Abstract
Coal combustion residues (CCRs) are presently regulated as solid waste (Subtitle D) under the Resource Conservation Recovery Act. Such classification promotes beneficial use by end-users i.e. mitigating excessive liability. According to the US Environmental Protection agency (USEPA), about 131million tons of coal combustion residuals—including 71million tons of fly ash, 20million tons of bottom ash and boiler slag, and 40million tons of flue gas desulfurization (FGD) material—were generated in the US in 2007. Of this, approximately 36% was disposed of in landfills, 21% was disposed of in surface impoundments, 38% was beneficially reused, and 5% was used as minefill. Stringent regulation, as Subtitle C (hazardous waste), would impose a perceived liability upon end-users; greatly reducing beneficial use opportunities. Mandatory use of synthetic liners—would not have prevented dike wall failure and fails to consider inherent engineering characteristics of CCRs.
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