Big Yellow Taxi?“…you don’t know what you got ‘til it’s gone”

2015 Chestnut Street, Camp Hill, PA 17011Phone: (717) 763-7635, Fax: (717) 763-7455

2015 Pennsylvania Abandoned Mine Reclamation (AMR) ConferenceJune 25, 2015

Presented by:Dennis Simmers, A/C Power, Colver Power Project

Who is ARIPPA?• ARIPPA is the trade association for a very special industry

that remediates and reclaims coal refuse sites from historic mining activities by removing the refuse and turning it into environmentally beneficial electricity

• The electricity produced by this industry is recognized in PA Act 129 of 2008 as an alternative energy source

• ARIPPA member facilities provide solutions to serious land, water and air pollution problems, as well as health and safety issues, by removing, remediating (including physical and chemical processes) and reclaiming coal refuse piles

• 1/1/89 – 12/31/13 over 200 million tons of Pennsylvania coal refuse removed and thousands of acres remediated and reclaimed

What is the Process?• Coal refuse removed from site

• Combusted with limestone in FBC

• Beneficial use ash returned to site

• Remaining material neutralized and stabilized using beneficial use ash

• Water runoff managed

• Future surface and groundwater pollution eliminated

• Future air pollution eliminated by eliminating fire potential

Plants, Problems and Drainage Basins

To Be Remediated and Reclaimed?

Unreclaimed Coal Refuse Site Burning Coal Refuse Site

To Be Remediated and Reclaimed?

Unreclaimed Coal Refuse SiteMine Drainage from a Coal Refuse Site

How much coal refuse is out there?

• No one really knows…Estimated 2 billion cubic yards split between anthracite and bituminous regions

• Not all coal refuse is useable as a fuel

• Three classes of refuse sites

• Abandoned mine land inventory (pre-1977 Sites)

• Bond forfeiture site (Post 1977- to present)

• Active sites

• The older the coal refuse site, the higher the probability that the coal refuse can be used as fuel

Reclamation through AML Program

• Pre-1977 Sites

• Must meet Priority 1 or 2 Category

• Includes hydrologic controls, re-grading, compaction, covering and vegetating

• Addressing discharges of pollution may occur

• Reclaimed sites still have potential to cause water and air pollution

PADEP Reclamation Costs

• PA experience - $40,000 - $100,000 per acre

• Typically limited to a limited scope physical reclamation and doesn’t always include pollution controls

• Project costs are site specific • volume of material per acre,

• the location of the site,

• availability of topsoil,

• stability of the material, and

• the proximity to streams, etc.

Physical Reclamation Shortcomings

• The project scope does not address the treatment of Acid Mine Drainage (AMD)

• The project scope does not eliminate the threat of future fires

• The reclaimed site does not allow for future land use

• To reclaim these sites requires more than just planting beach grass

• The sites need plans developed to address

• water pollution problems,

• proper grading and controls and

• the proper use of vegetative sustaining cover using indigenous vegetation

Physical Reclamation Shortcomings cont.

Reclamation and Remediation Through Coal Refuse Fired EGUs

Remediation and Reclamation By Coal Refuse-fired Electric Generations

Coal refuse burned with limestone in FBC

Beneficial Use of FBC Ash a Key • The FBC beneficial use ash results from the combustion

of coal refuse with limestone injection

• The FBC beneficial use ash is an integral part of the coal refuse/mine site abatement/remediation and reclamation plan

• The FBC beneficial use ash neutralizes any remaining acidic materials that remain on site

• The FBC beneficial use ash’s chemical and physical properties make this process the most economical and complete form of remediation and reclamation

Beneficial Use Ash Requirements

• Meet Title 25 Chapter 290 requirements

• Certified Semi-annually by the Department

• Tested quarterly

Beneficial Use Ash Requirements cont.

Tests include:• Leachate

• pH must be 7.0 or above

• Alkaline additive

• Low permeability material

Note: The Department may approve the addition of lime or cement to FBC ash to achieve the requirements for beneficial use

Remediation and Reclamation cont.

Design Considerations:

• Water pollution from run-off and acid mine

drainage discharges

• Site stabilization including re-grading

• Covering with vegetative supporting material

• Planting with vegetation to support the final land

use

Remediation and Reclamation cont.

Engineering design:

• Abatement Plan

• Mining Plan

• Reclamation Plan

Plans Through the Permitting Process Include

• Installation of hydrologic controls

• Utilization of FBC beneficial use ash in the

reclamation

• Grading and compacting

• Covering with 1 - 4 feet of soil

• Adjusting the soil pH

• Addition of fertilizers

• Vegetate consistent with the local flora

What is NOT Remediation and Reclamation!

• JUST PLANTING BEACH GRASS

• To remediate and reclaim these sites properly you need to include both Physical and Chemical Processes to insure the considerations above are addressed

Two Case StudiesRevloc – Ebensburg Power Company

• 4,120,000 tons of coal refuse and approximately 53 acres of land

• Discharges:

• Acidity reduced by 93%

• Iron reduced by 92%

• Manganese reduced by 71%

• Aluminum reduced by 95%

• Approximately six miles of the South Branch of the BlacklickCreek has returned to a quality which supports aquatic life

Revloc

BEFORE AFTER

Two Case Studies cont.

Maple Coal Company – Colver Power Plant• Approximately 3.5 million tons of coal refuse used as fuel

• Discharge to Elk Creek:

• Acidity reduced by 99.9%

• Iron reduced by 97.6%

• Manganese reduced by 99.2%

• Aluminum reduced by 99.9%

Maple Coal

BEFORE AFTER

Future Water and Air Pollution Gone

Acid Mine Drainage Coal Refuse Fire

With Remediation and Reclamation

Additional Benefits:

• Eliminate future fires

• Eliminates toxic air pollutants

• Eliminate greenhouse gases

• Improves water quality

• Virtually eliminates stream loadings of acid, metals, heavy metals and silt

• Virtually eliminates the pollution of groundwater

• Vegetation

• Eliminates a “heat sink”

• Sequesters CO2

• Virtually eliminates fugitive dust

FBC Emissions Profile

• SO2 – 90% to 95% capture

• Filterable PM – 98% to 99 % capture

• NOx – 0.15 lb to 0.3 lb NO2/MMBtu

• Hg – 99+% capture, part of MACT floor

• Other air toxics – meet MATS limits, except HCl but we’ll discuss

Coal Refuse-fired Units

The premier solution to the environmental, health and

safety issues associated with coal refuse!

Regulatory Issues Affecting Coal Refuse-fired EGUs

• Cross-State Air Pollution Rule

• Mercury and Air Toxics Standards

• Clean Power Plan• RGGI

• Waters of the US

• Coal Combustion Residuals

• PA Reasonably Available Control Technology (RACT)

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

• Cross-State Air Pollution Rule (CSAPR)

• Mercury and Air Toxics Standards (MATS)

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

CSAPR• CSAPR is a market-based rule developed by EPA to

address the transport of precursors of fine particulate matter (PM2.5) and ozone

• Allocates SO2 and NOx allowances to electric generating units (EGUs) in two Phases

• Phase 1 is effective January 1, 2015 and Phase2 January 1, 2017

• EGUs must surrender allowances to account for the emissions from the affected units

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

CSAPR• EPA didn’t consider the specificity of the FBC design

• EPA didn’t adequately consider the high and variable sulfur content of bituminous coal refuse

• EPA didn’t appropriately consider the technologies

• EPA didn’t consider the high cost, $ per ton, to control sulfur dioxide with post-combustion controls on an FBC

• PA coal refuse-fired EGUs are electric wholesale generators not rate-based utilities competing to sell power

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

CSAPR• Phase 2 SO2 allocation is too low to bituminous coal refuse-fired

EGUs

• If all of the affected units cannot operate below their allocation then a seller’s market likely develops

• Limited trading and significant costs if the state budget exceeded and your EGU exceeds its annual allocation

• The purchase price of allowances must be added to the bid price

• The price of electricity from certain coal refuse-fired EGUs becomes uncompetitive and they’re retired

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

MATS• Establishes maximum achievable control technology

(MACT) standards for hazardous air pollutants (HAPs)

• Establishes MACT for a variety of HAPS including mercury, non-mercury hazardous metals and acid gases

• Coal refuse-fired EGUs used to establish mercury MACT

• Coal refuse-fired EGUs used to establish filterable particulate matter (FPM) surrogate standard for non-mercury metals (NMM)

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

MATS• Coal refuse-fired EGUs , except one, can’t meet HCl

limit

• No bituminous coal refuse-fired EGU can meet the alternative SO2 acid gas limit of 0.2 lb SO2/MMBtu

• EPA did not consider the unique characteristics and variability of bituminous coal refuse in developing an acid gas surrogate limit

• In the NSPS EPA recognized coal refuse variability and provided both a limit and a performance standard

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

MATS - HCl or SO2 Surrogate• HCl emission rate is problematic for Coal Refuse Fired EGUs

• Sulfur content is the issue and fuel switching is not available

• DSI resulted in exceedance of MATS Hg limit

• DSI resulted in FBC ash not meeting beneficial use criteria

• The SO2 surrogate limit cannot be met by EGUs combusting refuse from bituminous coal

• A 98+% reduction of potential SO2 emissions would be required

Regulatory Issues Affecting Coal Refuse-fired EGUs cont.

MATS

• Operating under Clean Air Act extension provisions

• Testing to determine if more reduction can be achieved

• DSI makes the ash unable to be certified for beneficial use

• Without a solution or alternative performance standard surrogate limit, the bituminous coal refuse fired EGUs will be retired as the costs to comply do not allow them to compete in the market place

ARIPPA Facilities Need Your Help

ARIPPA needs your help to keep coal refuse-fired EGUs doing their good work and achieving the results that are so important to areas impacted by coal refuse. These results include multi-media environmental benefits as well as achieving these reclamations and remediation projects. For this to occur, we are asking for your assistance in addressing technical and other errors in the regulatory process in a fashion that would result in reasonable and appropriate costs and burdens to these facilities that would ultimately allow the coal refuse-fired EGUs to continue to operate and compete in the electric energy market.

Your Help

Ways to Help

• Writing letters to your State Senator and Representative supporting the Coal Refuse-fired Facilities

• Writing letters to your US Senators and Members of Congress supporting the Coal Refuse-fired Facilities

• Providing comments to the State, USEPA and OSMRE regarding their proposal rule makings that support the Coal Refuse-fired Facilities

Questions?

2015 Chestnut Street, Camp Hill, PA 17011Phone: (717) 763-7635, Fax: (717) 763-7455

www.arippa.org