SPECIAL WASTE MANAGEMENT FOR LANDFILLS AND MONTANA COMMUNITIES

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SPECIAL WASTE MANAGEMENT FOR LANDFILLS AND
MONTANA COMMUNITIES November 12 13, 2008
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INDUSTRIAL WASTESNONHAZARDOUS SUBTITLE D
REGULATORY INTRODUCTION

• Tim Stepp
• Solid Waste Program
• Waste Underground Tank Management Bureau

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EPA SPECIAL WASTE EXCLUSIONS

• EPA allows some industrial wastes to be
  temporarily managed for disposal under approved
  Montana Solid Waste authority
• Final EPA rulemaking based on process, volume,
  waste characterization stability (C2P2 Coal
  Combustion Products Partnership)
• TCLP leachate levels (acidic solvent) or separate
  extraction in alkaline leachate (As, Sb)
• Evaluation of risks based on several factors,
  including improved operational practices

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EPA SUBTITLE-D REGULATION

• New EPA OSW definition of solid waste allows
  certain sub-C exemptions for beneficial uses of
  special wastes
• Economic marketability or benefits of products
  (BUDs) determines level of regulation
• Coal combustion waste (CCW)
• EPA 2002 CCW finding 2007 NODA (new rules in
  process)
• Montana exclusion for on-site disposal at
  coal-fired power plants
• Cement kiln dust (CKD)
• EPA 1999-2002 NODA (new rules in draft)

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CCW CKD GENERATIONWASTE CHARACTERISTICS

• Fly ash byproduct forms during burning of finely
  pulverized coal (pc) in boiler
• Siliceous (Class F) to calcic (Class C) silt- to
  clay-sized, sorted glassy spherules resembling
  pumice
• Pozzolan-type reaction with lime (Class F) or
  simple hydration by water (Class C) triggers
  rapid set-up into cementitious block
• Bottom ash or slag (wet) byproduct forms at base
  during firing of pulverized coal furnaces
• Porous or glassy agglomerate of well-graded ash
  residues

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CCW CKD GENERATIONWASTE CHARACTERISTICS

• Flue Gas Desulfurization (FGD) byproduct from wet
  or dry scrubbers leading to stack
• Calcium-sulfate (gypsum) and -sulfite material
• Alkaline CKD byproduct generated in cement kilns
  during calcination for cement
• CCW CKD contain antimony, arsenic, barium,
  boron, beryllium, cadmium, chromium, lead,
  mercury, selenium, thalliumoften detected in
  groundwater via release at unlined facilities

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CCW CKD LANDFILLSMONTANA CLASS II LICENSE

• CCW ash and CKD clinker are defined under
  leachable Montana Group II waste
• Requirements exceed EPA recommendations for sub-D
  regulations in draft
• Program allows flexibility for alternative liners
  covers, and groundwater protection standards or
  monitoring waivers
• Location, design, operation, closure more
  similar to Class IV monofills (see CD)
• CCW and CKD can be easily stabilized during
  set-up like concrete upon disposal

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CCW CKD LANDFILLSCLASS-IV UNIT OPERATIONS

• Uniquely minimal infiltration due to exothermic
  set-up during on-site blending/watering of lifts
• Low leachate and methane production
• Less erosion control needed within unit
• Dust control on entry roads
• Walking-floor trailers for transport containment
• Cover side slopes as fill reaches ultimate grade
• Likely approval for alternative final cover

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CCW CKD BENEFICIAL USESSTABILIZED PRODUCTS
(CCP)

• Porous bottom ash provides CCP baseline
• Mine and subgrade fills structural embankments
• Road base high-wear pavements
• Raw material for concrete products
• Feed stock for cement production (kilns)
• Siliceous fly ash has additional uses
• Raw material for grout flowable fill products
• Ingredient for waste stabilization or soil
  additive
• FGD gypsum has same uses as fly ash
• Boiler slag grit used for sand blasting roofing

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CCW CKD BENEFICIAL USESSTABILIZED PRODUCTS
(CCP)

• Leachability of toxic metals can be stabilized
• Sulfates react with silica to set-up like
  concrete
• Used to stabilize other initially hazardous
  wastes
• Case-by-case Beneficial Use Demonstration (BUD)
  approval required for RRF license
• Deleterious ammonia can be removed from CCW
• Lot of research on CCW use in concrete, mine
  flowable fills, mortars, stuccos, and cement
• Wide possibilities for CCW as mineral fill in
  asphalt for durable road surfaces

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POTENTIAL BUD PROBLEMSCLEAN AIR ACT TITLE-V
HAPs

• Implementation of EPA 2005 CAMR requires
  reduction of mercury emissions to meet CAIR
  levels
• Causes potential increase in mercury captured by
  CCW byproducts
• May affect CCP quality potential for demos of
  beneficial utilization
• Impacts on soil, cement, concrete, grout, and
  fill applications unknown
• Possible ban on use as cement kiln feedstock

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CLASS II CCW Working face over MSW lift
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CLASS II CCW Erosion outer slope
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CLASS II CCW Rapid setup after watering
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CLASS II CCW Setup after water truck pass