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Document Record Detail



Full Document:
Title:REGULATORY STATUS OF MATERIALS BEING USED IN SPECIFIC RECIRCULATION/REINJECTION PROCESSES AND CARBON BURN-OUT (CBO) UNITS
RCRA Online Number:14822
Date:07/21/2011
To:Faggert
From:Rudzinski
Organization of Recipient:Dominion Resources Services
Description: The NHSM rule identifies which NHSM are, or are not, solid wastes when used as a fuel or an ingredient in combustion units. The NHSM also identifies certain materials as traditional fuels. The threshold question in evaluating the ash recirculation reinjection process is whether the ash material is the continual processing (for energy recovery) of coal or whether the ash material being re-circulated/re-injected is a secondary material. Secondary material is defined as “material that is not the primary product of a manufacturing or commercial process, and can include post-consumer material, off-specification commercial chemical products or manufacturing chemical intermediates, post-industrial material, and scrap.” Recirculating or reinjecting coal containing ash material is an extension of the electricity producing operations, similar to stoker units and would not be considered a secondary material until the material exits the process or is otherwise discarded. As these specific processes do not involve combustion of a solid waste, they would be subject to the section 112 Clean Air Act (CAA) standards. The Agency cannot make a categorical determination whether carbon is being destroyed or being used for its fuel value, but high carbon fly ash may have more than marginal energy value and can be a source of additional power. It is appropriate for these units to consider the legitimacy criteria in making discard determinations. The threshold question is whether the high-carbon ash material used in the CBO unit is the continual processing (for energy recovery) of coal or whether the ash material fed into the CBO unit is a secondary material.
Regulatory Citation(s) : 241.2, 279.11 EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Waste Determinations for Combusted Non-Hazardous Secondary Materials
Approximate Number of Hardcopy Pages:5
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:Yes

 

 
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