Although products of coal combustion (PCCs) such as coal ash are currently exempted from classification as a hazardous waste in the United States under the 1976 Resource Conservation and Recovery Act (RCRA), the U.S. Environmental Protection Agency (EPA) is now revising a proposed rule to modify disposal practices for these materials in order to prevent contamination of ground- and surface water sources by leached trace elements. This paper analyzes several aspects of EPA’s scientific reasoning for instating the rule, with the intent of answering the following questions: 1) Are EPA’s cited values for PCC production and disposal accurate estimates of annual totals?; 2) In what ways can EPA’s leaching risk modeling assessment be improved?; 3) What is the total quantity of trace elements contained within all PCCs disposed annually?; and 4) What would be the potential costs and feasibility of reclassifying PCCs not under RCRA, but under existing NRC regulations as low-level radioactive waste (LLRW)? Among the results of my calculations, I found that although EPA estimates for annual PCC disposal are 20% larger than industry statistics, these latter values appear to be closer to reality. Second, EPA appears to have significantly underestimated historical PCC disposal: my projections indicate that EPA’s maximum estimate for the quantity of fly ash landfilled within the past 90 years was likely met by production in the last 30 years alone, if not less. Finally, my analysis indicates that while PCCs may potentially meet the criteria for reclassification as low-level radioactive waste by NRC, the cost of such regulation would be many times that of the EPA June proposed disposal rule ($220-302 billion for PCCs disposed in 2008 alone, versus $1.47 billion per year for the Subtitle C option and $236-587 million for Subtitle D regulatory options). / text

Coals, from mines in the Highveld coalfield, as well as gasification ash samples were characterised, in order to understand the mineralogical and chemical properties of the individual components in the gasification feedstocks. X-ray diffraction of low temperature oxygen-plasma ash indicates that the coals contain significant proportions of kaolinite, quartz and a fluxing elements-bearing mineral (dolomite), plus minor concentrations of illite and other fluxing elements-bearing minerals namely calcite, pyrite and siderite. Of the feed coal, the -75+53 mm size fraction has a high pyrite, and to a lesser extent a high calcite and dolomite content. However, the small proportion of iron-bearing phases (from the reaction between kaolinite and pyrite) in samples taken from the gasifier implies that pyrite contributes minimally to sintering or slagging in this case. Calcite is mainly present in the >1.8 g/cm3 density fraction of the feed coal, whereas dolomite is mainly present in the 1.5-1.8 g/cm3 density fraction, as inclusions or fine cleats in the coal matrix. Electron microprobe analyses of coals from the six different South African mines confirmed that some Ca, Mg, Al, Si, Na, K, Ti and Fe are present in the organic matrix in the coal samples tested in this study, but the amounts of these are small compared with the fluxing elements in minerals. XRD and microprobe analyses indicate that the ash clinker samples taken from the gasifiers contain a number of crystalline high temperature phases, including anorthite, mullite, cristobalite, quartz and diopside. FactSage confirmed that anorthite and mullite are equilibrium phases at elevated temperatures in the ash clinkers and heated rock fragments. Limited reaction takes place between the included coal minerals and the extraneous rock fragments. / Thesis (PhD)--University of Pretoria, 2008. / Materials Science and Metallurgical Engineering / unrestricted