Analysis - The Institute for Southern Studies

Beneficial uses of CCR have been consistently growing in the recent past. Since the percent of CCR beneficially used has been growing, EPA
sought to characterize that trend so that the future percent beneficially used could be applied to the future tons of CCR. The ACAA data from
2001 to 2008 indicate that this trend was increasing. After running several regressions, EPA disposed of the typical trend fits for various
reasons. A first-order (linear) trend line was abandoned because it would have led to beneficial use above 100% well within the time-frame of
the analysis. Higher order regressions led to oddities where beneficial use would trend away from 100% at some point in time. Once typical
fits were ruled out, EPA assumed that CCR beneficial use would not exceed 100% of CCR generated. 140 Instead, it would potentially become
more and more difficult to use CCR as a higher percent went to beneficial uses, because of market limitations. Thus, it made sense to use an
exponential curve that approached, but never crossed an asymptote of 100% beneficial use.
To fit an exponential curve to the 2001 to 2008 CCR beneficial use data, a spreadsheet calculation solver was programmed to minimize the
residual sum of squares between the actual and projected percent of CCR beneficial use by changing the regression equation variables B, C,
and D. From solver result, B was set to 1.021, C was set to 1.369, and D was set to 13.99. Using these values, the future CCR beneficial use
projection as measured on a percentage basis relative to CCR generation were estimated, as displayed in Exhibit 5C-11 and Exhibit 5C-12
below. The percentage of CCR beneficially used under the baseline (i.e., without RCRA regulation) is expected to gradually approach, but
never reach 100% of CCR generation. By 2061 at the end of the 50-year period-of-analysis, 88% of CCR would be beneficially used under this
projection. While this is a relatively high number, current experiences in at least one US state and in at least 16 other countries (i.e., 15
European countries + Japan), already demonstrate that very high CCR beneficial use rates of 90% and above are achievable:
1. Wisconsin: Several companies are developing technologies to convert CCR into bricks used in construction, and one such technology
was recently commercialized in Wisconsin. 141 Some of these technologies have the potential for using 100% CCR (fly ash) in brick
production, as opposed to the conventional 30%-50% limit for replacing Portland cement in concrete.
2. Europe: As of 2007, 15 European countries reported a CCR beneficial use rate of 89% (i.e., 55.449 million metric tons beneficially
used in 2007 in 24 industrial applications, out of the 62.094 million metric tons generated in 2007). 142
3. Japan: As of 2006, Japan reported a CCR beneficial use rate of 97% (i.e., 10.657 million tons used in Japan in 2006 for 3 cement
applications, 6 civil engineering applications, 3 construction applications, 2 agriculture/forestry/fisheries applications, and at least three
other miscellaneous applications, out of the 10.969 million tons CCR generated in Japan in 2006). 143
140 The fact that some electric utility plants currently excavate previously disposed CCR for supplying to beneficial use markets suggests this may be a limiting assumption
which could underestimate future potential growth of CCR beneficial use. For example, one electric utility company reported a 106% CCR beneficial use rate in 2006 for
its four electricity plants because it recovered CCR that it had previously disposed.
141 Source: “CalStar Gives Sneak Peek of Low-Carbon Brick Factory,” Cleantech Group, 27 Oct 2009 at http://cleantech.com/news/5217/calstar-flyash-low-carbon-brick
142 Source: Europe’s 2007 CCR beneficial use rate is reported by ECOBA (European Coal Combustion Products Association) which was founded in 1990 by European
energy producers to deal with matters related to the usage of construction raw materials from coal. As of 2009, membership in ECOBA consists of 24 companies and
associations from 15 countries in Europe, all generators of electricity and heat. ECOBA members represent over 86 % of total CCR generation by the 27 total European
countries. ECOBA’s 15 member countries are Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Netherlands, Poland, Portugal, Romania, Russia,
Spain, and United Kingdom. ECOBA’s 2007 CCR beneficial use rate is reported in “Production and Utilisation of CCPs in 2007 in Europe (EU 15)” at:
http://www.ecoba.com/evjm,media/statistics/ECOBA_Stat_2007_EU15.pdf
143 Source: Japan’s 2006 CCR beneficial use rate is reported by the Japan Coal Energy Center (JCOAL) in Table 3-1 of “Status of Coal Ash Production” at:
http://www.jcoal.or.jp/coaltech_en/coalash/ash01e.html
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