GMA speaks up during EPA coal ash hearing
GeosyntheticsMagazine.com | September 1, 2010
As hearings continued through September 2010, the U.S. Environmental Protection Agency (EPA) seeks comments regarding the regulation of coal ash containment sites. The Geosynthetic Materials Association (GMA) was among the first in line to address the issue Aug. 30 at the initial hearing in Arlington, Va.
The major issue in the proposed EPA regulations concerns how coal ash should be classified—as solid waste just as household garbage is regulated or as hazardous waste.
GMA has long maintained a position that coal combustion residuals (CCRs) could be safely contained as solid waste and that a designation as hazardous waste would be overkill. However, regardless of the designation the EPA makes, it is clear that through advocacy efforts by GMA and others, the use of liners will be required in the disposal of coal ash waste.
GMA’s comments regarding the coal ash disposal regulations were prepared for the EPA’s seven public hearings around the country in August and September. The EPA’s hearings were scheduled in Arlington, Va., Denver, Dallas, Charlotte, Chicago, Pittsburgh, and Louisville. In addition to the Aug. 30 Arlington hearing, GMA members planned comments at public hearings in Denver on Sept. 2, Dallas Sept. 8, Charlotte Sept. 14, Chicago Sept. 16, Pittsburgh Sept. 21, and Louisville on Sept. 28.
In addition, GMA has posted several written comments on this issue. (The complete set of GMA’s comments can be found at: http://geosyntheticsmagazine.com/news/gmaupdate)
In addition to the public hearings and written comments, GMA bolsters support for geosynthetic lining of coal ash sites during Capitol Hill meetings with U.S. House and Senate staffs during GMA’s Lobby Day activities Sept. 15.
Following are the comments made by GMA members during the Aug. 30 EPA hearing in Arlington, just outside Washington, D.C.:
Today I am representing the Geosynthetic Materials Association, the trade group of 80 companies that manufacture, distribute and install geosynthetic materials, including liners systems. The industry employs 12,000 people throughout the United States.
Our comment to EPA is very simple. We request that EPA mandate the geosynthetic lining of coal ash storage facilities using composite lining systems. In the shortest terms, use liners, specifically composite liners.
Why? Because liners work. Concerns of safety regarding CCRs are mitigated if the landfill storage sites are lined with a composite liner system of a geomembrane and a geosynthetic clay liner. A composite liner system prevents the leachate from entering the environment. Safety concerns regarding surface impoundments are also mitigated if the impoundments are lined with a composite liner system.
The American Society of Civil Engineers does a regular “Report Card on America’s Infrastructure.”For the last three report cards, representing over a decade, solid waste has received the highest grade of any category. My industry does a good job of taking America’s waste and properly storing it to protect the environment. The materials, technology and people exist [now]—the engineers, engineering techniques and standards, the general contractors and installers who can build the proper facilities and the regulators and inspectors who assure the work is done correctly. We urge EPA to “use what exists and is working today.”
Further, our industry has continuously improved over time and EPA has been a part of that effort. Over the years, EPA has commissioned nearly 80 studies of the design and performance of lining systems. We specifically call your attention to a 2002 study titled “Assessment and Recommendations for Optimal Performance of Waste Containment Systems” (EPA 600/R-02/099). That study contains a great deal of pertinent information on how to construct containment systems. Most illustrative for today is a graph charting the leakage rate of different designs over the life cycle of nearly 200 facilities. The composite liner system of a geomembrane and a geosynthetic clay liner was demonstrated to have the lowest leakage rate over all life cycle stages, including a near zero leakage rate after the facilities are closed and final cover placed. Our materials work.
Use of composite liner systems will achieve the EPA mission to protect human health and the environment for all Americans.
A brief word on the hazardous/non-hazardous question. While coal ash does contain heavy metals, it lacks the traditional characteristics of hazardous materials, radioactivity or the presence of infectious medical waste, etc. In the opinion of our trade organization, coal ash can be properly stored using subtitle “D” regulations, a non-hazardous solid waste designation with composite liner systems.
Thank you.
Chart courtesy of the Geosynthetic Research Institute (GRI) at Drexel University.
Waste disposal sites in the U.S.—199 total—with a variety of designs and materials were examined. The survey population included sites at different phases of the site lifespan as indicated on the “X” axis. The site leakage (collection) rate was plotted on the “Y” axis for the three types of liner design: yellow–geomembrane alone, green–geomembrane and compacted clay, red–a geomembrane and GCL (geosynthetic clay liner) composite liner system.
The key point is the optimal performance of the composite liner system(s), including a near zero leakage rate for the closed (“After Final Cover”) site.
Data Source: Bonaparte, Daniel, and Koerner. (2002) “Assessment and Recommendations for Optimal Performance of Waste Containment Systems,” EPA/600/R-02/099. U. S. EPA, ORD, Cincinnati, OH
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Comments are the opinion of individual posters and do not reflect the views of Geosynthetics or Industrial Fabrics Association International.
1:19 pm CDT
What about selenium and coal ash
Your cited data source does not measure selenium in the leachate from the coal ash disposal site, or any other for that matter. It does state that the leachate rate is 300-600% greater for the coal ash site than other waste types, which suggests that post-closure data is critical to evaluate the performance of what you are proposing in the context of EPA's new rule, i.e., that composite liners will protect people and the environment. Yet, you have no post-closure data for the coal waste site. How can you accurately project performance for your liner system in a coal-ash application when you (1) have no post-closure data and (2) you have no selenium measurements at all? Understand that I am a proponent of liners……they are a step in the right direction. But what you have presented is not convincing or conclusive with respect to coal ash and selenium. I hope you have more substantial data that will be forthcoming soon.
Dennis Lemly
10:54 am CDT
Re: What about selenium and coal ash
Editor's note: We received the following response to the comment above:
The performance of liner systems is typically not—in fact, almost never—evaluated against specific agents (i.e., selenium).
The interaction of geosynthetic liner materials to an extremely wide range of chemicals is well-known and understood. There is one general class of chemical (very low molecular weight halogenated hydrocarbons) where there are measurable interaction differences between the chemical and the geosynthetic material, depending on the specific nature of the chemical.
For all other general classifications of chemical interactions, the performances of the geosynthetics are relatively uniform. Thus, testing is not done for a specific chemical.
In fact, it is thought that mixtures of a wide range of chemical components present a more difficult performance standard for geosynthetic barriers. That is why, during the early use of geosynthetics, a large number of tests were conducted using leachate from waste containment facilities, which contained a broad range of chemical constituents.
These tests, identified under the name EPA 9090, have successfully demonstrated the inertness to a broad range of chemicals that has allowed geosynthetic materials such as high-density polyethylene to contain materials effectively for decades.
–Boyd Ramsey, GSE Lining Technologies
9:14 am CDT
What about selenium and coal ash
Boyd, thanks for your reply. I am not concerned about selenium interacting with the membrane and degrading it, which is what EPA 9090 examines (compatibility). I want to know if there are permeability issues for the oxyanion and organic forms of selenium (selenate, selenite, selenomethionine, hydrogen selenide, etc.). Specifically, are there (1) laboratory studies showing that permeation or co-transport of selenium and water do not occur in the long-term (months-years) when the membrane is exposed to whole-ash leachate, and (2) field monitoring studies to confirm that none of these forms is passing through and getting into groundwater or surface water at concentrations of concern to fish and wildlife health (>1 ug/L) during the operational life of a lined coal ash landfill or surface impoundment, and 1, 5, 10 etc. years after closure. It would also be very useful to know the volume of leachate that is contained by the liner during the same period, as well as its Se concentration. The 1984 EPA 9090 tests and many others since then were conducted with industrial or municipal waste leachate that contained <5 ug/L Se.....coal ash leachate can have >20,000. Unless there are lab and field performance studies available which show satisfactory results, it is, at best, misleading for a GMA spokesperson to appear at an EPA hearing on coal ash disposal and contend that "our liners work" with respect to selenium pollution. You can't credibly say they work if you can't demonstrate that they work. This demonstration has apparently not been done for selenium. I hope your last statement, i.e., that geosynthetic materials have effectively contained materials for decades, will prove true for selenium and coal ash, but I see no current evidence or proof of this in the trade, scientific, or regulatory literature. Are there others within your industry that have additional information that would be useful in answering my questions??
Dennis Lemly
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