The electrical generating community is aware of the U.S. EPA-proposed first-time nationwide regulations for handling and disposal of coal ash residuals (CCRs) including fly ash, bottom ash, and flue gas desulfurization (FGD) byproducts. Option one (Subtitle C) makes CCRs subject to hazardous waste requirements under the Resource Conservation and Recovery Act (RCRA). Option two (Subtitle D) establishes stringent requirements under non-hazardous classification similar to municipal solid waste rules, also under RCRA. The industry is buzzing with speculation regarding the form of the final rule, timing, litigation and how to influence change. The critical question is “what is this going to cost?” Timely budget planning, decisions, and actions are necessary to prepare for minimum requirements common to both options, with sufficient flexibility to adapt should the more stringent classification be approved. In addition to new dry disposal requirements, existing wet ash and FGD handling systems may be phased out entirely, requiring conversion of equipment, addition of dewatering systems, and closure of ash ponds. Some states already have similar disposal requirements; others have no such regulations. Using the combined resources of detailed cost analysis for specific sites, adjustments from municipal and hazardous waste regulations and costs, trade and association summaries, existing regulations, local economic conditions, computer models, and 30 years of disposal records for other wastes help to develop high confidence level cost estimates. This paper presents an up-to-the moment rule status summary, key points of the CCR proposal and discusses optional engineering solutions available for compliance along with associated costs using the Total Cost Accounting approach. Potential impacts on beneficial uses (recycling) of CCRs are difficult to predict but must be factored into the financial decision making process. Click Here For Complete Speaker Text
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