasing substantially the economic base of affected counties in the Appalachia region. Liners for constructed wetlands hold promise as a cost-effective substitute for geocomposite clay liners (estimated savings of about $34,000 per acre). The low-permeability characteristic of many FGD materials has promise for the use of compacted FGD as a landfill cap, daily cover, and containment liner in place of commonly used clay. For a medium-sized landfill of 100-acre footprint, more than half million tons of FGD could be used for cap construction, and the resultant cost savings at closure are expected to be about $ 5 million (based on 1996-97 cost data).

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for traditional wet scrubber products depending on the economics of oxidation and dewatering the FGD. Magnesium hydroxide can be economically recovered from magnesium-enhanced lime scrubbing systems and subsequently used for wastewater sludge treatment. Several benefits result from the recovery of magnesium hydroxide. First, the utility is able to recover the magnesium hydroxide reagent from the FGD process and generate income from its sales, and at the same time save some of the costs associated with decreased landfill disposal. The end user, wastewater plants, would have access to a cheaper acid waste neutralization reagent, which could be as effective as commercially available reagents. The societal benefit would be an improved quality of the environment into which the wastewater is discharged as well as the treatment of pollution at its source rather than after it enters the natural environment. The potential markets for the recovered reagent will be cities and towns within a reasonable distance from magnesium- enhanced lime scrubbers. Fly ash or cenosphere-enhanced plastics, alloys, composites, and ceramics are high-value products and the use of these materials for filler applications is expected to generate more durable and lighter products. Carbon extraction from high-carbon fly ashes may result in two sellable products - high quality carbon for the steel industry, and low-carbon fly ash for use in cement replacement applications.

Results from a linear optimization model for the three main high volume uses of CCPs, highway applications, reclamation of current surface mine and abandoned mine lands with an adoption rate of 10% were presented and discussed. In the model, landfilling was considered to be the fourth but least desirable option. It was assumed that the highway applications could be used for road construction and repairs in all 88 counties. For reclamation purposes, FGD was considered as a soil amendment in 21 eastern counties and for the landfill option, four existing FGD landfills in vicinity of the Gavin, Conesville, Zimmer, and OSU McCracken power plants were considered. The transportation cost was assumed to be $.10 per ton per mile and was considered to be borne by the utility or FGD supplier. The source destinations were set at the centers of the 88 Ohio counties. Applications rates of $3.50 per ton were assumed for the highway and reclamation uses. For mine reclamation, an application rate of 250 tons per acre was incorporated into the analysis. A sensitivity analysis was presented to determine the effect of landfilling costs on the quantity of FGD that could be potentially used versus landfilled. It was concluded that a statewide average landfilling cost of $27.50 per ton would result in 64% of the FGD material generated in the state being utilized and only 36% being landfilled. A reduction of landfilling costs from $27.50 per ton to $20 per ton results in relatively little impact on the amount of FGD that would be utilized since landfilling is still a high cost option. As the landfill costs drop below $20 per ton, FGD use for highway or mine reclamation becomes less attractive than landfilling. At $15 per ton landfilling cost, 43% of the FGD generated would be utilized, whereas at $10 per

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ton, only 29% of FGD material would be utilized. For landfilling cost less than $10 per ton, the utilization rate falls rapidly. At a landfilling cost of $5 per ton, only a small amount (3%) of FGD would potentially be used and the rest (97%) would be landfilled. The landfilling cost for FGD in Ohio ranges from $3 to $10 per ton for generators with captive landfills and varies from $10 to $35 per ton for FGD generators without captive landfills. More than 95% of FGD material generated in the state is produced by CCP generators with captive landfills and hence the average statewide FGD landfilling cost ranges between $3 and $10 per ton with a mean cost of about $6.50 per ton. A statewide mean landfilling cost of $6.50 per ton corresponds to utilization of 0.65 MST of FGD or 16% utilization (refer to Figure 9-1). This projected utilization rate is almost double the 1997 utilization rate of 8.4% for FGD material. Results of the linear optimization model showed that there is significant economic incentive for utilities to promote the use of FGD for highway construction and maintenance, and surface mine reclamation. The current statewide FGD utilization rate of 8.4% can be doubled to 16% in the short term if utilities continue to subsidize the transportation costs up to the breakeven point and the end user pays for the processing costs. However for the long term, an FGD utilization rate much greater than 16% is needed. This will necessitate that the processing and transportation costs be borne by the end- user in the long run for successful and productive utilization of FGD materials across the state of Ohio.

The future projections for the quantity and quality of CCPs generated in Ohio will depend on several factors including shifts in coal-based energy production in the state, competitiveness of high-sulfur Ohio coal, and future emission control restrictions. If all the current Ohio plants were to use high-sulfur coal and install FGD scrubbers, the production of FGD material in the state would range between 12 to 16 million tons per year. At the present time, three additional FGD scrubbers are being installed or planned in Ohio. These will be located at City of Hamilton (COH), Ohio University (OUP), and the Medical College of Ohio (MCO). All of these proposed facilities use small amounts of coal and will be using dry scrubbing technology. New coal-fired power plants are not expected to be installed in the state in the next 10-15 years. However, existing coal-fired plants will continue to provide the base load electricity to the state, while peaking electric loads are expected to be generated from natural gas or renewable sources. Compliance with Phase II of the Clean Air Act Amendments by the year 2000 by Ohio coal-fired power plants is expected to result from a combination of a) fuel switching / and or blending with lower sulfur coals, b) obtaining additional SO2 allowances, c) installing FGD equipment, d) using previously implemented emission controls, e) retiring units, f) boiler re-powering, g) substituting Phase II units for Phase I units, and h) compensating Phase I units with Phase II units. A review of the current online Phase II compliance methods for Ohio projected by the USEPA shows that fuel switching / and or blending with lower sulfur coals will be the preferred option of choice in the state. Fuel switching and blending from high-sulfur to lower sulfur coals will result in higher amounts of fly ash production. The quality of CCPs generated are expected to be impacted severely by the proposed NOx rules due to an increase in the carbon and ammonia contents in the ash. The public response to the release of Toxic Release Inventory (TRI) information by utilities may have some negative impact on the marketing of CCPs. Identification of barriers to CCP use in the state, finding innovative solutions to reduce and overcome these barriers (refer to Section 10.4), as well as their positive implementation will result in an increase in the utilization of CCPs throughout Ohio.

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11.3 Conclusions

Ten recommendations have been made for the removal / reduction of these barriers. These barriers can be removed with the synergy and focused attention of government agencies, the utility industry, trade organizations, university research and technology transfer, and market development programs. The successful reduction and removal of these barriers along with a strong technology transfer and market development program will be critical to the future potential high-volume uses of CCPs, particularly FGD and fly ash in the state of Ohio. Success will allow Ohio coal to remain competitive with other coal sources, and keep the cost of energy production in the state low while protecting human health and the environment. The long-term successful utilization of CCPs will be possible for application technologies that are technically safe, environmentally sound, socially beneficial, and commercially competitive.

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12 REFERENCES

American Concrete Institute, 1994, Controlled Low Strength Materials (CLSM), American Concrete Institute Committee 229, Report No. 229R-94, American Concrete Institute, Detroit, Michigan, July, 1994. American Concrete Institute, 1996, Guide for Selecting Properties of High-Strength Concrete With Portland Cement and Fly Ash, American Concrete Institute Manual of Concrete Practice, Part 1, ACI 211.4R-93, American Concrete Institute, Detroit, Michigan, 1996. American Coal Ash Association, 1991, Flexible Pavement Manual, Alexandria, Virginia, 1991. American Coal Ash Association, 1995, Fly Ash Facts for Highway Engineers, FHWA-SA-94- 081, Federal Highway Administration, Washington, D.C., August 1995. American Coal Ash Association, 1997, Comparison of Coal Combustion Products (CCPs) Used as Structural Fill Material vs. Disposal in a Landfill Using the Life Cycle Assessment Framework, Alexandria, Virginia, September, 1997. American Coal Ash Association, 1998, State Solid Waste Regulations Governing the Use of Coal Combustion Products (CCPs), Alexandria, Virginia, August, 1998. American Electric Power, undated, Flash Fill, Flash Fill by American Electric Power, and Physical Properties of Flash Fill (Publicity literature), American Electric Power Service Corporation, Columbus, Ohio. American Metal Market, 1998, Carbon Plus a Joint Venture Formed by Three Energy Concern to Make Market High-Grade Carbon and Low-Carson Fly Ash Products, American Metal Market, 106(183):3, September 23, 1998. American Society for Testing and Materials, 1992, Standard Test Method for Shake Extraction of Solid Waste with H2O, ASTM Designation D3987-85. American Society of Testing and Materials, 1997a, Standard Guide for Use of Coal Combustion By-Products in Structural Fills, ASTM Designation E1861-97. American Society of Testing and Materials, 1997b, Test method for One-Dimensional Expansion, Shrinkage, and Uplift Pressure of Soil-Lime Mixtures, ASTM Designation D3877. Applied Sciences, Inc., 2000, Proposed Project Proposal Submitted to Ohio Coal Development Office, January, 2000. Bigham J.M., Soto, U.I., Stehouwer, R.C, Yibrin, H., 1999, Use of FGD By-Product Gypsum Enriched with Mg(OH)2 as a Soil Amendment, Report prepared by OARDC Wooster for the Ohio Coal Development Office, Dravo Lime Company, and Cinergy, April, 1999. Brendel, G.F., Kyper, T.N., 1992, Institutional Constraints to Coal Fly Ash Use in Construction, Final Report, EPRI TR-101686, Project 3176-04, Electric Power Research Institute, Palo Alto, California, December 1992. Butalia, T., Wolfe, W., Dick, W., Limes, D., Stowell, R., 1999a, Coal Combustion Products, The Ohio State Extension Fact Sheet, AEX-330-99, The Ohio State University, Columbus, Ohio. Butalia, T., Dyer, P., Stowell, R., Wolfe, W., 1999b, Construction of Livestock Feeding and Hay Bale Storage Pads Using FGD Material, The Ohio State Extension Fact Sheet, AEX-332- 99, The Ohio State University, Columbus, Ohio.

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Cincinnati Enquirer, 1999, Zimmer to Provide Raw Material, The Cincinnati Enquirer, January 28, 1999. Cleveland Plain Dealer, 1998, FirstEnergy Corp, Crown Coal & Coke and Canyon Resources Form Carbon Plus LLC to Make and Market Carbon and Low-Carbon Fly Ash Products Used in Steel, Foundry, and Cement Industries, Cleveland Plain Dealer, September 18, 1998, Cleveland, Ohio. Code of Federal Regulations, 1991, USEPA Method 1311, Vol. 40, Part 261, Appendix II, July 1991. Columbus Dispatch, April 23, 1999, AEP Will Attack Pollution, Associated Press, The Columbus Dispatch, Columbus, Ohio. Columbus Dispatch, May 27, 1999, State’s Coal Burner’s Catch a Break With Court’s Decision, The Columbus Dispatch, Columbus, Ohio. Columbus Dispatch, July 11, 1999, Drywall Shortage Leaves Some Builders Cornered, The Columbus Dispatch, Columbus, Ohio. CONSOL Energy News, 1999, CONSOL Energy Produces Aggregates from Coal Combustion By-Products: Product From Pilot Plant Performs Well in Tests, Press release issued on September 2, 1999. County Engineers Association of Ohio, 1997, Ohio’s County Highways 2003, County Engineers Association of Ohio, Columbus, Ohio. Crowell, D.L., 1995, History of the Coal-Mining Industry in Ohio, Division of Geological Survey, Ohio Department of Natural Resources. Crowell, D.L., 1997, Mine Subsidence, GeoFacts No. 12, Ohio Department of Natural Resources: Division of Geological Survey, February, 1997. Deller, S.C., and Walzer, N., 1997, Rural Roads and Bridges: A Comprehensive Analysis, United States Department of Agriculture, Agricultural Marketing Service, Transportation and Marketing Division, September, 1997. Dick, W., J. Bigham, L. Forster, F. Hitzhusen, R. Lal, R. Stehouwer, S. Traina and W. Wolfe, R. Haefner, G. Rowe, 1999a, Land Application Uses of Dry FGD By-Product: Phase 3 Report, Electric Power Research Institute, EPRI TR-112916, 1999. Dick, W., J. Bigham, L. Forster, F. Hitzhusen, R. Lal, R. Stehouwer, S. Traina, W. Wolfe, R. Haefner, and G. Rowe, 1999b, Land Application Uses of Dry Flue Gas Desulfurization By-Products: Executive Summary, The Ohio State University, 1999. Electric Power Research Institute, 1998, Coal Ash: Its Origin, Disposal, Use, and Potential Health Issues, Environmental Focus, 1998. Electric Power Research Institute, 1999, Flue Gas Desulfurization By-Products: Composition, Storage, Use, and Health and Environmental Information, Environmental Focus, 1999. Energy Information Administration, 1996, State Electricity Profiles, Energy Information Administration, DOE/EIA-0582(97), May, 1996. Energy Information Administration, 1997a, Coal Industry Annual 1997, Energy Information Administration, DOE/EIA-0584(97). Energy Information Administration, 1997b, The Effects of Title IV of the Clean Air Act Amendments of 1990 on Electric Utilities: An Update, Energy Information Administration, DOE/EIA-0582(97), March, 1997. Energy Information Administration, 1998a, Electric Power Annual 1997, Volume II, Energy Information Administration, DOE/EIA-0348(97)/2, October 1998.

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Energy Information Administration, 1998b, Challenges of Electric Power Industry Restructuring for Fuel Suppliers, Energy Information Administration, DOE/EIA-0623, September, 1998. Energy Information Administration, 1998c, Cost and Quality of Fuels for Electric Utility Plants – 1997 Tables, Energy Information Administration, DOE/EIA-XXXX(XX), UC-950, May, 1998. Federal Highway Administration, 1997, User Guidelines for Waste and Byproduct Materials in Pavement Construction, Turner-Fairbank Highway Research Center, FHWA-RD-97-148. (http://www.tfhrc.gov/, follow Materials Technology link to Secondary Materials Recycling Center to Publications) Federal Highway Administration, 1998, Pavement Recycling Guidelines for State and Local Governments, Turner-Fairbank Highway Research Center, FHWA-SA-98-042. (http://www.tfhrc.gov/, follow Materials Technology link to Secondary Materials Recycling Center to Publications) GAI Consultants, 1993, Use of Coal Combustion By-Products in Highway Construction, Report prepared for General Assembly of Indiana and The Indiana Department of Transportation, Project 91-401-10, October, 1993. Gallia County NRCS, 1997, Heavy Use Livestock Pads Constructed of Stabilized FGD By- Product, Report prepared by Gallia County NRCS and Radian Corporation, Federal Energy Technology Center, Pittsburgh, Pennsylvania. Global New Energy Corporation, 1999, A Brief Description of “One Furnace, Two Functions”: A Patented Pollution Control Technology for Coal-Fired Power Plants and Cement Manufacturers. (http://www.gnegroup.com) Hao, Y.L., Dick, W.A., and Stehouwer, R.C., 1998, Inhibition of Acid Production in Coal Refuse Amended with Calcium Sulfite and Calcium Sulfite-Containing FGD, Report submitted to Ohio Coal Development Office, Dravo Lime Company, and CINERGY, June, 1998. Hassett, D.J., 1991, Evaluation of Leaching Potential of Solid Coal Combustion Wastes, Final Report prepared for Indian Coal Council, Inc., December 1991. Hassett, D.J., and Pflughoeft-Hassett, D.F., 1993, Environmental Assessment of Coal Conversion Solid Residues, Proceedings of the Tenth International Ash Use Symposium – Volume 1, Orlando, Florida, January, 18-21, 1993, EPRI TR-101774, pp. 31-1 to 31- 12, Electric Power Research Institute, Palo Alto, California. Hudson, J.F., Stolder, M., Demeter, C., Farrell, S.O., 1982, Institutional Barriers to Increased Utilization of Power Plant Ash in Maryland: Analysis and Recommendations, Report # PPSP-MP-35, January 1982. Hunt, R.G., Seitter, L.E., Collins, J.C., Miller, R.H., and Brindley, B.S., 1981, Final Report: Data Collection and Analyses Pertinent to EPA’s Development of Guidelines for Procurement of Highway Construction Products Containing Recovered Materials, Volume I: Issues and Technical Summary, EPA Contract 68-01-6014, July 6, 1981. Industrial Specialties News, 1999, Lafarge Corp Plans to Build a US $90 Mil, 900 Mil Square Feet/Year Greenfield Gypsum Wallboard Plant in Silver Grove, KY, Industrial Specialties News, 13(3), February 8, 1999. Irgolic, K.J., Haas, G., Schlagenhaufen, C., and Geossler, W., Identification of Arsenic Species in Coal Ash Particles, TR-109002, Electric Power Research Institute, Palo Alto, California, June, 1998. ISO/DIS, 1996, Environmental Management, Life Cycle Assessment, Principles and Framework.

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Kalyoncu, R., Coal Combustion Products, 1997, United States Geological Survey – Minerals Information – 1997. Lee, J.W., 1998, Beneficial Use of FGD By-Products as Flowable Fill, M.S. Thesis, The Ohio State University, Columbus, Ohio. Lee, J.W., Butalia, T.S., and Wolfe, W.E., 1999 Potential Use of FGD as a Flowable Fill, 1999 International Ash Utilization Symposium, Lexington, Kentucky, October 18-20, 1999. Miller, M.M., Kramer, D.A., Vagt, G.O., 1993, Flue Gas Desulfurization and Industrial Minerals: A Bibliography, U.S. Department of the Interior, Bureau of Mines, Special Publication, October, 1993. Nelson Jr., S., Dick. W., and Chen, L., Agricultural Field Tests of Fluesorbent FGD By- Products, EPRI-DOE-EPA Combined Utility Air Pollutant Control Symposium, Atlanta, Georgia, August 17, 1999. Nodjomian, S.M., 1994, Clean Coal Technology By-Products Used in a Highway Embankment Stabilization Demonstration Project, M.S. Thesis, The Ohio State University, Columbus, Ohio. Ohio Department of Agriculture, 1998, 1997 Ohio Agricultural Statistics and Ohio Department of Agriculture Annual Report, Ohio Department of Agriculture, Reynoldsburg, Ohio. Ohio Department of Transportation, 1997, Construction and Material Specifications, January, 1997 Ohio Department of Transportation, 1998, Manual for Abandoned Underground Mine Inventory and Risk Assessment, Ohio Department of Transportation, May 15, 1998. Ohio Energy Strategy Interagency Task Force, 1994, The Ohio Energy Strategy Report, State of Ohio, Columbus, Ohio. Ohio Environmental Protection Agency, 1994, Beneficial Use of Nontoxic Bottom Ash, Fly Ash, and Spent Foundry Sand, and Other Exempt Waste, Division of Surface Water policy DWS 0400.007, November 7, 1994. Ohio Environmental Protection Agency, 1997a, Management Directive: Division of Labor Regarding Traditional Waste Management Practices and Alternative Waste Disposal Practices, Memorandum from Chiefs of Division of Surface Water and Division of Solid and Infectious Waste Management, June 26, 1997. Ohio Environmental Protection Agency, 1997b, 1997 Solid Waste Facility Report (1996 data), Ohio Environmental Protection Agency, Division of Solid and Infectious Waste Management, Columbus, Ohio. Organization for Economic Co-Operation and Development, 1997, Recycling Strategies for Road Works, Organization for Economic Co-Operation and Development, Paris, France. Patelunas, G.M., 1988, High Volume Fly Ash Utilization Projects in the United States and Canada, Electric Power Research Institute, Report CS-4446, Palo Alto, California, May, 1988. Pflughoeft-Hassett, D.F., Sondreal, E.A., Steadman, E.N., Eylands, K.E., Dockter, B.A., 1999, Barriers to the Increased Utilization of Coal Combustion / Desulfurization By-Products by Government and Commercial Sectors – Update 1998, Energy & Environment Research Center Topical Report, University of North Dakota, Grand Forks, North Dakota, July 1999. Power Journal, 1999, WH Zimmer Generating Station to Invest $20 Mil to Make High Quality Synthetic Gypsum to be Sold to Lafarge Gypsum Div for a $90 Mil Wallboard Plant, Power Engineering, 103(5): 12, May, 1999.

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PRNewswire, 1999, Delphi Turns Ashes to Flowers, April 23, 1999. Public Utilities Commission of Ohio, 1996, Ohio Long Term Forecast of Energy Requirements 1995-2015, Editor in Chief: Galip Feyzioglu, Public Utilities Commission of Ohio, Utilities Department, Division of Forecasting, Columbus, Ohio, July 1996. Sherwood, P.T., 1995, Alternative Materials in Road Construction, Thomas Telford Publications, London, UK. Smith, K., Babu, M., and Inkenhaus, W., 1998, Recent Advances in Use of Magnesium- Enhanced FGD Processes Include a Natural Oxidation Lime Scrubber Conversion and the First Commercial ThioClear Application, Proceedings of the 23rd International Technical Conference on Coal Utilization and Fuel Systems, Clearwater, Florida, March 9-13, 1998, Coal and Slurry Technology Association, Washington, D.C. Society for Environmental Toxicology and Chemistry, 1993, Guidelines for Life-Cycle Assessment: A Code of Practice. Sondreal, E.A., Steadman, E.N., Dockter, B.A., Pflughoeft-Hassett, D.F., Eylands, K.E., 1993, Barriers to the Increased Utilization of Coal Combustion / Desulfurization By-Products by Government and Commercial Sectors, Final Draft Technical Report Submitted to U.S. Department of Energy, University of North Dakota, Grand Forks, North Dakota, October 7, 1993. Stehouwer, R., Dick, W., Bigham, J., Forster, L., Hitzhusen, F., McCoy, E., Traina, S. and Wolfe, W.E., Haefner, R., 1995, Land Application Uses for Dry FGD By-Products: Phase 1 Report, Electric Power Research Institute, EPRI TR-105264. Stehouwer, R., Dick, W., Bigham, J., Forster, L., Hitzhusen, F., McCoy, E., Traina, S., and Wolfe, W.E., Haefner, R., Rowe, G., 1998, Land Application Uses for Dry FGD By- Products: Phase 2 Report, Electric Power Research Institute, EPRI TR-109652. Stewart, B.R, and Kalyoncu, R.S., 1999, Materials Flow in the Production and Use of Coal Combustion Products, 1999 International Ash Utilization Symposium, Lexington, Kentucky, October 18-20, 1999. Transportation Research Board, 1994a, Synthesis of Highway Practice 199: Recycling and Use of Waste Materials and By-Products in Highway Construction, National Academy Press, Washington, D.C. Transportation Research Board, 1994b, Technical Appendix to NCHRP Synthesis of Highway Practice 199: Recycling and Use of Waste Materials and By-Products in Highway Construction, National Academy Press, Washington, D.C. Turner, R.P., 1976, Status Report on Aggregate-Lime-Fly Ash Base, Ohio Department of Transportation, Columbus, Ohio, August 1976. United States Department of Agriculture, 1985, Assessment and Treatment of Areas Impacted in Ohio by Abandoned Mines, Technical Report published by Soil Conservation Service in cooperation with Economic Research Service, Forest Service, and Ohio Department of Natural Resources – Division of Reclamation. United States Department of Energy, 1994, Barriers to the Increased Utilization of Coal Combustion / Desulfurization Byproducts by Governmental and Commercial Sectors, Report to U.S. Congress, Department of Energy Office of Fossil Energy, July 1994. United Stated Department of Energy Project Facts, 1999, Production of Construction Aggregate From Flue Gas Desulfurization Sludge, January, 1999 United Stated Environmental Protection Agency, 1988, Wastes from the Combustion of Coal by Electric Utility Power Plants, Report to Congress, EPA 530-SW-88-002, February 1988.

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United Stated Environmental Protection Agency, 1993, Large-Volume Wastes From Coal-Fired Electric Utilities Exempted as Hazardous Wastes, Environmental Fact Sheet, EPA 530-F- 93-014, August 1993. United Stated Environmental Protection Agency, 1999, Wastes From the Combustion of Fossil Fuels, Volume 1 and 2, Report to Congress, EPA 530-R-99-010, March 31, 1999. Weisgarber, S.L., 1997, 1996 Report on Ohio Mineral Industries, Ohio Department of Natural Resources – Division of Geological Survey, Columbus, Ohio. Wolfe, M., 1998, 1997 Report on Ohio Mineral Industries, Ohio Department of Natural Resources – Division of Geological Survey, Columbus, Ohio.

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13 APPENDICES

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APPENDIX A

USEPA ENVIRONMENTAL FACT SHEET (EPA 530-F-93-014)

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APPENDIX B

BENEFICIAL USE OF NONTOXIC BOTTOM ASH, FLY ASH, AND

SPENT FOUNDRY SAND, AND OTHER EXEMPT WASTE (DSW 0400.007)

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APPENDIX C

HISTORICAL REVIEW OF CCP RESEARCH IN OHIO

C-1 Introduction

With approximately 90% of Ohio’s electricity being generated from the burning of coal, the state generates approximately 10 million tons of coal combustion products (CCPs) annually. In the past, most of these CCPs (particularly FGD) have been put in landfills or surface impoundments, resulting in largely non-productive disposal of these materials. The utilization of CCPs as raw materials for civil engineering, mineland reclamation, agricultural applications, and manufacturing uses make possible (1) a decrease in the need for landfill space, (2) conserve the natural resources of the state, (3) better and more durable products, (4) allow continued use of

Ohio’s high-sulfur coal, (5) significant economic savings for end users, and (6) reduces overall cost of generating electricity. Several CCP projects completed or under progress in the state of

Ohio are shown in Figure C-1.

This chapter reviews the progress made in the last few years in CCP (particularly FGD) research by discussing a number of demonstration projects conducted in Ohio to promote the utilization of CCPs. A comprehensive overview of the utilization technologies successfully developed and implemented in the state as well as those under deve lopment is presented. A CCP pilot extension program, the first of its kind in any state of the US, which was established at The Ohio State University, is discussed.

C-2 Research on Utilization of CCPs

Over the last nine years, Ohio has become a leader in the development of new technologies for uses of CCPs. This is the result of tremendous cooperation and support by a large number of organizations including: the Ohio Coal Development Office within the Ohio Department of Development, The Ohio State University, US Department of Energy’s Federal Energy Technology Center, American Electric Power, Ohio Edison, Dravo Lime Company, Electric Power Research Institute, US Geological Survey, Ohio Department of Natural Resources, Ohio Environmental Protection Agency, American Coal Ash Association and others.

Several researchers at The Ohio State University participated in a long-term study aimed at characterizing the physical, chemical, mineralogical and engineering properties of dry and wet FGD material and its land application (Stehouwer et al., 1995a, 1998, Wolfe et al., 1992, Adams et al., 1992, Beeghly et al., 1993, 1994, 1995b, Wolfe and Cline, 1995, Dick, et al., 1997, 1999a, 1999b). An extensive review of the state of the art for the characterization and utilization of FGD materials was performed (Stehouwer et al., 1995a, 1998, Dick et al., 1999a, 199b). Samples were collected from 13 different coal-fired boilers and representative samples of FGD technologies being tested in Ohio were selected for detailed analysis. The technologies included Lime Injection Multistage Burners (LIMB), Pressurized Fluidized Bed Combustion (PFBC), Spray Dryer and Duct Injection. The engineering properties of compacted FGD that were studied

151 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

ASHTABULA

LAKE WILLIAMS FULTON LUCAS OTTAWA WOOD GEAUGA TRUMBULL HENRY CUYAHOGA DEFIANCE SANDUSKY ERIE LORAIN PORTAGE HURON SUMMIT 5 SENECA PAULDING MEDINA PUTNAM HANCOCK 18 MAHONING

VAN WERT WAYNE WYANDOT STARK COLUMBIANA ALLEN HARDIN 1,14,15 MERCER MARION CARROLL AUGLAIZE HOLMES 8 LOGAN KNOX SHELBY UNION MORROW COSHOCTON 1 HARRISON DARKE DELAWARE 1,2,10,11,12 6 CHAMPAIGN LICKING MIAMI GUERNSEY BELMONT 1 MUSKINGUM FRANKLIN 1 1 CLARK 1 16 1,4,17,19 PERRY PREBLE FAIRFIELD 1 MONROE 3 GREENE MADISON PICKAWAY 1 MORGAN 7 9 NOBLE FAYETTE HOCKING WASHINGTON WARREN BUTLER CLINTON ROSS ATHENS VINTON

HAMILTON HIGHLAND 13 PIKE MEIGS JACKSON 1

GALLIA BROWN ADAMS SCIOTO 1 0 10 20 30 40 miles 0 10 20 30 40 50 kilometers LAWRENCE

1. Livestock Feeding and Hay Storage Pads* (More than 175 constructed in 12 counties) 2. 3. SR83 Highway Embankment Repairs* 4. OSU Truck Ramp* CONSOL Synthetic Road Aggregate Demonstration Project* 6. 7. Caldwell Reclamation Demonstration Project* 8. 9. Rehoboth Tests Plots* & Rehoboth Phase I Reclamation Project Broken Aro Seal Project Roberts Dawson Underground Injection Project* Conesville Prep Plant Refuse Cover Project 13. Wastewater Treatment Using Reclaimed Mg(OH)2* 14. Wooster Agricultural Liming Studies* 15. Sorbent FGD Liming Studies* 16. FGD Lined Demonstration Pond Facility* 17. Small-Scale FGD Lined Wetlands* 18. Autoclaved Cellular Concrete Demonstration Project* 19. CCP Pilot Extension Program*

* : Co-funded by the Ohio Coal Development Office

(Source: Ohio Coal Development Office)

Figure C-1: Ohio CCP Projects

152 – May 2000

permeability, and swelling potential. These engineering properties the design and construction of high volume engineered fills, highway embankments and other

including, agricultural liming substitu reclamation, treatment of acidic overburden at active mine sites and toxic mine spoils,

benefits of CCP utilization w

The swelling potential of FGD was studied by Adams (1992) and Adams and Wolfe (1993) by - plants representative of FG episode occurred almost immediately after water was supplied to the specimens. This

greatest v observed to begin after 10 or more days had elapsed. A study of the occurrence of swell along et al.

- et al. material. Higher water content samples exhibited greater reducti to freeze thaw cycling. It was observed that high strengths could be maintained under freeze thaw cycling if at least 5% lime (dry weight basis) was added to the FGD before compaction and ays before being exposed to freeze thaw. These general

For the use of FGD in highway construction applications, the effect of freeze thaw cycling on the PFBC material can be quite significant. Roy (1994) and Wolfe (1997) - subgrade material in the construction of low traffic volume roads. Favorable compar FGD moduli with published values for materials commonly used in road base construction were

The suitability of dry and wet FGD material as low permeability liners in place of commonly et (1992a) and Butalia and Wolfe

to achieve permeability coefficients lower than the value typically required by EPA for lining 10 7 with high fly ash to filter cake ratio (2:1) and high lime percentage (8%).

C 3 Ohio Demonstration Projects

ns that are

characterizing the behavior of FGD materials would be to conduct field demonstration projects

Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

to study the suitability of the material and its performance, before a particular utilization technology can be made commercial for the end user. The Ohio Coal Development Office within the Ohio Department of Development has sponsored many of the field demonstration projects that have been carried out in Ohio. A brief description of these project follows.

C-3.1 Truck Ramp

The purpose of constructing a truck ramp was to evaluate the field handling and compaction characteristics of the spray dyer ash generated at Ohio State University’s McCracken Power plan. The truck ramp (17 meter long by 7.5 meters wide and 1.2 meters high) was designed by Ohio State University’s Department of Physical Facilities to provide a location for unloading hard trash (Wolfe and Beeghly, 1993). The ramp was constructed by university maintenance personnel during work schedule breaks in the summer of 1992. Spray dryer ash from the university’s McCracken power plant was used as the primary construction material. The ash was placed within 5% of the optimum moisture content and greater than 90% standard Proctor densities were achieved. The ash did not require any special handling and was constructed using university owned equipment. Tests performed on samples cored from the ramp showed that after a year of service, the water content was considerably higher than the optimum moisture content. Unconfined compressive strength tests conducted on samples cored from the ramp exhibited lower strengths than those achieved in the laboratory. Despite the difficulty in achieving uniform conditions during construction, the ramp performed well with no evidence of failures during subsequent use by university vehicles.

C-3.2 Livestock Feeding and Hay Storage Pads

In high rainfall areas such as Ohio, it is desirable to pave livestock feedlot and feeding areas with a durable material like concrete or rock aggregates. Otherwise animals expend considerable amount of energy just to move through slushy organic soil. An inexpensive and reliable technique for stabilizing the feeding areas was identified to be the use of compacted FGD. The site chosen for the first FGD cattle feedlot demonstration project was the Eastern Ohio Resource Development Center in Belle Valley, Ohio. Dry cyclone ash from AEP’s PFBC Tidd plant was used to stabilize the saturated organic in-place soil. The ash was blended into the top 1 ½ feet of the soil and the mixture was compacted to produce a stabilized base. A 1 ½- 2 ½ feet thick layer of compacted ash was then put on top of the stabilized base. All the construction activities were performed by farm personnel using standard farm equipment. Some minor failures were observed when the first round of cattle was brought onto the feedlot. However since the repair of these minor failures, the feedlots have performed well. Additional livestock feeding and hay storage pads were constructed at the EORDC farm in September of 1993 using wet FGD from AEP’s Conesville plant. These feedlots have performed very well with an approximately ¼ to ½ inch annual wear. Ohio EPA was satisfied with the performance of the FGD feeding and hay storage pads and American Electric Power currently has a state wide blanket permit to install (PTI) FGD livestock feedlot and hay storage pads using lime enriched FGD material from its Conesville (CON) and Gavin (GAV) power plants. As long as the conditions in the PTI are met and the thickness of FGD layer is less than 15 inches, no additional approval from Ohio EPA is

154 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

necessary. The construction of FGD feedlots does not require any special equipment. The cost of an FGD feedlot can be up to 25 percent less than the estimated cost using aggregate and approximately 65 percent less than the estimated cost of concrete. AEP’s plants have generally provided the material free of cost at the plant with farmers paying for hauling costs. In some cases, the plant has been willing to truck the material to the site if it is in vicinity of the plant. In the summer of 1997, a total of 24 livestock feedlots and hay storage pads ranging in size from 1,500 ft2 to 14,000 ft2 were constructed in southern and eastern Ohio. Because of the success of these pads, livestock feedlots and hay storage pads constructed with FGD material are in high demand in some parts of Ohio. In 1998, more than 45,000 tons of FGD material was used to construct over 50 FGD pads in 12 Ohio counties.

C -3.3 Highway Embankment Repairs

A section of Ohio State Route 541 located west of Coshocton that was failing due to a rotational slide was stabilized in the winter of 1993 using PFBC ash generated by AEP’s Tidd plant. The portion of the road affected by the slide was constructed in 1966 over a large fill. The first phase of the project involved the excavation of approximately 310,000 ft3 of soil from above the slip plane. Half of the excavated soil was stockpiled for later use at the site while the rest was transported off site. Several under drains had to be constructed to direct water away from the load bearing portions of the embankment. The second phase involved the placement and compaction of FGD material. Self-loading scrapers delivered the material stocked onsite, as bulldozers spread it evenly over an area 40 feet wide and 100 feet long. The first lift was approximately 2 feet thick and was placed and compacted in one day. Within 12 hours of placement the FGD had gained enough strength for the scrapers to drive over it without leaving any tire tracks. The FGD buttress was constructed up to a height of 13 to 16 feet. The thickness of layers and the amount of water added to the FGD were not strictly monitored. It was observed that the material had a wide workable range and did not have to be mixed with laboratory precision to yield excellent strengths. The original embankment material was then placed on top of the FGD buttress in controlled lifts and the final road surface was constructed. During the first and second phase of the embankment repairs, regular monitoring of the water quality upstream and downstream of the project was done. The variations in pH and total dissolved solids were within the acceptable range of fluctuations associated with the stream. However, water samples taken from underdrains showed a significant rise in sulfates and total alkaline measured as CaCO3. The volume of stream flow was so much greater than the volume of water being expelled through the underdrains that the total system appeared unaffected by the increase in measured sulfates and CaCO3 in the leachate. Long-term water quality monitoring of the site is being continued through the third phase of the project. A system of inclinometers, piezometers and deformation measuring gauges were installed at the site and are regularly monitored by ODOT personnel. A more detailed description of the project was presented by Nodjomian (1994), Nodjomian and Wolfe (1994) and Kim et al. (1995).

A second highway embankment repair project involved the stabilization of a portion of Ohio State Route 83 south of Cumberland. A section of the road that had been damaged due to repeated rotational slides was reconstructed using Tidd PFBC ash in 1994. The first phase of the project involved excavation of approximately 380,000 ft3 of embankment soil. Fabric drain

155 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

boards were installed in a trench dug along the hillside to prevent groundwater from reaching the embankment. The trench was backfilled with compacted FGD in approximately 1 foot thick lifts using a small bulldozer for spreading and a sheepsfoot roller for compaction. The second phase of the project was begun by dividing the embankment into four separate sections. Control sections were established at the north and south end of the site. The control sections were repaired according to standard ODOT procedures by drying, replacing and compacting the stockpiled soil. One test section consisted of a mix of Tidd ash and onsite soil while the third section was constructed using only the ash. The ash-soil section was compacted in lifts of about 8 inches thick while the ash only section could be compacted with much thicker lifts ranging from 1 to 2 feet. Strict control was kept on the moisture content and compacted density and approximately 95% compaction using the standard Proctor was achieved for the four sections. The embankment construction was completed in December of 1994. However, because asphalt plants had closed down for the season, one half of the road was constructed with a 1.5 feet thick compacted FGD wearing course while the other half was made with a 1.5 feet thick layer of stone aggregate. The road was opened to traffic in late December. The ash has performed well over the last four years and has not needed any repairs. Water around the embankment has shown no indication of metals leaching into the surrounding environment. More details on the Ohio SR83 project can be found in Payette et al. (1997) and Civil Engineering News (1997).

The results from these two studies indicated that laboratory precision was not required to achieve excellent strength properties that were more than sufficient for road repair. In order to facilitate the use of FGD in highway embankment repairs, a knowledge-based expert system was developed by Kim et al. (1992b, 1993, 1994).

High volume uses of CCPs such as those for highway embankment applications generally require temporary stockpiling of the material onsite. A 1,500 ton pile of dry LIMB FGD material was constructed in 1992 at a moisture content approaching the optimum water content of 40-50% (Beeghly et al., 1995a). The changes in the properties of the pile were studied for 30 months. Hydration reactions formed gypsum and ettrengite creating a crust that stabilized the surface of the pile. This prevented dusting during dry periods and also reduced erosion from the slopes of the pile. However, the runoff from the slopes was minimal. By allowing for the formation of some ettrengite to proceed, the expansion of an embankment after placement and compaction of FGD could be minimized. But this would result in a decrease in the cementious capacity of FGD. However, the addition of a small amount of lime just prior to placement should help overcome the loss of cementious reaction that occurred during storage.

C-3.4 Surface Reclamation of Abandoned Mined Lands

Laboratory investigations into the use of various types of FGD materials for mine reclamation applications were carried out by Sutton and Stehouwer, 1992, Stehouwer et al., 1993 and Soto et al., 1993. Greenhouse column studies were carried out by Stehouwer et al. (1995b) to study the element solubility and mobility characteristics of amended minespoils while Stehouwer et al. (1995c) studied the plant growth in minespoils amended with dry FGD. Issues relating to the extension of laboratory tests to field demonstration of minespoil amendments were presented by Dick et al., 1994a.

156 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

Several field demonstration projects have been conducted in Ohio that have studied the use of FGD materials for reclamation of highly degraded abandoned mines. An abandoned clay and coal mine near Dover commonly referred to as the Fleming demonstration site was regraded in summer of 1994 and three types of amendment treatment were applied in fall of 1994. The treatment schemes included separate equivalent applications of limestone, FGD material (PFBC) and a 2.5:1 mixture of FGD and yard waste compost. The treatments were incorporated to a depth of approximately 8 inches. Surface water and drainage water samples were collected. Arsenic was found to be the only trace element that approached a level that would preclude the use of FGD for mine reclamation. The concentrations of all other elements were below the regulation concentrations or loading limit. It was observed that often these metal concentrations were lower than those in the existing overburden spoil that required reclamation. All three treatments improved water quality. The concentration of Boron in the leachate was particularly high from the FGD plots but was below the phytotoxic levels. Surface water quality has remained almost unchanged from 1995. All treatments resulted in water pH of approximately 7. The drainage water samples collected in spring of 1995 showed the FGD plots were neutral while others were acidic (pH of 4-5.5). In July of 1996, the pH values of the treatments whose pH had declined earlier, rose to the neutral level. All the treatments provided complete ground cover. However, all treatments showed a decline in the vegetative growth in 1996 as compared with 1995 with the decline being the greatest for lime treated plots. Long-term effectiveness of the FGD treatments is being studied at the site to learn more about the ecological sustainability of these materials.

Additional mine reclamation field-testing was carried out at Unit II of the Eastern Ohio Resource Development Center near Caldwell, in Southeastern Ohio. The aim of the project was to evaluate the reclamation performance of two wet FGD materials and compare them with borrow soil and sewage sludge minespoil amendments. The two types of FGD materials used in this demonstration project were generated by the wet lime scrubbers of AEP’s Conesville plant and an experimental scrubber at Cinergy’s Zimmer plant. The original field plot sites had low levels of extractable nutrients. The site was regraded in summer of 1995 and treated with six different types of mine soil amendments. These treatments included: 1) sewage sludge, 2) gypsiferous Zimmer FGD, 3) Conesville FGD, 4) Zimmer FGD mixed with sewage sludge, 5) Conesville FGD mixed with sewage sludge, and 6) red silty clay borrow soil. Details on the applications rates were presented by Kost et al. (1997). All the amendments were rototilled to a depth of about 30-cm. These treatments were applied in the fall of 1995. A flume was installed at the bottom of each plot to collect surface water runoff. Appropriate fertilization of the plots was carried out and they were seeded in fall of 1995 with winter wheat cover crop, and a mix of birdsfoot trefoil, red clover, perennial ryegrass and timothy. Ten seedlings each of white ash, black locust, sycamore and sweetgum were planted in spring of 1996 in each plot. Tree survival, tree height, biomass cover, soil and water quality were monitored. Preliminary results (Kost et al., 1997) of samples collected at the site indicate that all amendments except the sewage sludge alone are effective in decreasing soil acidity within the zone of incorporation. Vigorous herbaceous cover has existed on all the treatments for two years. During this time, herbaceous biomass was reported to be the greatest for plots that were treated with a mixture of Conesville FGD and sewage sludge (Kost, 1997). Additional observations and conclusions for these demonstration projects can be found in Dick et al., 1994b and Stehouwer and Dick, 1997.

157 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

C -3.5 Agricultural Liming Substitute

FGD holds promise as a substitute for conventional agricultural lime to adjust the pH of soils (Dick et al., 1993, Sutton et. al, 1994, Stehouwer et al., 1995d). The neutralizing potential of FGD is due to the presence of calcium carbonate and calcium hydroxide. FGD with a total neutralizing potential of 60% CCE (calcium carbonate equivalency) was used as a limestone substitute at two different Ohio sites. The first field test was conducted at a highly acidic site (pH of approximately 4.6) near Wooster. The amount of PFBC FGD ash applied to the site was varied from 0, 0.5, 1 and 2 times the lime requirement rate as determined by standard soil tests. The FGD ash was applied in the fall of 1992 and alfalfa was planted that season, while corn was planted in spring of 1993. Alfalfa yields increased rapidly compared with untreated control. Corn yields were not significantly increased with the use of PFBC ash. The concentrations of Boron in alfalfa tissue were high for the FGD plots but were below the phytotoxic levels. Tissue concentrations of aluminum and manganese decreased for all samples. Soil acidity was neutralized in the zone of application (0-4 inches) and within one year the pH correction had extended to a depth of about 12 inches. In 1997, another field experiment was begun in Wooster using a sorbent FGD that contained clay. The CCE of the FGD was 46% and it was applied in the spring of 1997 at a rate based on standard soil tests. Alfalfa was planted on the plots. Sorbent FGD significantly increased alfalfa yields as compared to untreated control plots. The yields were more with the sorbent FGD than when the soils were amended with agricultural limestone. This benefit may be due to the presence of trace elements in the FGD material as well as its neutralizing potential. The plots are being monitored to evaluate their long-term performance. Laboratory and field tests have shown that FGD materials with low boron content, low soluble salt content and high acidic neutralizing potential can be utilized as a soil amendment in place of agricultural limestone. Weathering of FGD prior to application results in lower boron and salt content but decreases its neutralizing potential. Application of FGD to the soil using a conventional limestone spinner spreader can cause excessive dusting due to the fine fly ash particles. A drop box spreader can be used instead for spreading the FGD or it could be mixed with other amendments such as organic matter and incorporated into the soil.

C-3.6 Low Permeability Liner

In order to evaluate the performance of FGD as a liner for ponds, manure holding facilities, and wetlands, a full-scale pond facility was constructed in the summer of 1997 at the Ohio State University’s Ohio Agricultural Research and Development Center near South Charleston. The pond capacity is approximately 150,000 cubic ft. and the facility was constructed using wet FGD as the primary liner. The FGD material used for the project was generated by AEP’s Conesville plant using lime slurry injection. A total of approximately 2700 tons of FGD material was compacted in 4-6 inch lifts to obtain an 18 inches thick FGD liner. The design and construction of the FGD-lined facility was presented by Butalia, et al. (1997) and Wolfe and Butalia (1998). First year monitoring of the facility indicates (a) small amount of water is leaching through the field compacted FGD liner (permeability coefficients using full-scale tests are in the range of 10- 7 cm/sec), and (b) quality of the leachate generally meets the National Primary Drinking Water

158 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

Regulations (Wolfe et al., 1999). The water in the pond is being replaced with swine manure in Septem ber 1998 and the site will be monitored for at least one more year.

C -3.7 Abatement of Acid Mine Drainage

Acid mine drainage (AMD) from abandoned underground coal mines in Ohio causes significant contamination to area streams and lakes. A small abandoned deep mine commonly referred to as Robert-Dawson mine near Coshocton, Ohio was chosen to study the technical feasibility of injecting cementitious alkaline materials such as FGD into the mine to reduce the environmental degradation occurring due to AMD discharge into the local stream. The effluent at the mine entrances had a low pH (2.8-3.0). Wet FGD generated by AEP’s Conesville plant was pressure grouted into the mine through vertical grout injection holes during the winter of 1997-98. The FGD injection was carried out using regular grouting equipment. Approximately 26,000 tons of FGD material was estimated to be pumped into the underground mine. Two types of FGD grouts were injected into the mine. A thicker mine seal mix (slump of 4-6 inches) was used to seal the down dip areas. The intent was to flood the mine behind the plug so that the water level behind the seal would rise above the coal seam. This would lead to a reduction in AMD production, as no oxygen would be available to oxidize the pyrites in the coal. A similar but much more fluid (slump 8-10 inches) grout mix was injected in some of the up-dip areas of the mine. This was done to neutralize the acidic water in the mine and to coat the bottom of the mine with FGD to cover the pyrite material. A detailed description of the Robert-Dawson AMD abatement project was presented by Mafi et al. (1997). Monitoring of the surface and ground water is being conducted to evaluate the impact of FGD injection inside and outside the deep mine.

C-3.8 Construction Aggregate

A program to investigate the technical and economic feasibility of making construction-grade aggregates from wet FGD is under progress by CONSOL. The characterization and bench scale pelletization of FGD material have been completed. The results of this study have shown that products meeting all AASHTO specifications for Class A highway construction aggregates and products meeting important ASTM specifications for lightweight aggregate can be produced from wet FGD material. The synthetic aggregates were produced using CONSOL’s disk pelletization technology. A large amount of synthetic aggregate was produced and used in two field demonstration projects. The first project involved the construction of a bituminous paving test patch with the synthetic aggregate and the second was the construction of a mine stopping wall using lightweight blocks. The durability of the road aggregate and structural integrity of the lightweight blocks is being monitored.

C-3.9 Ohio CCP Pilot Extension Program

Recent research and demonstration projects in Ohio have shown that CCPs can be utilized with proper preparation and oversight. A pilot technology transfer and market development program

159 Market Opportunities for Utilization of Ohio FGD and Other CCPs – Volume 2 May 2000

was established in January 1998 at The Ohio State University. The CCP pilot extension program is the first of its kind in any state in the US. It aimed to move technologies for utilization of CCPs (particularly FGD material) from the research and demonstration phase into the marketplace with the establishment of a statewide Coal Combustion Products Coordinator. Bringing CCP use technology to the marketplace has both economic direct benefits and indirect and societal benefits for Ohio. The direct benefits are most easily quantified and are generally what drive the adoption of a new product or technology. Direct economic benefits include those realized by both the producer of the CCPs and the end user. The producer benefits if the cost associated with support of beneficial uses is lower than that of landfilling or other disposal means. The end user benefits if the CCP application results in lower cost than conventional application. The CCP Coordinator acts as a liaison among the parties interested in CCP use, producing fact and information sheets and providing expertise in the field to those who wish it. The Coordinator also sponsors or co-sponsors seminars, meetings, and speaking at these events, and generally works to promote knowledge about the productive and proper application of these products as useful raw materials. A significant component of this program is the compilation of this market development study, which includes identification of CCP production in Ohio, and the estimated and potential markets for these CCPs particularly in highway/road construction and related civil engineering uses, mine reclamation and agricultural applications. The principal sponsors of the CCP pilot extension program are the Ohio Coal Development Office and The Ohio State University.

C-4 References

Adams, D.A., 1992, Swelling Characteristics of Dry Sulfur Dioxide Removal Waste Products, M.S. Thesis, The Ohio State University, Columbus, Ohio. Adams, D.A., Wolfe, W.E., and Wu, T.H., 1992, Strength Development in FGD-Soil Mixtures, Proceedings of the 9th Annual Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, October, 12- 16, p. 224 -228. Adams, D.,A., and Wolfe, W.E., 1993, The Potential for Swelling in Samples of Compacted Flue Gas Desulfurization By-Products, Tenth American Coal Ash Association Symposium, Orlando, Florida. Beeghly, J., Bigham, J., and Dick, W.A., 1993, An Ohio Based Study on Land Application Uses of Dry FGD By-Products, Tenth American Coal Ash Association Symposium, Orlando, Florida. Beeghly, J., Dick, W., Harness, J., and Wolfe, W.E., 1994, Land Application Uses of Pressurized Fluidized-Bed Combustion (PFBC) Ash, Conference on Management of High Sulfur Coal Combustion Residues, Carbondale, Illinois, April. Beeghly, J., Bigham, J., Dick, W., Stehouwer, R., and Wolfe, W.E., 1995a, The Impact of Weathering and Aging on a LIMB Ash Stockpile Material, Proceedings of 11th International Symposium on Use and Management of Coal Combustion By-Products (CCBs), Orlando, Florida, Jan 15-19, American Coal Ash Association and Electric Power Research Institute, EPRI TR-104657, V. 1. Beeghly, J.., Dick, W.A., and Wolfe, W.E., 1995b, Developing Technologies for High Volume Application Uses of Pressurized Fluidized-Bed Combustion (PFBC) Ash, Proceedings of the International Conference on Fluidized Bed Combustion, ASME, V.2, p. 1243-1257. Bigham J.M., Soto, U.I., Stehouwer, R.C, Yibrin, H., 1999, Use of FGD By-Product Gypsum Enriched with Mg(OH)2 as a Soil Amendment, Report prepared by OARDC Wooster for the Ohio Coal Development Office, Dravo Lime Company, and Cinergy, April, 1999. Butalia, T.S. and Wolfe, W.E., 1997, Re-Use of Clean Coal Technology By-Products in the Construction of Impervious Liners, 1997 Ash Utilization Symposium, Lexington, Kentucky, October 20-22.

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Butalia, T.S., Mafi, S., and Wolfe, W.E., 1997, Design of Full Scale Demonstration Lagoon Using Clean Coal Technology By-Products, 13th International Conference on Solid Waste Technology and Management, Philadelphia, Pennsylvania, November 16-19. Chen, X., W.E. Wolfe and M.D. Hargraves, 1997, The Influence of Freeze-Thaw Cycles on the Compressive Strength of Stabilized FGD Sludge, Fuel, V.76, p. 755-759. Civil Engineering News, 1997, Coal Combustion Product is Good for Highway Use, November.

Dick, W., Stehouwer, R., Sutton, P., Bigham, J., Lal, R., Traina, S., McCoy, E., and Fowler, R., 1993, Plant Growth and Soil Properties Responses to Additions of Dry Flue Gas Desulfurization By-

Products, EPRI/USEPA SO2 Control Symposium, Boston, Massachusetts, August 24-27. Dick, W., Stehouwer, R., and Bigham, J., 1994a, Problems Getting From The Laboratory to The Field: Reclamation of an AML Site, Proceedings of the 11th Annual Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, September 12-16, p. 451-456. Dick, W., Stehouwer, R., Beeghly, J., Bigham, J., and Lal, R., 1994b, Dry Flue Gas Desulfurization By- Products as Amendments for Reclamation of Acid Minespoil, Proceedings of the International Land Reclamation and Mine Drainage Conference, Pittsburgh, Pennsylvania, April 24-29, p. 129- 138. Dick, W., Stehouwer, R., Bigham, J., Wolfe., Adraino, D.C., Beeghly, J., and Murarka, I., 1997, Land Application Uses of Coal Combustion By-Products: Examples and Case Studies,

ASA/CSSA/SSSA Annual Meeting, Anaheim, CA, October 26-31. Dick, W., J. Bigham, L. Forster, F. Hitzhusen, R. Lal, R. Stehouwer, S. Traina and W. Wolfe, R. Haefner, G. Rowe, 1999a, Land Application Uses of Dry FGD By-Product: Phase 3 Report, Electric Power Research Institute, EPRI TR-112916, 1999. Dick, W., J. Bigham, L. Forster, F. Hitzhusen, R. Lal, R. Stehouwer, S. Traina, W. Wolfe, R. Haefner, and G. Rowe, 1999b, Land Application Uses of Dry Flue Gas Desulfurization By-Products: Executive Summary, The Ohio State University, 1999. Hao, Y.L., Dick, W.A., and Stehouwer, R.C., 1998, Inhibition of Acid Production in Coal Refuse Amended with Calcium Sulfite and Calcium Sulfite-Containing FGD, Report submitted to Ohio Coal Development Office, Dravo Lime Company, and CINERGY, June, 1998. Hargraves, M.D., 1994, The Effect of Freeze-Thaw Cycles on the Strength of Flue Gas Desulfurization Sludge, M.S. Thesis, The Ohio State University, Columbus, Ohio. Hite, D., Chern, W., and Hitzhusen, F., 1994, Analysis of Welfare Impacts of Landfilling Coal FGD By- th Products, Proceedings of the 11 Annual Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, September 12-16, p. 431-435. Hitzhusen, F.J., 1992, Social Costs and Benefits of Recycling Coal Fired Power Plant FGD By-Products, Department of Agricultural Economics and Rural Sociology, The Ohio State University, Columbus, Ohio. Kalyoncu, R., 1996, Coal Combustion Byproducts, US Geological Survey- Minerals Information. Kim, S., Wolfe, W., and Wu, T., 1992a, Permeability of FGD By-Products, Proceedings of the 9th Annual Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, October 12-16. p. 218-223. Kim, S.H., Wolfe, W.E., and Hadipriono, F.C., 1992b, The Development of a Knowledge Based Expert System For Utilization of Coal Combustion By-Products in Highway Embankment, Civil Engineering Systems, V. 9, pp. 41-57. Kim, S.H., Wolfe, W.E., and Hadipriono, F.C., 1993, An Intelligent Decision Support System for Embankment Design Using FGD By-Products, Symposium on Recovery and Effective Reuse of Discarded Materials and By-Products for Construction of Highway Facilities, Denver, Colorado, October. Kim, S.H., 1994, A Decision Support System for Highway Embankment Design Using FGD By- Products, Ph.D. Dissertation, The Ohio State University, Columbus, Ohio. Kim, S.H., Nodjomian, S., and Wolfe, W.E., 1995, Field Demonstration Project Using Clean Coal Technology By-Products, Proceedings of 11th International Symposium on Use and Management

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of Coal Combustion By-Products (CCBs), Orlando, Florida, Jan 15-19, American Coal Ash Association and Electric Power Research Institute, EPRI TR-104657, V. 1, p. 16(1-15). Kost, D., Stehouwer, C., and Vimmerstedt, J.P., 1997, Initial Growth of Ground Cover and Trees on Acid Mine Spoils Treated With Wet Flue Gas Desulfurization By-Products, Sewage Sludge, and Borrow Soil, 1997 Ash Utilization Symposium, Lexington, Kentucky, October 20-22. Logan, T.J., 1992, Mine Spoil Reclamation with Sewage Sludge Stabilized with Cement Kiln Dust and

Flue Gas Desulfurization Byproduct (N-Viro Soil Process), National Meeting of the American Society for Surface Mining and Reclamation, Duluth, Minnesota, Jun 14-18, 1992. Mafi, S., Damian, M.T., and Baker, R., 1997, Injection of FGD Grout to Abate Acid Mine Drainage in Underground Coal Mines, 1997 Ash Utilization Symposium, Lexington, Kentucky, October 20- 22. Nelson Jr., S., Dick. W., and Chen, L., Agricultural Field Tests of Fluesorbent FGD By-Products, EPRI- DOE-EPA Combined Utility Air Pollutant Control Symposium, Atlanta, Georgia, August 17, 1999. Nodjomian, S.M., 1994, Clean Coal Technology By-Products Used in a Highway Embankment Stabilization Demonstration Project, M.S. Thesis, The Ohio State University, Columbus, Ohio. Nodjomian, S.M., and Wolfe, W.E., 1994, Field Demonstration Projects Using Clean Coal Technology By-Products, Second Annual Great Lakes Geotechnical/Geoenvironmental Conference, West

Lafayette, Indiana, May. Payette, R.M., W.E. Wolfe and J. Beeghly, 1997, Use of Clean Coal Combustion By-Products in Highway Repairs, Fuel, V.76, p. 749-753. Roy, B.L., 1994, The Effect of Freeze-Thaw Cycling on the Resilient Modulus of Clean Coal Technology By-Products, M.S. Thesis, The Ohio State University, Columbus, Ohio. Soto, U., Fowler, R., Bigham, J., and Traina, S., 1993, Solution Chemistry and Mineralogy of Clean Coal Technology By-Products and Mine-Spoil Mixtures, American Society of Agronomy Meetings, Cincinnati, Ohio, November 7-12. Stehouwer, R.C., Sutton, P., and Dick, W., 1993, Growth of Fescue on Acid Minespoil Amended With FGD and Sewage Sludge, American Society of Agronomy Meetings, Cincinnati, Ohio, November 7-12. Stehouwer, R., Dick, W., Bigham, J., Forster, L., Hitzhusen, F., McCoy, E., Traina, S. and Wolfe, W.E., Haefner, R., 1995a, Land Application Uses for Dry FGD By-Products: Phase 1 Report, Electric Power Research Institute, EPRI TR-105264. Stehouwer, R.C., Sutton, P., Fowler, R.K., and Dick, W.A., 1995b, Minespoil Amendment With Dry Flue Gas Desulfurization By-Products: Element Solubility and Mobility, Journal of Environmental Quality, V.24, p. 165-174. Stehouwer, R.C., Sutton, P., and Dick, W.A., 1995c, Minespoil Amendment With Dry Flue Gas Desulfurization By-Products: Plant Growth, Journal of Environmental Quality, V.24, p. 861-869. Stehouwer, R., Sutton, P., Dick, W., 1995d, Use of Clean Coal Technology By-Products as Agricultural Liming Materials, Proceedings of 11th International Symposium on Use and Management of Coal Combustion By-Products (CCBs), Orlando, Florida, Jan 15-19, American Coal Ash Association and Electric Power Research Institute, EPRI TR-104657, V. 1, p. 1(1-14). Stehouwer, R., and Dick, W., 1997, Soil and Water Quality Impacts of a Clean Coal Combustion By- Product Used For Abandoned Mined Land Reclamation, Proceedings of 12th International Symposium on Coal Combustion By-Product (CCB) Management and Use, American Coal Ash Association and Electric Power Research Institute, V. 1, p. 7(1-12). Stehouwer, R., W. Dick, J. Bigham, L. Forster, F. Hitzhusen, E. McCoy, S. Traina and W. Wolfe, R. Haefner, G. Rowe, 1998. Land Application Uses of Dry FGD By-Products: Phase 2 Report, Electric Power Research Institute, Report # EPRI TR-109652. Stewart, B., 1997, Coal Combustion Products (CCPs) Production and Use: Current Trends, 1997 Ash Utilization Symposium, Lexington, Kentucky, October 20-22.

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Sutton, P., Stehouwer, R., 1992, Dry FGD By-Products as a Soil Amendment for Acidic Minespoils, Proceedings of the 9th Annual Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, October 12- 16, p. 253-258. Sutton, P., Stehouwer, R., Dick, W.A., 1994, Mobility and liming Efficacy of Soil-Applied Dry, Alkaline FGD By-Product, American Society of Agronomy Meetings, Seattle, Washington, November 13- 18.

Wolfe, W.E., Wu, T.H., and Beeghly, J.H., 1992, Laboratory Determination of Engineering Properties of Dry FGD By-Products, Proceedings of the 9th Annual Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, October 12-16, p. 229-234. Wolfe, W.E, and Beeghly, J.H., 1993, Truck Ramp Construction From Clean Coal Technology Waste Products, Symposium on Recovery and Effective Reuse of Discarded Materials and By-Products for Construction of Highway Facilities, Denver, Colorado, October. Wolfe, W.E., Cline, J.H., 1995, A Field Demonstration of the Use of Wet and Dry Scrubber Sludges in Engineered Structures, Proceedings of 11th International Symposium on Use and Management of Coal Combustion By-Products (CCBs), Orlando, Florida, Jan 15-19, American Coal Ash Association and Electric Power Research Institute, EPRI TR-104657, V. 1, p. 17(1-10). Wolfe, W.E., Butalia, T.S., and Meek, B.L., 1997, Influence of Freeze Thaw Cycling on Resilient Modulus of Clean Coal Technology By-Products, 1997 Ash Utilization Symposium, Lexington,

Kentucky, October 20-22. Wolfe, W.E., and Butalia, T.S., 1998, Use of FGD as an Impervious Liner, 23rd International Technical Conference on Coal Utilization and Fuel Systems, Clearwater, Florida, March 9-13. Wolfe, W.E., Butalia, T.S., and Fortner, C., 1999, Preliminary Performance Assessment of an FGD-Lined Pond Facility, 13th International Symposium on Management and Use of Coal Combustion Products (CCPs), Orlando, Florida, January 11 -14.

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APPENDIX D

ODOT EMBANKMENT DRAFT SPECIFICATION

STATE OF OHIO DEPARTMENT OF TRANSPORTATION SUPPLEMENTAL SPECIFICATION 880

EMBANKMENT CONSTRUCTION USING RECYCLED MATERIALS

March 1, 2000

880.01 Description 880.02 Materials 880.03 Environmental Restrictions on Use 880.04 Soils Consultant Analysis 880.05 Geotechnical Restriction on Use 880.06 Construction Requirements 880.07 Method of Measurement 880.08 Basis of Payment

880.01 Description. This work includes the construction of embankment using recycled materials. Substitute recycled materials for soil in 203 Embankment Items in the contract or use recycled materials when they are specifically called out in the contract documents.

It is not a requirement to use the recycled material in the embankment unless specifically called for in the contract.

Item 203, Roadway Excavation and Embankment shall apply: deviations from these are as follows.

880.02 Materials. Recycled materials are fly ash, bottom ash, foundry sand, recycled glass, tire shreds, and petroleum contaminated soil (PCS).

Fly ash and bottom ash are defined as the residue resulting from the burning of ground or powdered coal. Furnish bottom ash with at least 35% of the material retained on the #4 (4.75mm) sieve on a dry weight basis.

Foundry sand is spent foundry sand generated from foundry operations.

Use container glass used for consumer food and beverages, beverage drinking glasses, plain ceramic or china, dinner ware, building window glass free from framing material for recycled glass. Hazardous wastes or hazardous substances, automobile windshields or other glass from automobiles, light bulbs of any kind, laboratory glass, television glass, computer or other cathode monitor tubes are not allowed.

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Crush the recycled glass to a maximum size of 1" (25 mm). Use recycled glass that is 95% free from foreign material by visual inspection.

Make shredded tires from scrap tires. Do not use any tire shreds with contaminates such as oil, grease, gasoline, diesel fuel, etc. that could leach into the groundwater or create a fire hazard. Do not use tire shreds that contain the remains of tires that have been subjected to a fire because the heat of a fire may liberate liquid petroleum products from the tire that could leach into the groundwater or create a fire hazard when the shreds are placed in a fill.

Use tire shreds with the following:

- A maximum dimension, measured in any direction, of 8 inches (200mm).

- 100% passing the 4 inch (100mm) square mesh sieve, a minimum of 95% passing the 3 inch (75mm) square mesh sieve, a minimum of 50% passing the 1½-inch (38mm) square mesh sieve, and a maximum of 5% passing the No. 4 (4.75mm) sieve. All percentages are calculated by weight.

-Less than 1% (by weight) of metal fragments which are not at least partially encased in rubber.

-At least one side wall shall be severed from the tread of each tire.

-Free from fragments of wood, wood chips, and other fibrous organic matter.

-Metal fragments that are partially encased in rubber shall protrude no more than 1 in. (25 mm) from the edge of the tire shred on 75% of the pieces and no more than 2 inches (50 mm) on 100% of the pieces.

-Free of ice and snow.

The minimum dry weight requirements in Item 203 are waived for all recycled materials.

Submit a sample of approximately 50 pounds of the recycled material to the Laboratory at least 30 days prior to the incorporation into the work.

880.03 Environmental Restrictions on Use. Submit all the information stated below in a suitable format to the Engineer 10 working days prior to the intended usage. Use recycled materials that conforms with all environmental policies, rules and regulations and the following:

(A) Fly ash, Bottom ash, and Foundry Sand. Determine if fly ash, bottom ash and foundry sand meets the requirements of the Division of Surface Water Policy 400.007 “Beneficial use of Non- Toxic Bottom Ash, Fly Ash and Spent Foundry Sand and other Exempt Wastes,” and all other regulations. Obtain written approval from the Ohio Environmental Protection Agency (OEPA). Provide all additional work required by the EPA at no additional cost to the Department.

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(B) Petroleum Contaminated Soil. Certify to the Engineer by an independent Department approved environmental consultant that the PCS material does not exceed the petroleum constituent concentrations stated in OAC 1301: 7-9-16(I)(1)(c)(ii)(b). These values are below:

Benzene 35 parts per million Toluene 109 parts per million Ethylbenzene 32 parts per million Total Xylenes 165 parts per million

Include test results from BTEX testing by using United States Environmental Protection Agency (USEPA) test method SW 846 method 8020 or equivalent method.

Perform the tests on every 100 tons (90 metric tons) of PCS used on the project.

(C) Notify the Scrap Tire Management Unit, Robert Large at 614-728-5347 10 days prior to the use of the scraps tire in the fills.

(D) Certify that all recycled materials not listed above used on this project conforms with all environmental policies, rules and regulations.

880.04 Soils Consultant Analysis. Use an independent soils consultant approved by the Department to submit the following information:

Except for recycled glass and tire shreds, classify the recycled material as per Section 4.3 of the Department’s “Specifications for Subsurface Investigation Manual”.

Determine the suitability of the recycled material for use under Item 203 Embankment Materials as it applies to the project intended usage.

Make a moisture density curve in accordance with AASHTO T 99 for every 250 tons (225 metric tons) of the recycled material, except for recycled glass and tire shreds.

Use a Registered Professional Engineer to write and seal the above information in a suitable format to the Engineer at least 10 working days prior to the proposed work.

880.05 Geotechnical Restrictions on Use. Do not use recycled material within the top 3 feet(1 m),(5.0 feet for tire shreds), of the final subgrade elevation or within 8 feet (2.5 m ) from any exposed surface.

Keep the outer soil cover at lest 1.0 foot (0.3m) above the recycled materials at all times. Do not dump or spread the recycled material on soft areas or in standing water.

For internal drainage, except for tire shreds, place Item 605 aggregate drains at 50 foot (15m) intervals at the toe of the slopes on each side of the embankment. Extend the aggregate drains

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through the outside 8 feet (2.5m) of cover and completely wrapped with 712.09 Type A fabric. As an alternative, 707.45 Polyvinyl Chloride pipe may be used, provided that the inner end of the pipe is completely wrapped with 712.09 Type A fabric.

Place the tire shreds at a maximum 3.0 foot(1.0 m) layer. Use an 18 inch (450mm) layer of granular soil below the each tire shred layer and extend the granular layer to day light the gr anular soil through the side slope cover soil. Use a well graded granular soil classified as AASHTO A-1, A-3 ,A-2-4, A-2-6,or A-2-7.

Completely separate and enclose the 3.0 foot tire shred layer (1.0m), (top, sides and bottom) with a geotextile fabric meeting 712.09 Type D. Use sufficient lapping, tying or stapling of the fabric to complete the work.

Complete the side slopes and surface of the tire shred course to a condition of uniform stability and compaction. To compensate for settlement of the tire shreds caused by the weight of the overlaying soil, place a surcharge layer on the subgrade. Place 1.0 foot of surcharge for every 3.0 feet (1 m) of tire shreds used.

Place settlement platforms at the bottom of each 3.0 foot layer of tire shreds. Use one settlement platform for every 5000 square yards of tire fill. Have a prequalified soils consultant monitor the settlement. Leave the surcharge in place until 90% consolidation of the tire shreds is achieved or 2 months, which ever is longer. Receive approval prior to the removal of the surcharge.

Do not use for any tire shreds for bedding or backfill of any pipe or within 100 feet (30 m) of any structure, as measured horizontally.

880.06 Construction Requirements. Produce a stable embankment. Place recycled materials in 8 inch (200mm) loose lifts. Compact with a self propelled vibratory roller with a minimum weight of 10 tons, except for PCS material.

Coordinate the compaction operation with the spreading operation as to minimize the uncompacted recycled material spread out on the embankment. Do not leave fly ash material uncompacted overnight.

Provide sufficient moisture to prevent dusting when fly ash , bottom ash and foundry sand are hauled, spread, or stockpiled on the site. Use a securely fastened cover of suitable material to prevent dusting while hauling the fly ash. Keep fly and bottom ash surface damp to prevent dusting. If the work is suspended long enough to make watering impractical, or if not necessary, then use other methods.

When water is needed for compaction, uniformly mix water throughout the lift to bring the recycled material to the specified moisture.

Compact the fly and bottom ash at optimum moisture minus 3 or more, or to a moisture content to obtain the density and the stability. Compact the fly and bottom ash to 97 % of T-99 or to a

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density determined as per Item 304, which ever is greater. The Engineer will determine the moisture correction when using the nuclear gauges.

Compact foundry sand at a moisture content and to a density determined as per Item 304.

Compact recycled glass to a density determined as per Item 304 or eight passes which ever is more, except water is not needed to aid in the compaction.

Alternate layers of PCS material with other Department approved soil layers (other than recycled material). Compact PCS material with a self propelled tamping foot or smooth drum vibratory roller with a minimum weight of 10 tons.

Place each layer of tire shreds over the full width of the section. Spread the tire shreds with track mounted bulldozers, rubber tired motor graders, backhoes, or other equipment as needed to obtain a uniform layer thickness. Spread with no pockets of either fine or coarse tire shreds. Do not segregate large or fine particles.

Compact each lift of tire shreds with eight passes of a vibratory smooth drum roller with a minimum static weight of 10 tons.

Compact the PCS material at a moisture content to obtain the required density and embankment stability. Compact the PCS material to a density required under 203 or to a density determined as per Item 304, which ever is greater.

880.07 Method of Measurement. The recycled material will be paid as per the 203 Items in the contract documents or as a separate pay item when denoted in the contract documents.

880.08 Basis of Payment. The contract unit price per cubic yard (cubic meter) for the 203 Items or 880 Items in the contract documents will include full compensation for furnishing all materials,(e.g. pipe, settlement plat forms fabrics, water, granular material, surcharge) , all equipment, testing, analysis, certifications and all work, labor, and incidentals involved with the recycled material furnishing, placement, compaction, grading and acceptance and all other items listed above.

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Item Unit Description

880 Cubic yard Embankment Using Fly Ash (cubic meter)

880 Cubic yard Embankment Using Bottom Ash (cubic meter)

880 Cubic yard Embankment Using Foundry Sand (cubic meter)

880 Cubic yard Embankment Using Recycled Glass (cubic meter)

880 Cubic yard Embankment Using Tire Shreds (cubic meter

880 Cubic yard Embankment Using ______(cubic meter

880 Cubic yard Embankment Using Recycled Materials (cubic meter

Designers note: Prior to incorporation of this note into the plans the designer needs to perform a geotechnical review of the fills by the Geotechnical Section of the Office of Materials Management or Prequalified Soils Consultant.

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APPENDIX E

AMLIS DATABASE SEARCH RESULTS

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APPENDIX F

STANDARD TEST PROCEDURES, SPECIFICATIONS, AND GUIDELINES

This appendix contains standard test procedures, specifications, guidance documents, design manuals, fact sheets etc. that have been developed for the testing, utilization, and disposal of CCPs.

Engineering Characteristics ASTM D 422: Grain Size Distribution ASTM D 2216, D4643: Moisture Content ASTM D 854: Specific Gravity ASTM D 698, D 1557: Density ASTM D 2166, D 3080, D 2435: Shear Strength ASTM D2166, D5102: Unconfined Compressive Strength ASTM D 2435: Consolidation ASTM D 2434, D5084: Permeability ASTM D 2325: Capillarity ASTM D 560: Frost Susceptibility ASTM D3877: Swell potential and uplift pressures ASTM D5759, Standard Guide for Characterization of Coal Fly Ash and Clean Coal Combustion Fly Ash for Potential Uses ASTM Specifications Pertaining to Coal Ash (Fly Ash or Bottom Ash): Report provided by the American Coal Ash Association.

Leaching Characteristics Toxicity Characteristic Leaching procedure (TCLP), US EPA Method 1311 Synthetic Precipitation Leaching Procedure (SPLP), US EPA Method 1312 Multiple Extraction Procedure (MEP), US EPA Method 1320 ASTM D-3987, Standard Test Method for Shake Extraction of Solid Waste with Water, 1995 ASTM D-4793, Standard Test Method for Sequential Batch Extraction of Waste with Water, 1995 ASTM Method D-5284, Standard Test Method for Sequential Batch Extraction of Waste with Acidic Extraction Fluid, ASTM, 1995 ASTM Method D-4874, Standard Test Method for Leaching Solid Waste in a Column Apparatus, ASTM, 1995 American Coal Ash Association, Summary of Leaching Methods, April 1997.

Concrete Applications ASTM C14/C14M-95: Standard Specification for Concrete Sewer, Storm Drain, and Culvert Pipe, ASTM Vol. 4.05.

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ASTM C227-90: Standard Test Method for Potential Alkali Reactivity of Cement-Aggregate Combinations (Mortar-Bar Method), ASTM Vol. 4.02. ASTM C311-97: Standard Test Methods for Sampling and Testing Fly Ash or Natural Pozzolans for Use as a Mineral Admixture in Portland Cement Concrete, ASTM Vol. 4.02. ASTM C330-89: Standard Specification for Lightweight Aggregates for Structural Concrete. ASTM Vol. 4.02. ASTM C331-94: Standard Specification for Lightweight Aggregates for Concrete Masonry Units, ASTM Vol. 4.02. ASTM C332-91: Standard Specification for Lightweight Aggregates for Insulating Concrete., ASTM Vol. 4.02. ASTM C441-89: Standard Test Method for Effectiveness of Mineral Admixture of Ground Blast Furnace Slag in Preventing Excessive Expansion of Concrete Due to the Alkali-Silica Reaction, ASTM Vol. 4.02. ASTM C593-95: Standard Specification for Fly Ash and Pozzolans for Use with Lime, ASTM Vol. 4.01. ASTM C595/C595M-95a: Standard Specification for Blended Hydraulic Cements, ASTM Vol. 4.01. ASTM C618-97: Standard Specification for Coal Fly Ash or Calcined Natural Pozzolan for Use as a Mineral Admixture in Portland Cement Concretes, ASTM Vol. 4.02. ASTM C938-91: Standard Practice for Proportioning Grout Mixtures for Preplaced Aggregate Concrete, ASTM Vol. 4.02. ASTM C1141-94: Standard Specification for Admixtures for Shotcrete. ASTM Vol. 4.02. ASTM C1157/C1157M-95: Standard Performance Specification for Blended Hydraulic Cement, ASTM Vol. 4.01. ASTM C1260-94: Standard Test Method for Potential Alkali Reactivity of Aggregates (Mortar- Bar Method), ASTM Vol. 4.02. ASTM D5370-96: New Standard Specification for Pozzolanic Blended Material in Construction Applications, ASTM Committee D34. ASTM Vol. 11.04. American Coal Ash Association, Sulfate Resistance of Fly Ash Concrete: An Overview of Selected Publications, March 1995. American Coal Ash Association, Increased Fly Ash Use Under the Climate Challenge Program: A Summary of Participation Accords Between the Electric Utilities and the U.S. Department of Energy, March 1996. Mid-Atlantic Regional Technical Committee , Guide to Alkali-Aggregate Reactivity, June 1993 Mid-Atlantic Regional Technical Committee, Guide Specifications for Concrete Subject to Alkali-Silica Reactions, June 1993 American Concrete Institute, 1996, Guide for Selecting Properties of High-Strength Concrete With Portland Cement and Fly Ash, American Concrete Institute Manual of Concrete Practice, Part 1, ACI 211.4R-93, American Concrete Institute, Detroit, Michigan, 1996.

Bituminous Paving Mixtures ASTM D242-89: Standard Specification for Mineral Filler for Bituminous Paving Mixtures, ASTM Vol. 4.03. American Coal Ash Association, Flexible Pavement Manual, 1991

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Controlled Low Strength Material (CLSM) ASTM D4832-95: Standard Test Method for Preparation and Testing of Controlled Low Strength Material (CLSM) Test Cylinders. ASTM Vol. 4.09. ASTM D5971-96: Standard Practice for Sampling Freshly Mixed CLSM. ASTM Vol. 4.09. ASTM D6023-96: Standard Test Method for Unit Weight, Yield, and Air Content (gravimetric) of CLSM. ASTM Vol. 4.09. ASTM D6024-96: Standard Test Method for the Ball Drop on CLSM to Determine Suitability for Load Application. ASTM Vol. 4.09. ASTM D6103-97: Standard Test Method for Flow Consistency of CLSM. ASTM Vol. 4.09. American Concrete Institute, 1994, Controlled Low Strength Materials (CLSM), American Concrete Institute Committee 229, Report No. 229R-94, American Concrete Institute, Detroit, Michigan, July, 1994.

Structural Fills ASTM E1861-97: Standard Guide for Use of Coal Combustion Fly Ash in Structural Fills. ASTM Vol. 11.04. ASTM E1266-88: Standard Practice for Processing Mixtures of Lime, Fly Ash, and Heavy Metal Wastes in Structural Fills and Other Construction Applications, ASTM Vol. 11.04. ASTM E 850: Standard Practice for Use of Inorganic Process Wastes as Structural Fill

Highway Construction Federal Highway Administration, 1997, User Guidelines for Waste and Byproduct Materials in Pavement Construction, Turner-Fairbank Highway Research Center, FHWA-RD-97-148. (http://www.tfhrc.gov/, follow Materials Technology link to Secondary Materials Recycling Center to Publications) EPRI, 1995. Environmental Performance Assessment of Coal Combustion By-Product Use Sites: Road Construction Applications. EPRI TR-105127. Electric Power Research Institute, Palo Alto, CA 94304 American Coal Ash Association, 1995. Fly Ash Facts for Highway Engineers, FHWA-SA-94- 081, U.S. Dept. Of Transportation. Federal Highway Administration, Washington, D.C American Coal Ash Association, 1991, Flexible Pavement Manual, Alexandria, Virginia, 1991. EPRI, 1994. Use of FGD Gypsum and Bottom Ash in Roadway and Building Construction. EPRI TR-103856 Electric Power Research Institute, Palo Alto, California.

Soil Stabilization ASTM D5239-92: Standard Practice for Characterizing Fly Ash for Use in Soil Stabilization. ASTM Vol. 4.09. ASTM D5434-93: Standard Test Method for Diagnostic Soil Test for Plant Growth and Food Chain Protection, ASTM Vol. 4.09. American Coal Ash Association, Soil and Pavement Base Stabilization with Self-Cementing Coal Fly Ash, May 1999.

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Agricultural Uses Butalia, T., Dyer, P., Stowell, R., Wolfe, W., 1999b, Construction of Livestock Feeding and Hay Bale Storage Pads Using FGD Material, The Ohio State Extension Fact Sheet, AEX-332- 99, The Ohio State University, Columbus, Ohio. Korack, R.F., Agricultural Uses of Coal Combustion Byproducts, Chapter 6 of Agricultural Uses of Municipal, Animal and Industrial Byproducts, USDA-Agricultural Research Service, Conservation Research Report Number 44, January 1998, pp. 103-119 (NTIS document PB98128739) Korack, R.F., Agricultural Uses of Phosophogypsum, Gypsum, and Other Industrial Byproducts, Chapter 7 of Agricultural Uses of Municipal, Animal and Industrial Byproducts, USDA- Agricultural Research Service, Conservation Research Report Number 44, January 1998, pp. 120-126 (NTIS document PB98128739) Stout, W.L., Hern, J.L, Korcak, R.F., and Carlson, C.W., Manual for Applying Fluidized Bed Combustion Residue to Agricultural Lands, USDA-Agricultural Research Service, ARS- 74, 15 pp., August, 1988 Stout, W.L., and Korack, R.F., Manual for Applying Fluidized Bed Combustion Residue to Agricultural Lands – Revised, Draft by USDA-Agricultural Research Service, November, 1996 Standards for the Use or Disposal of Sewage Sludge, Federal Register, 1993, Final Rule (Part II, 58 FR-9248), Federal Register 58:032, February 19, 1993. Soholt, L.F., et al., Coal Combustion Waste Manual: Evaluating Impacts to Fish and Wildlife, U.S. Fish and Wildlife Service, Biological Services Program, National Power Plant Team, FWS/OBS-81/05. 150 pp. 1981. ASTM C22, Standard Specification for Gypsum ASTM C602, Specification for Agricultural Liming Materials EPRI, 1995. Land Application of Coal Combustion By-Products: Use in Agriculture and Land Application. EPRI TR-103298. Electric Power Research Institute, Palo Alto, California

Impact on Fish and Wildlife Soholt, L.F., et al. 1981. Coal Combustion Waste Manual: Evaluating Impacts to Fish and Wildlife. U.S. Fish and Wildlife Service, Biological Services Program, National Power Plant Team, FWS/OBS-81/05. 150 pp.

Landfill Disposal EPRI, 1995. Coal Ash Disposal Manual: Third Edition. EPRI TR-104137. Electric Power Research Institute, Palo Alto, California EPRI, 1995. FGD By-Product Disposal Manual: Fourth Edition. EPRI TR-104731. Electric Power Research Institute, Palo Alto, California

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APPENDIX G

COMPARISON WITH REGIONAL STATES

In this Appendix, the prevalent regulation practices for states neighboring Ohio are presented. These include Indiana, Illinois, Kentucky, Virginia, West Virginia, Pennsylvania, and Michigan. Also attached is a table published by the American Coal Ash Association (1998) on the authorized and allowed uses of CCPs across the various states.

Indiana: Under Indiana law, fly ash, bottom ash, or such ash when mixed with flue gas desulfurization products may not be regulated if the material is not hazardous and is disposed in a properly permitted and approved facility. Additionally, fly ash, bottom ash, or such ash when mixed with flue gas desulfurization products or boiler slag may not be regulated when used in the following manner IND. CODE 13-19-3-3: · For the extraction and recovery of materials and compounds within the ash; · As an anti-skid material (bottom ash); · As raw material in manufacturing another product; · For mine subsidence, mine fire control, and mine sealing (Note: restrictions may apply under the laws and regulations applicable to mining); · As structural fill when combined with cement, sand or water to produce a controlled strength fill material; and · As a base in road construction. The Indiana Department of Environmental Management ("IDEM") has prepared Coal Ash Classification Guidelines specifying testing and other requirements for CCBs proposed for reuse in ways other than those specified above. Although the guidelines are currently being updated, under the current guidelines and other applicable regulations (329 IAC 10-9-4), CCBs may be disposed at Type I restricted waste sites (generally a site designed as a sanitary landfill) without specific testing. CCBs may be disposed of at other waste sites (Types II, III, IV) only if (329 IAC 10-9-4): · EP toxicity results for arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver are within specified limits; · TCLP results for barium, boron, chlorides, total cyanide, fluoride, Ph, sodium, sulfate, total sulfide and total dissolved solids are within specified limits; and Resampling is conducted every five years, whenever the characteristics of the coal change, whenever the process generating the waste changes or as otherwise required by IDEM. IDEM’s Office of Solid and Hazardous Waste Management has prepared procedures for land application of biosolids, industrial waste product, and pollutant-bearing water (327-IAC 6.1), which includes FGD or CCPs mixed with or without biosolids for food or feed applications. Rulemaking pertaining to mine haul back of ash is currently in progress. Other CCB applications may be authorized upon IEPA's written determination that the proposed use has no greater adverse environmental impact that the beneficial uses specified in the law.

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Illinois: Under Illinois regulations, fly ash, bottom ash, slag and flue gas emission control waste generated primarily from the combustion of coal or other fossil fuels are exempt from regulation as hazardous waste. 35 ILL. ADMIN. CODE §721.104.

In 1995, Illinois enacted legislation specifically authorizing reuse of coal combustion waste. 415 ILCS 5/3.94 (P.A. 89-93). P.A. 89-93 creates two classifications of coal ash: coal combustion waste ("CCW") and coal combustion byproduct ("CCB"). CCW is subject to limited management and disposal options. CCB, on the other hand, may be used in multiple applications as discussed below. The term CCW includes fly ash, bottom ash, slag or flue gas or fluid bed desulfurization by-products generated through combustion of coal. The term also includes waste from coal combusted with the following: · Fuel grade petroleum coke, other fossil fuel, both fuel grade petroleum coke and other fossil fuel; or · Fuel grade petroleum coke, other fossil fuel, or both fuel grade petroleum coke and other fossil fuel in combination with no more than 20% tire derived fuel or wood or other materials by weight of the material combusted. Note: An Agency determination is required that storage and disposal of the resultant wastes will not result in an environmental impact greater than waste from the combustion of coal alone and that the storage and disposal of the resultants wastes will not violate federal law. CCW can be classified as CCB under certain conditions and reused based on this classification. CCB may be reused as follows: · For the extraction and recovering of materials and compounds within the ash; · As a raw material in the manufacture of cement, concrete, concrete products and concrete mortars; · For asphalt or cement based roofing shingles; · In plastic products, paints and metal alloys; · In conformance with the specifications and under the approval of the Illinois Department of Transportation ("IDOT"); · As anti-skid material, athletic tracks or foot paths (bottom ash); · As a lime substitute in the lime modification of soils so long as the CCBs meet the IDOT specifications for by-product limes, and the functional equivalent for agricultural lime as a soil conditioner; · As an agricultural soil amendment in the form of FGD gypsum; · In non-IDOT pavement base, pipe bedding, or foundation backfill (bottom ash); · As structural fill when used in an engineered application or combined with cement, sand or water to produce a controlled strength fill material and covered with 12 inches of soil unless infiltration is prevented by the material itself or other cover material; and · For mine subsidence, mine fire control, mine sealing and mine reclamation. Certain restrictions apply to reuse of CCBs. The user of CCBs in certain applications must notify the Illinois Environmental Protection Agency ("IEPA") of each project utilizing CCBs, document the quantity of CCBs that will be utilized and certify that the CCBs have not been mixed with hazardous waste prior to use and that the CCBs do not exceed Class I groundwater quality standards for metals when tested utilizing ASTM method D3987-85. Dust generation in fly ash applications must be minimized. CCBs may not be accumulated speculatively. Note:

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CCBs are not accumulated speculatively if 75% of the CCBs accumulated at the beginning of a calendar year are used during the calendar year.

Mine applications of CCW and/or CCBs must meet the requirements specified in 415 ILCS 5/21(r) and certain guidance memorandum issued by the Illinois Department of Mines and Minerals ("IDMM") and IEPA. IDMM and IEPA have dual jurisdiction over mine disposal of CCBs. IDMM and IEPA have issued joint memorandums detailing the procedures and requirements for mine disposal of CCBs. (Land Reclamation Memorandum 92-11 and Land Reclamation Memorandum 95-89). Groundwater monitoring and liners may be required by IDMM and IEPA in certain applications. In addition, CCW requirements are more stringent than those for CCB. Specifically: · CCW waste disposal must be associated with coal sales (on a company wide basis) of the coal company. A coal company may not dispose of CCW from a company that has not purchased coal from the mine. · CCW disposal may not exceed 35% of coal sales unless information is submitted justifying a higher percentage (According to Scott Schmitz of IDMM, additional volumes will be allowed if it is established that the particular combusted coal generates a greater volume of ash). Initially, this restriction was stated as a limitation applicable to each coal sales source. This requirement was clarified in a November 20, 1995 IDMM memo which states that IDMM is not limiting each CCW source to a 35% disposal limit, but that the 35% limit applies to total coal company sales. source The quantity of CCW from each source as well as the total quantity of CCW received at the disposal site must be reported quarterly. Other CCB applications may be authorized upon IEPA's written determination that the proposed use has no greater adverse environmental impact that the beneficial uses specified in the law.

Kentucky: Under Kentucky regulations, CCBs are exempt from regulation as hazardous waste but are classified as special waste. Specifically included within the definition of coal combustion by-products classified as special waste is fly ash, bottom ash, and scrubber sludge produced by coal fired electrical generating units. Excluded is boiler slag, and residues of refuse derived fuels such as municipal waste, tires and solvents. KY. REV. STAT. ANN. §224.50-760(1)(a); 401 KY. ADMIN. REGS. 45:010 §(4).

Under Kentucky law, CCBs (as defined above) may be reused under permit by rule regulation as follows: · As an ingredient in manufacturing a product; · As an ingredient in cement, concrete, paint and plastics; · As anti-ski material; · As highway base course; · Structural fill; · As blasting grit; · As roofing granules; and · For disposal in an active mining operation if the mine owner/operator has a mining permit which authorizes disposal of special waste. (See also KY. REV. STAT. ANN. §350.270.)

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Specific conditions for reuse of CCBs apply. These conditions under 401 KAR 45:060 include: · The CCB reuse may not create a nuisance; · Erosion and sediment controls must be undertaken; · The CCB reuse must be at least 100 feet from a stream and 300 feet from potable wells, wetlands or flood plains; · The ash must be "non-hazardous;" and · The generator must submit an annual report identifying the type and amount of waste released for reuse, the name and address of the recipient of the waste intended for reuse, and the specific use, if known, each waste recipient made of the CCB. Mine applications must be specifically authorized under the terms of a permit issued by the Department for Surface Mining, Reclamation and Enforcement. Regulatory requirements to obtain such permit authorization along with operational requirements can be found at KY. REV. STAT. ANN. §350.270. In summary: · CCBs mixed with low volume waste or material with hazardous waste characteristics may not be used in mine applications; · CCBs generated prior to a certain date may not be used in mine applications unless a satisfactory demonstration is made that the CCBs have not been mixed with low volume waste or material with hazardous waste characteristics; · CCBs may be placed only in the pit or extraction area from which coal has been removed by surface mining. Placement of CCBs in other areas within the permit area may be allowed only upon a satisfactory demonstration, based on site specific conditions and the characteristics of the CCBs, that no adverse environmental impacts will occur. Underground injection of CCBs is not authorized; · The permittee must keep records of the source and amount of CCBs received; · Any material that is not CCB approved for disposal must be removed. The permittee must keep records describing the removed material and its disposition; · The permittee must maintain maps showing each CCB disposal location, and the volume of CCBs disposed of at that location; · An annual CCB lab analysis report must be submitted; · An application to modify an existing permit to initially include CCB disposal will be considered a major permit revision application; · An application for CCB mine disposal must demonstrate the permittee's legal right to conduct such activities. Public notice of the application is required; and · The application must contain specific information such as the annual volume of CCBs that will be received, CCB analytical results, proposed operational procedures, hydrogeologic information, and a groundwater monitoring plan.

Virginia: Under Virginia regulations, fly ash, bottom ash, slag and flue gas emission control waste generated primarily from the combustion of coal or other fossil fuels are exempt from regulation as hazardous waste.

Under Virginia regulations, CCBs are exempt from regulation as a solid waste if beneficially reused in the following manner and managed in accordance with all applicable state agency requirements:

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· For mine reclamation or mine refuse disposal on a mine site permitted by the Virginia Department of Mines, Minerals and Energy when used in accordance with the standards developed by the Department of Waste Management; · For soil nutrient additive, stabilization agent, structural improvement or other agricultural purposes under the authority of the Virginia Department of Agriculture and Consumer Services; · As a traction control material or road surface material if the use is consistent with Virginia Department of Transportation specifications (bottom ash or boiler slag); · As a base, subbase or fill material under a paved road, the footprint of a structure, a paved parking lot, sidewalk, walkway or similar structure; · When processed with a cementitious binder to produce a stabilized structural fill product which is spread and compacted with proper equipment for the construction of a project with a specified end use; and · For the extraction or recovery of materials and compounds contained within the CCBs. (9 VAC 20-80-160.)

In 1995, Virginia promulgated a regulation specifying the terms and conditions under which CCBs may be reused through land application such as structural fills, mine reclamation or mine refuse disposal (in conjunction with Virginia Surface Mining regulations). The regulation allows for the use of CCBs in structural fills and mine reclamation projects. The regulation also provides for the siting of such projects, the design and construction of runoff and cover systems, the closure of projects, and establishes minimum operational requirements.

CCBs managed under these regulations are not subject to solid waste facility permitting, however, at least 30 days prior to initial placement of CCBs the facility owner must: · Submit certification that the owner has legal control over the proposed site for the project life and closure period, that the location and operation of the site will be in compliance with all local ordinances, and that the owner will allow Department inspections to ensure compliance with applicable regulations; · Provide a description of the intended use, reuse, or reclamation of the CCBs including a description of the site, the estimated beginning and ending dates of the operation, an estimate of the volume of CCBs to be used, and the physical and chemical characteristics of the CCBs including TCLP analyses for specified characteristics; · Certification by a professional engineer that locational restrictions have been satisfied and that the project has been designed in accordance with specified standards; and · An operational and closure plan. Various location restrictions apply. For example, CCBs may not be placed: · In areas subject to base floods unless it can be shown that the CCBs can be protected from inundation or washout and that the flow of water us not restricted; · With the vertical separation between the CCB and the maximum seasonable water table or bedrock less than two feet; · Closer than 100 feet from any perennial stream, water well, sinkhole or 25 feet from a bedrock outcrop (unless the outcrop is treated to minimize infiltration into fractured zones) or property boundaries;

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· In wetlands, unless applicable federal, state and local permits are obtained; or · At the site of an active or inactive dump, unpermitted landfill, lagoon or similar facility, even if closed. In addition, storage and stockpiling of materials must meet specified regulatory requirements. 9 VAC 20-84.

West Virginia: West Virginia regulations adopt by reference the federal regulation which exempts CCBs from classification as hazardous waste. Exempt from hazardous waste regulation are fly ash, bottom ash, slag and flue gas emission control waste generated primarily from the combustion of coal.

Under West Virginia regulations, CCBs may be reused in the following manner: · As a material in manufacturing another product (e.g. concrete, flowable fill, lightweight aggregate, concrete block, roofing materials, plastics, paint) or as a substitute for a product or natural resource (e.g. blasting grit, filter cloth precoat for sludge dewatering); · For the extraction or recovery of materials and compounds contained within the CCBs; · As a stabilization/solidification agent for other wastes if used singly or in combination with other additives or agents to stabilize or solidify another waste product. Advance written notice must be submitted to the state and the use must result in altered physical or chemical characteristics of the other waste and a reduction of the potential for the resulting established mixture to leach constituents into the environment; · Under the authority of the West Virginia Department of Energy; · As pipe bedding or as a composite liner drainage layer; · As an anti-skid material (bottom ash, boiler slag) if such use is consistent with Department of Highways specifications. The use of fly ash as an anti-skid material is not deemed to be a beneficial use; · As a daily or intermediate cover for certain solid waste facilities if the permit allows for such use; and · As a construction base for roads or parking lots that have asphalt or concrete wearing surfaces, if approved by the West Virginia Department of Highways and the project owner. (W.VA.REGS. §33-1-5.5.2.d.)

West Virginia regulations note that beneficial reuse of CCBs for structural fills and as soil amendment will be addressed in future rule makings.

Pennsylvania: Under Pennsylvania regulations, fly ash, bottom ash, slag and flue ash gas emission control waste generated primarily from the combustion of coal or other fossil fuels are exempt from regulation as hazardous waste (25 Pa. Code §261.4). Coal ash is regulated under the Solid Waste Management Act and the residual waste management regulations. In December 1986, this act was amended to authorize the beneficial use of coal ash. Beneficial use of coal ash was implemented through Department of Environmental Protection ("DEP") guidelines under the residual waste management regulations, 25 Pa. Code Chapter 287, which were amended in July 1992 to include the beneficial use of coal ash, 25 Pa. Code §§287.661-287.666. On January 25, 1997, the beneficial use of coal ash regulations, 25 Pa. Code §§287.663 and 287.664 were

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amended to change the requirements concerning groundwater monitoring, reporting to the Department, coal ash beneficial uses, and the amounts of coal ash that could be used at active coal mine and abandoned mine sites.

Coal ash is defined in Pennsylvania's Solid Waste Management Act as fly ash, bottom ash or boiler slag resulting from the combustion of coal and may be beneficially used. Other coal ash that is not beneficially used is a "residual waste."

Pennsylvania residual waste management regulations provided that coal ash may be beneficially used. Other coal ash that is not beneficially used is a "residual waste." Pennsylvania residual waste management regulations provided that coal ash may be beneficially used: · As a structural fill upon approval from the Department if the person proposing the use complies with specified requirements. (Any other use as a structural fill requires a disposal permit.); · As a soil substitute or soil additive if the person proposing the use complies with specified requirements; · For reclamation at an active surface coal mine site, a coal refuse reprocessing site, or a coal refuse disposal site if the use complies with all specified requirements under 25 Pa. Code §287.663, the Clean Streams Law and regulations promulgated thereunder, the Surface Mining Conservation and Reclamation act (52 P.S. §§1396.1-1396.19a), the Coal Refuse Disposal Control Act (52 P.S. §§30.51-30.66), and the applicable provisions of Chapters 86-90; · For reclamation at an abandoned coal or an abandoned non-coal (industrial mineral) mine site if the reclamation work is approved by the Department or is performed under a contract with the Department and the use complies with 25 Pa. Code §287.664, and the applicable environmental statutes and regulations promulgated thereunder; · In the manufacture of concrete; · For the extraction or recovery of one or more materials and compounds contained within the coal ash; · As an anti-skid material or road surface preparation material, if the use is consistent with Department of Transportation specifications or other applicable specifications. (This use applies to bottom ash or boiler slag only. The use of fly ash as an anti-skid material or road surface preparation material is not deemed to be a beneficial use.); · As a raw material for a product with commercial value, including the use of bottom ash in construction aggregate. (Storage of coal ash prior to processing s subject to specific requirements.); · For mine subsidence control, mine fire control and mine sealing, if the person or municipality proposing the use gives advance written notice to the Department, the pH of the coal ash is in a range that will not cause or allow the ash to contribute to water pollution, and use of the coal ash in projects funded by or through the Department is consistent with applicable Department requirements; · As a drainage material or pipe bedding, if the person or municipality proposing the use has first given advance written notice to the Department, and has provided to the

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Department an evaluation of the pH of the coal ash and a chemical analysis of the coal ash that meets the specific chemical waste analysis requirements; and · As a stabilized product where the physical or chemical characteristics are altered prior to use or during placement if the person or municipality proposing the use has first given advance written notice to the Department, the coal ash is not mixed with solid waste, unless otherwise approved in writing by the Department prior to use, and the use of coal ash results in demonstrated reduction of the potential of the coal ash to leach constituents into the environment.

Michigan: Under Michigan regulations, fly ash, bottom ash, slag and flue gas emission control waste generated primarily from the combustion of coal or other fossil fuels are exempt from regulation as hazardous waste. MICH.ADMIN.CODE 299.9204. These materials are, however, considered low hazard industrial wastes. MICH.ADMIN.CODE 299.4103; 299.4122.

Under Michigan law, fly ash or other ashes produced from the combustion of coal are not considered solid waste and may be reused: · With a maximum of 6% of unburned carbon as a component of concrete, grout, mortar, or casting molds; · With a maximum of 12% unburned carbon passing Michigan Department of Transportation test method MTM 101 when used as a raw material in asphalt for road construction; · As aggregate, road, or building material which in ultimate use will be stabilized or bonded by cement, lime, or asphalt; · As a road base or construction fill which is covered with asphalt, concrete, or other material approved by the Michigan Department of Environmental Quality ("DEQ") and which is placed at least four feet above the seasonal groundwater table; and · As the sole material in a depository designed to reclaim, develop, or otherwise enhance land, subject to the approval of the DEQ. (See Rule 99.4113 - 299.4119 for conditions regarding approval for land reclamation). (MICH. COMP. LAWS ANN. §324.11506(1)(k).)

Under Michigan regulations, coal ash may be used to reclaim, develop, or enhance land following submission of a plan and approval of the plan by the DEQ. The plan submitted to the DEQ must describe how the proposed use will reclaim, develop, or enhance the land and must demonstrate compliance with other requirements (see rule 299.4113-4119).

For example, the plan must demonstrate the ash is inert (rules 299.4114-4117 specify the criteria or the waste must satisfy to be classified as inert), that the site conditions are sufficient to prevent the migration of ash constituents, or that the plan is otherwise protective of human health and the environment. A plan proposing to use ash designated as inert (see rule 299.4116-4118 for the requirements to obtain an "inert" designation) must include information demonstrating the ash is inert, that the ash will not adversely affect human health or the environmental from all exposure routes other than groundwater, topographic maps, a closure plan, documentation of landowner authorization, post-closure restrictions and other information specified in the regulations.

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A plan proposing to use ash which does not meet the inert designation criteria must include the same information, as well as engineering plans prepared by a registered professional engineer, and a hydrogeological report which verifies the presence of a natural soil barrier which will ensure that hazardous substances will be attenuated before reaching the saturated zone or which demonstrates the water quality performance standards of rule 299.4306 will be met. (MICH. ADMIN. CODE 299.4113.)

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(Source: American Coal Ash Association, 1998)

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(Source: American Coal Ash Association, 1998)

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(Source: American Coal Ash Association, 1998)

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APPENDIX H

USDOE’s 1994 REPORT TO CONGRESS – EXECUTIVE SUMMARY

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APPENDIX I

OSU EXTENSION FACT SHEET AEX-332-99

(http://ohioline.ag.ohio-state.edu/aex-fact/0332.html)

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APPENDIX J

LIST OF LOCAL AND MATERIAL SPECIFIC EXCHANGE PROGRAMS IN OHIO

Source: Ohio’s Materials Exchange (OMEx)

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APPENDIX K

REPORT REVIEW PROCESS

A draft of the report was sent in August, 1999 for review comments to the following agencies, organizations, and personnel: · American Coal Ash Association · American Coal Ash Association – Ohio Chapter · American Electric Power · Cinergy · Dravo Lime Company (now Carmeuse NA) · Federal Energy Technology Center (now National Energy Technology Laboratory) · FirstEnergy · Ohio Cattlemen’s Association · Ohio Coal Development Office · Ohio Dairy Farmers Federation · Ohio Department of Agriculture · Ohio Department of Natural Resources – Division of Mines and Reclamation · Ohio Department of Transportation · Ohio Environmental Protection Agency · Ohio Farm Bureau · The Ohio State University · The Ohio State University Extension · Dr. Jack Cline Written comments on the draft report and additional information were received from the following: · American Coal Ash Association · American Coal Ash Association – Ohio Chapter · American Electric Power · Cinergy · Dravo Lime Company (now Carmeuse NA) · Federal Energy Technology Center (now National Energy Technology Laboratory) · FirstEnergy · Ohio Coal Development Office · Ohio Department of Natural Resources – Division of Mines and Reclamation · Ohio Environmental Protection Agency · The Ohio State University · The Ohio State University Extension · Dr. Jack Cline The comments received from the report reviewers were given strong consideration by the authors. All the comments were carefully reviewed and incorporated into the final report to the extent possible. A copy of the comment letter received from Mr. Christopher Jones, Director, Ohio Environmental Protection Agency is appended below.

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APPENDIX L

USEPA PRESS RELEASE DATED APRIL 25, 2000

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