Languishing 2009-13 coal ash recycling rates reflect regulatory uncertainty

Sources: American Coal Ash Association (ACAA), Farmington Hills, Mich.; CP staff

According to ACAA’s “Production and Use Survey,” 51.4 million tons of coal combustion products (CCP) were beneficially used in 2013 —down from 51.9 million tons in 2012 and well below the 2008 peak of 60.6 million tons. In the closely watched category of fly ash consumed in concrete mixes, utilization increased only slightly to 12.3 million tons, up by 577,705 tons over 2012, but still below 12.6 million tons in 2008.

The decline occurred as the U.S. Environmental Protection Agency proposed coal ash management regulations that could have designated the material as “hazardous waste” when disposed. A final rule issued in late December averts that label and acknowledges the large volume of recycling embodied in ASTM C618-grade fly ash marketing and related concrete specifications.

Prior to the final rule, ACAA observed growing numbers of ash producers, specifiers and customers restricting coal ash use in light of the regulatory uncertainty and publicity surrounding EPA rulemaking activities. “Regulatory certainty is imperative if we are to increase volumes of coal ash that are beneficially used rather than disposed,” Executive Director Thomas Adams noted upon release of the 2013 Production and Use Survey results. “People don’t just wake up one day and decide to recycle more. It takes planning and investment that are difficult to justify in an environment of regulatory uncertainty and misleading publicity about the safety of coal ash.”

The decline in 2009-13 recycling volumes stands in stark contrast to the previous decade’s trend, he adds: “In 2000, when the recycling volume was 32.1 million tons, the EPA issued its Final Regulatory Determination that regulation of ash as a ‘hazardous waste’ was not warranted. Over the next eight years, EPA also began actively promoting the beneficial use of coal ash and the recycling volume soared to 60.6 million tons.

“The fact is that coal ash disposal costs did not change much between the 1990s and 2000s. What caused the dramatic growth of recycling in the 2000s was regulatory certainty that encouraged people to invest in recycling rather than disposal, and a supportive EPA that actively encouraged recycling.”

Analysis of historic production and use data reaffirms that the recent decline in coal ash recycling is largely attributable to regulatory uncertainty and not general economic trends. During five recessionary periods since 1973, fly ash utilization out-performed overall concrete production in all but the most recent economic downturn. The current fly ash market continues to be depressed, even as ready mixed concrete volumes began to increase as early as 2010. “In previous economic downturns, we actually saw fly ash utilization increase as concrete producers sought less expensive materials in an effort to reduce costs,” Adams concludes. “That did not happen in our most recent economic downturn as regulatory uncertainty trumped economic incentives.”