nm3clol-public/Gentry_Locke/2024-06-14-Gentry_Locke_FOIA/Virginia Energy Study on Waste Coal Piles in SWVA 20240129/README.md

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title: Virginia Energy Study on Waste Coal Piles in SWVA 20240129
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  - 2024-06-14-Gentry_Locke_FOIA
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Virginia Department of Energy 
study on the economic and 
environmental impacts of 

eliminating waste coal piles in 
Southwest Virginia 

 

Report to the Governor and the General Assembly 

January 10, 2024 

 

 

Report Overview ........................................................................................................................ 2 
Background on Waste Coal........................................................................................................ 3 

What is Waste Coal ................................................................................................................ 3 
Environmental impacts ........................................................................................................... 3 
Background in Virginia – industry history, volume ................................................................... 6 
Relevant federal rules or programs ......................................................................................... 7 
Relevant state rules or programs ............................................................................................ 7 
Previous waste coal reports, inc. Inventory ............................................................................. 7 
AML program .......................................................................................................................... 8 
Pennsylvania .......................................................................................................................... 8 
Comparison of VA and PA Waste Coal Assets ....................................................................... 9 

Options for addressing waste coal ............................................................................................10 
No action ...............................................................................................................................10 
Encapsulation/remediation ....................................................................................................10 

Q Energy
Virginia Department of Energy
study on the economic and
environmental impacts of

eliminating waste coal piles in
Southwest Virginia

Report to the Governor and the General Assembly
January 10, 2024

Report Overview.........
Background on Waste Coal
What is Waste Coal....
Environmental impact
Background in Virginia — industry history, volumi

Relevant federal rules or programs

Relevant state rules or programs...

Previous waste coal reports, inc. Inventory
AML program...

Pennsylvania...
Comparison of VA and PA Waste Coal Asset:
Options for addressing waste coal
No action...
Encapsulation/remediation ...





   
 

2 
 

VCHEC ..................................................................................................................................10 
New Waste Coal to Generation Facilities ...............................................................................12 
Potential Source of Rare Earth Minerals (REEs) ...................................................................12 

TRC Report Summary ...............................................................................................................13 
Policy options ............................................................................................................................14 

Business as usual .................................................................................................................14 
Incentivize remediation ..........................................................................................................14 
Incentivize combustion ..........................................................................................................14 
Further Study .........................................................................................................................17 

Recommendations ....................................................................................................................17 
Conclusion ................................................................................................................................18 
Appendix 1 TRC Report ............................................................................................................18 
Appendix 2 TRC Conceptual Recommendations to Improve CO2e Emissions Data from 
Abandoned GOB Piles in VA .....................................................................................................18 
 
 

Report Overview 
This report is created pursuant to Senate Joint Resolution 258 that was passed by the 2023 
Virginia General Assembly.  The resolution states that the Virginia Department of Energy (Virginia 
Energy) is requested to study the environmental and economic impacts of eliminating waste coal 
piles in Southwest Virginia, including a range of use case scenarios. Here is the statutory request 
and instructions:  

RESOLVED by the Senate, the House of Delegates concurring, That the Department of Energy be requested to study 
the economic and environmental impacts of eliminating waste coal piles in Southwest Virginia. 

In conducting its study, the Department of Energy (the Department) shall convene a work group of stakeholders 
featuring representatives from state and local governments, investor-owned utilities, environmental organizations, the 
waste coal reclamation industry, and others deemed appropriate by the Department. The Department shall hold at least 
one public meeting and shall create a mechanism to receive public comment for consideration during the study. 

The Department shall examine various use case scenarios ranging from capping all existing waste coal piles in place 
to combusting all the material at VCHEC or other approved facilities. Each scenario considered by the Department shall 
contain an analysis of the direct and indirect economic and environmental benefits of that particular scenario. 

All agencies of the Commonwealth shall provide assistance to the Department for this study, upon request. 

The Department shall complete its meetings by November 30, 2023, and shall submit to the Governor and the General 
Assembly an executive summary and a report of its findings and recommendations, if any, for publication as a House 
or Senate document. The executive summary and report shall be submitted as provided in the procedures of the 
Division of Legislative Automated Systems for the processing of legislative documents and reports no later than the 
first day of the 2024 Regular Session of the General Assembly and shall be posted on the General Assembly's website. 

VCHEC....
New Waste Coal to Generation Facilities.
Potential Source of Rare Earth Minerals (REEs) .
TRC Report Summary...

Policy options.

Business as usual ...
Incentivize remediation...
Incentivize combustion ..
Further Study.
Recommendations...

Conclusion ..
‘Appendix 1 TRC Report

Appendix 2 TRC Conceptual Recommendations to Improve CO2e Emissions Data from
Abandoned GOB Piles in VA..

Report Overview

This report is created pursuant to Senate Joint Resolution 258 that was passed by the 2023
Virginia General Assembly. The resolution states that the Virginia Department of Energy (Virginia
Energy) is requested to study the environmental and economic impacts of eliminating waste coal
piles in Southwest Virginia, including a range of use case scenarios. Here is the statutory request
and instructions:

RESOLVED by the Senate, the House of Delegates concurring, That the Department of Energy be requested to study
the economic and environmental impacts of eliminating waste coal piles in Southwest Virginia.

In conducting its study, the Department of Energy (the Department) shall convene a work group of stakeholders
featuring representatives from state and local governments, investor-owned utilities, environmental organizations, the
waste coal reclamation industry, and others deemed appropriate by the Department. The Department shall hold at least.
‘one public meeting and shall create a mechanism to receive public comment for consideration during the study.

‘The Department shall examine various use case scenarios ranging from capping all existing waste coal piles in place
to combusting all the material at VCHEC or other approved facilities. Each scenario considered by the Department shall
contain an analysis of the direct and indirect economic and environmental benefits of that particular scenario.

All agencies of the Commonwealth shall provide assistance to the Department for this study, upon request.

‘The Department shall complete its meetings by November 30, 2023, and shall submit to the Governor and the General
‘Assembly an executive summary and a report of its findings and recommendations, if any, for publication as a House
or Senate document. The executive summary and report shall be submitted as provided in the procedures of the
Division of Legislative Automated Systems for the processing of legislative documents and reports no later than the
first day of the 2024 Regular Session of the General Assembly and shall be posted on the General Assembly's website.




   
 

3 
 

In executing the General Assembly’s request, Virginia Energy convened a work group of 
stakeholders to identify key data points, assist with data collection and review draft materials. 
Virginia Energy also engaged TRC Companies to conduct a technical study comparing the carbon 
equivalent emissions (CO2e) and other air quality factors between leaving the waste coal in place 
and combusting it at the Virginia City Hybrid Energy Center (VCHEC). A public comment portal 
was posted on the Virginia Townhall website and a meeting for public input was held in Lebanon, 
Virginia on October 2, 2023. No public comment was provided through either channel.  

Members of the workgroup were Adam Wells (Appalachian Voices), Tom Ballou (DEQ), Ava 
Lovain (DEQ), Larry Barton (Dickenson County), Geoffrey Hensley (Dominion), Larry Kuennen 
(Dominion), Gina Pisoni (Dominion), John Matney (Russel County Reclamation), Patrick Carr 
(SCC), Mike Cizenski (SCC), David Dalton (SCC), Brad Kreps (The Nature Conservancy), Jeff 
Taylor (Ultra Production Company), Will Clear (Virginia Energy Strategies) and Mike Hatfield 
(Wise County). The contents of this report do not necessarily reflect the opinions of the individual 
workgroup participants and should be solely attributed to the Virginia Department of Energy 
unless otherwise stated. 

Background on Waste Coal 
What is Waste Coal? 
Coal refuse piles, known as GOB (Garbage of Bituminous) piles, are accumulations of waste coal 
and other discarded mining refuse from mining and coal cleaning processes.1 In the context of 
coal mining, when coal is extracted from the Earth, it often contains various impurities such as 
rock, shale and other non-coal materials. These impurities are separated from the coal, and the 
waste material is typically piled up in an area near the mine, creating a GOB pile. GOB piles can 
vary in size and composition depending on the mining methods used and the geological 
characteristics of the coal seam.2 
 
The term GOB is particularly used in bituminous coal mining regions, such as Virginia. GOB piles 
can vary in size and composition depending on factors such as the mining techniques employed 
and the geological characteristics of the coal seam. In southwest Virginia, these piles can reach 
weights of tens of thousands of tons. Due to limited environmental regulations, pollutants leach 
from the coal refuse, causing erosion in local streams and soil. These GOB piles pose significant 
threats to health and safety, actively degrading both environmental and economic conditions in 
the region. 
 
Environmental Impacts 
Abandoned coal refuse piles represent a legacy environmental hazard in Virginia as well as 
throughout the Appalachian coal producing region of the United States. Due to the sheer 
magnitude of legacy coal refuse abandoned in Virginia, existing coal refuse piles represent a well-
documented threat to the natural environment.3 GOB piles present adverse impacts on water 

 
1 Belleville, M., Cole, C., Englander, G., & Callahan, J. (2023). Addressing Virginia’s legacy gob piles. 
Appalachian Journal of Law, 22 (1). Retrieved from: https://appalachian.scholasticahq.com/article/73814-
addressing-virginia-s-legacy-gob-piles 
2 U.S. Department of the Interior, Office of Surface Mining Reclamation and Enforcement. (n.d.). Glossary 
of Mining Terms. Retrieved from: https://www.osmre.gov/resources/glossary  
3 Trout Unlimited, (2020). The West Branch Susquehanna - A Watershed in Recovery. Retrieved from: 
www.tu.org  

In executing the General Assembly's request, Virginia Energy convened a work group of
stakeholders to identify key data points, assist with data collection and review draft materials.
Virginia Energy also engaged TRC Companies to conduct a technical study comparing the carbon
equivalent emissions (CO2e) and other air quality factors between leaving the waste coal in place
and combusting it at the Virginia City Hybrid Energy Center (VCHEC). A public comment portal
was posted on the Virginia Townhall website and a meeting for public input was held in Lebanon,
Virginia on October 2, 2023. No public comment was provided through either channel

Members of the workgroup were Adam Wells (Appalachian Voices), Tom Ballou (DEQ), Ava
Lovain (DEQ), Larry Barton (Dickenson County), Geoffrey Hensley (Dominion), Larry Kuennen
(Dominion), Gina Pisoni (Dominion), John Matney (Russel County Reclamation), Patrick Carr
(SCC), Mike Cizenski (SCC), David Dalton (SCC), Brad Kreps (The Nature Conservancy), Jeff
Taylor (Ultra Production Company), Will Clear (Virginia Energy Strategies) and Mike Hatfield
(Wise County). The contents of this report do not necessarily reflect the opinions of the individual
workgroup participants and should be solely attributed to the Virginia Department of Energy
unless otherwise stated.

Background on Waste Coal

What is Waste Coal?

Coal refuse piles, known as GOB (Garbage of Bituminous) piles, are accumulations of waste coal
and other discarded mining refuse from mining and coal cleaning processes." In the context of
coal mining, when coal is extracted from the Earth, it often contains various impurities such as
rock, shale and other non-coal materials. These impurities are separated from the coal, and the
waste material is typically piled up in an area near the mine, creating a GOB pile. GOB piles can
vary in size and composition depending on the mining methods used and the geological
characteristics of the coal seam.

The term GOB is particularly used in bituminous coal mining regions, such as Virginia. GOB piles
can vary in size and composition depending on factors such as the mining techniques employed
and the geological characteristics of the coal seam. In southwest Virginia, these piles can reach
weights of tens of thousands of tons. Due to limited environmental regulations, pollutants leach
from the coal refuse, causing erosion in local streams and soil. These GOB piles pose significant
threats to health and safety, actively degrading both environmental and economic conditions in
the region.

Environmental Impacts

Abandoned coal refuse piles represent a legacy environmental hazard in Virginia as well as
throughout the Appalachian coal producing region of the United States. Due to the sheer
magnitude of legacy coal refuse abandoned in Virginia, existing coal refuse piles represent a well-
documented threat to the natural environment.? GOB piles present adverse impacts on water

* Belleville, M., Cole, C., Englander, G., & Callahan, J. (2023). Addressing Virginia's legacy gob piles
Appalachian Journal of Law, 22 (1). Retrieved from: https://appalachian scholasticahg.com/article/73614-
addressing-virginia-s-leqacy-qob-piles

2U.S. Department of the Interior, Office of Surface Mining Reclamation and Enforcement. (n.d.). Glossary
of Mining Terms. Retrieved from: https://www.osmre.goviresources/glossary

° Trout Unlimited, (2020). The West Branch Susquehanna - A Watershed in Recovery. Retrieved from:

www.tu.org,





   
 

4 
 

quality, air quality, the risk of hazardous collapses, such as the 1966 Aberfan disaster in Wales in 
the United Kingdom, and potential injuries resulting from unsafe recreational activities. 
 
The 1977 Surface Mining Control and Reclamation Act (SMCRA) acknowledges waste coal as a 
potential "toxic forming material" because of its elevated sulfur levels, which contribute to acid 
drainage. Waste coal piles leach iron, manganese and aluminum pollution into waterways and 
cause acid drainage that kills neighboring streams. These piles also pose a risk of in-place 
combustion, releasing toxins and GHGs into the air. 
 
The historical coal mining activities in Southwest Virginia have given rise to enduring 
environmental challenges. A tangible outcome of this legacy is the presence of GOB piles, which 
consist of mining waste and discarded coal accumulated by mining operations over several 
decades. Compromised water quality and greenhouse gas emissions are the main environmental 
impacts of gob piles.  
 
Water Quality Impacts 
Acid Mine Drainage (AMD) is a distinctive issue within the mining sector, resulting in significant 
negative externalities valued in billions of dollars. AMD arises as surface and groundwater 
permeate through discarded coal piles, initiating a reaction involving pyrite, oxygen and water 
(whether on the surface or underground). This reaction produces acidic runoff that includes 
sulfuric acid and dissolved iron compounds, each exerting distinct effects on the environment. 
Overall, gob piles undermine, disturb and degrade ecosystems, impeding their capacity to support 
marine and plant life.4 
 
Virginia’s Stone Creek is an example of the negative effects that AMD can impose on waterways 
and their habitability, as well as the potential for environmental recovery. A buildup of 
sedimentation and the continuation of dissolved solids from abandoned mine lands resulted in 
the degradation of the 5,251-acre watershed. The Virginia Department of Environmental Quality 
(DEQ) determined that the body of water lacked the capacity to sustain aquatic life, classifying it 
as a "severely impaired" to "moderately impaired" waterway (See footnote 5). Subsequent to the 
DEQ reclaiming the disturbed mine lands adjacent to Stone Creek, there has been a remarkable 
improvement in the Total Maximum Daily Load (TMDL)5. The water quality of Stone Creek has 
improved tremendously since then, resulting in readings above the minimum required TMDL 
threshold in the fall of 2009 and 2010 (See footnote 2) and Virginia Stream Condition Index 
(VASCI)6 scores that indicate that the biological conditions in Stone Creek now fully support the 
designated uses for aquatic life. Consequently, the previously impaired 3.33-mile segment of 
Stone Creek was removed from the list of impaired waters in the state's 2014 Clean Water Act 
(CWA) 305(b)/303(d) Water Quality Assessment Integrated Report.7 
 

 
4 Belleville, M., Cole, C., Englander, G., & Callahan, J. (2023). Addressing Virginia’s legacy gob piles. 
Appalachian Journal of Law, 22 (1). Retrieved from: https://appalachian.scholasticahq.com/article/73814-
addressing-virginia-s-legacy-gob-piles  
5 Total maximum daily load refers to the maximum daily load of pollutants a body of water can sustain 
(Mueller et al., 2015).  
6 To assess aquatic life condition of a stream, the Commonwealth of Virginia now uses the Virginia 
Stream Condition Index (VASCI) based on biometrics analysis. A waterbody achieving a rating score 60 
or above is considered to be supporting biological integrity and attaining the aquatic life designated use. 
https://www.deq.virginia.gov/home/showpublisheddocument/5155/637490875744330000  
7 Reclaiming Acid Mine Drainage Areas and Implementing Control Measures Improve the Biological 
Health of Stone Creek. Retrieved from: 
https://www.deq.virginia.gov/home/showpublisheddocument/5155/637490875744330000  

quality, air quality, the risk of hazardous collapses, such as the 1966 Aberfan disaster in Wales in
the United Kingdom, and potential injuries resulting from unsafe recreational activities.

The 1977 Surface Mining Control and Reclamation Act (SMCRA) acknowledges waste coal as a
potential "toxic forming material” because of its elevated sulfur levels, which contribute to acid
drainage. Waste coal piles leach iron, manganese and aluminum pollution into waterways and
cause acid drainage that kills neighboring streams. These piles also pose a risk of in-place
combustion, releasing toxins and GHGs into the air.

The historical coal mining activities in Southwest Virginia have given rise to enduring
environmental challenges. A tangible outcome of this legacy is the presence of GOB piles, which
consist of mining waste and discarded coal accumulated by mining operations over several
decades. Compromised water quality and greenhouse gas emissions are the main environmental
impacts of gob piles.

Water Quality Impacts

Acid Mine Drainage (AMD) is a distinctive issue within the mining sector, resulting in significant
negative externalities valued in billions of dollars. AMD arises as surface and groundwater
permeate through discarded coal piles, initiating a reaction involving pyrite, oxygen and water
(whether on the surface or underground). This reaction produces acidic runoff that includes
sulfuric acid and dissolved iron compounds, each exerting distinct effects on the environment.
Overall, gob piles undermine, disturb and degrade ecosystems, impeding their capacity to support
marine and plant life.“

Virginia's Stone Creek is an example of the negative effects that AMD can impose on waterways
and their habitabiliy, as well as the potential for environmental recovery. A buildup of
sedimentation and the continuation of dissolved solids from abandoned mine lands resulted in
the degradation of the 5,251-acre watershed. The Virginia Department of Environmental Quality
(DEQ) determined that the body of water lacked the capacity to sustain aquatic life, classifying it
as a "severely impaired” to "moderately impaired" waterway (See footnote 5). Subsequent to the
DEQ reclaiming the disturbed mine lands adjacent to Stone Creek, there has been a remarkable
improvement in the Total Maximum Daily Load (TMDL)®. The water quality of Stone Creek has
improved tremendously since then, resulting in readings above the minimum required TMDL
threshold in the fall of 2009 and 2010 (See footnote 2) and Virginia Stream Condition Index
(VASCI)° scores that indicate that the biological conditions in Stone Creek now fully support the
designated uses for aquatic life. Consequently, the previously impaired 3.33-mile segment of
Stone Creek was removed from the list of impaired waters in the state's 2014 Clean Water Act
(CWA) 305(b)/303(d) Water Quality Assessment Integrated Report.”

4 Belleville, M., Cole, C., Englander, G., & Callahan, J. (2023). Addressing Virginia's legacy gob piles.
Appalachian Journal of Law, 22 (1). Retrieved from: httos://appalachian.scholasticahg.com/article/73814-

5 Total maximum daily load refers to the maximum daily load of pollutants a body of water can sustain
(Mueller et al., 2015).

© To assess aquatic life condition of a stream, the Commonwealth of Virginia now uses the Virginia
Stream Condition Index (VASCI) based on biometrics analysis. A waterbody achieving a rating score 60
or above is considered to be supporting biological integrity and attaining the aquatic life designated use.
https:/www.dea. virginia, qov/home/showpublisheddocument/5155/637490875744330000

7 Reclaiming Acid Mine Drainage Areas and Implementing Control Measures Improve the Biological
Health of Stone Creek. Retrieved from:

https:/www.deq. virginia. gov/home/showpublisheddocument/5155/637490875744330000

4




   
 

5 
 

GOB piles have a direct impact on Virginia's streams and waterways, releasing acidic runoff 
containing sulfuric acid and dissolved iron compounds that seep into these water systems, 
adversely affecting their habitability. The accumulation of dissolved iron compounds is particularly 
detrimental to aquatic species, elevating levels of siltation and sedimentation in the affected 
waterways.  
 
The following figure demonstrates the concentration of GOB piles around the waterways of 
southwest Virginia; this pattern heightens the probability of impairment and the loss of aquatic 
life. Notably, 27 piles are situated within a 10-mile radius of the Powell River, and four piles exist 
within a 10-mile radius of Virginia’s Clinch River watershed. These watersheds are integral 
components of Virginia's aquatic network, connecting to numerous other waterways and 
tributaries. The detrimental and pollutant impact of each GOB pile intensifies as the affected 
waters traverse these extensive watershed systems. 

 
Figure: GOB Piles and Impacted Waterways in Southwest Virginia (Source: 
https://appalachian.scholasticahq.com/article/73814-addressing-virginia-s-legacy-gob-piles). 
 
GOB piles pose a negative impact on vegetation. Sloped surface piles pose several challenges 
to the process of revegetation, including, (1) challenges in applying soil amendments on an 
inclined surface; (2) hindrances for soil in absorbing and retaining water due to heightened runoff, 
compounded by the compaction of refuse piles; and (3) the impact of the climate on sloped 
surfaces, influenced by the direction they face. 
 
 
 

GOB piles have a direct impact on Virginia's streams and waterways, releasing acidic runoff
containing sulfuric acid and dissolved iron compounds that seep into these water systems,
adversely affecting their habitability. The accumulation of dissolved iron compounds is particularly
detrimental to aquatic species, elevating levels of siltation and sedimentation in the affected

waterways.

The following figure demonstrates the concentration of GOB piles around the waterways of
southwest Virginia; this pattern heightens the probability of impairment and the loss of aquatic
life. Notably, 27 piles are situated within a 10-mile radius of the Powell River, and four piles exist
within a 10-mile radius of Virginia's Clinch River watershed. These watersheds are integral
components of Virginia's aquatic network, connecting to numerous other waterways and
tributaries. The detrimental and pollutant impact of each GOB pile intensifies as the affected
waters traverse these extensive watershed systems.

we voHec Riveting Benthic Impeiiments ALL
+ ALLAML Gob Location

Figure: GOB Piles and Impacted Waterways in Southwest Virginia (Source:
https://appalachian. scholasticahg.com/article/73814-addressing-virginia-s-legacy-ob-piles).

GOB piles pose a negative impact on vegetation. Sloped surface piles pose several challenges
to the process of revegetation, including, (1) challenges in applying soil amendments on an
inclined surface; (2) hindrances for soil in absorbing and retaining water due to heightened runoff,
‘compounded by the compaction of refuse piles; and (3) the impact of the climate on sloped
surfaces, influenced by the direction they face.




   
 

6 
 

Air Quality Impacts 
Coal dust emanating from these piles is carried by the wind. It extends into nearby communities 
and causes detrimental effects.8 While the detrimental effects of rainwater runoff are extensively 
documented, the inventory of abandoned coal refuse also serves as a significant and continuous 
source of uncontrolled air emissions that encompass greenhouse gases and other fugitive air 
pollutants. 
 
Legacy GOB piles emit substances inherent to their composition. These emissions increase when 
GOB is burned, often in uncontrolled incidents like pile fires. Abandoned waste coal in Virginia 
releases the highly potent greenhouse gas methane throughout its lifecycle. This poses a 
significant challenge to reduce GHG emissions as these in-situ legacy waste coal piles essentially 
act as persistent sources of GHGs. With currently available means, breaking this cycle practically 
requires re-mining waste coal piles and permanently eliminating the methane emissions through 
efficient combustion, converting the output into the less potent greenhouse gas CO2.  
 
Background in Virginia – industry history, volume 
The first documented coal discovery in Virginia was in the early 1700’s. In his diary, Colonel 
William Byrd noted commercial coal mining in present-day Goochland County by 1709.  In the 
late 18th century semi -anthracite coal deposits were discovered in Montgomery and Pulaski 
counties and small-scale pit mining was recorded by 1790.  In 1750 Thomas Walker noted coal 
deposits in present-day Tazewell County near Pocahontas and in 1751 coal deposits were 
reported in Wise County by Christopher Gist. 

While coal was mined commercially for local markets, it was in 1883 that the first shipment of coal 
from Southwest Virginia was delivered by rail to Norfolk.  This spawned the era of large-scale 
commercial mining in the Southwest Coalfields. (Hibbard, 1990) 

Earlier mining operations had less sophisticated methods of processing coal for markets.  For 
many years the main criteria for marketable coal was size.  Coal was screened after removal and 
the coal that met requirements was shipped while the remaining unmarketable coal and slate 
were dumped over hillsides, into stream beds, or stored in large fills known as gob piles.  During 
this era there were no regulations on how to manage coal waste so mine operators left the 
material in place. 

Based on the Virginia Department of Energy Gob Pile Inventory that accounts for the piles subject 
to the AML program there are an estimated 128 gob pile sites that contain over 14 million cubic 
yards of material in the Southwest Coalfields.9 Additionally a 2022 study identified the presence 
of 151 waste coal piles, including the AML sites, which total over 80-million cubic yards of 
material.10  

 

 
8 Mueller, S. et al. (2015). Variability of natural dust erosion from a coal pile. Applied Meteorology & 
Climatology, 54. Retrieved from: file:///C:/Users/rrb/Downloads/apme-jamc-d-14-0126.1.pdf  

9 Retrieved November 2023 at 
https://vadmme.maps.arcgis.com/apps/dashboards/32b3cd5eac064becb7ff6ab787b19561 
10 Virginia Department of Energy, Waste Coal Piles Identification And Use Of Coal Ash Report 
HB657/SB120 (December 2022) 

Air Quality Impacts

Coal dust emanating from these piles is carried by the wind. It extends into nearby communities
and causes detrimental effects.* While the detrimental effects of rainwater runoff are extensively
documented, the inventory of abandoned coal refuse also serves as a significant and continuous
source of uncontrolled air emissions that encompass greenhouse gases and other fugitive air
pollutants.

Legacy GOB piles emit substances inherent to their composition. These emissions increase when
GOB is burned, often in uncontrolled incidents like pile fires. Abandoned waste coal in Virginia
releases the highly potent greenhouse gas methane throughout its lifecycle. This poses a
significant challenge to reduce GHG emissions as these in-situ legacy waste coal piles essentially
act as persistent sources of GHGs. With currently available means, breaking this cycle practically
requires re-mining waste coal piles and permanently eliminating the methane emissions through
efficient combustion, converting the output into the less potent greenhouse gas CO2.

Background in Virginia — industry history, volume

The first documented coal discovery in Virginia was in the early 1700's. In his diary, Colonel
William Byrd noted commercial coal mining in present-day Goochland County by 1709. In the
late 18th century semi -anthracite coal deposits were discovered in Montgomery and Pulaski
counties and small-scale pit mining was recorded by 1790. In 1750 Thomas Walker noted coal
deposits in present-day Tazewell County near Pocahontas and in 1751 coal deposits were
reported in Wise County by Christopher Gist.

While coal was mined commercially for local markets, it was in 1883 that the first shipment of coal
from Southwest Virginia was delivered by rail to Norfolk. This spawned the era of large-scale
commercial mining in the Southwest Coalfields. (Hibbard, 1990)

Earlier mining operations had less sophisticated methods of processing coal for markets. For
many years the main criteria for marketable coal was size. Coal was screened after removal and
the coal that met requirements was shipped while the remaining unmarketable coal and slate
were dumped over hillsides, into stream beds, or stored in large fills known as gob piles. During
this era there were no regulations on how to manage coal waste so mine operators left the
material in place.

Based on the Virginia Department of Energy Gob Pile Inventory that accounts for the piles subject
to the AML program there are an estimated 128 gob pile sites that contain over 14 million cubic
yards of material in the Southwest Coalfields.® Additionally a 2022 study identified the presence
of 151 waste coal piles, including the AML sites, which total over 80-million cubic yards of
material. °

® Mueller, S. et al. (2015). Variability of natural dust erosion from a coal pile. Applied Meteorology &
Climatology, 54. Retrieved from: file://JC:/Users/rrb/Downloads/apme-jamo-d-14-0126.1 pdf

® Retrieved November 2023 at

https:/ivadmme.maps.arcgis. com/apps/dashboards/32b3ed5eac064becb7ff6ab787b19561

‘° Virginia Department of Energy, Waste Coal Piles Identification And Use Of Coal Ash Report
HB657/SB120 (December 2022)




   
 

7 
 

Relevant federal rules or programs 
In 1999 the Office of Surface Mining and Reclamation Enforcement (OSMRE) amended 30 C.F.R. 
707 and 874.  The amendments relaxed requirements that previously required AML programs to 
cover at least 50% of a project’s costs.  The new requirements allowed AML programs to finance 
a portion of the costs while the sale of incidental coal removal would offset the remainder of the 
project costs. In Virginia most of the removed coal is used for combustion at VCHEC. 

Relevant state rules or programs 
In January 2000 OSMRE approved Virginias Enhancement rule.  This marked a transition in how 
Virginia Energy approached gob pile reclamation by creating an option for removing a large 
portion of waste material from the site.  The contractor reclaiming the site was now allowed to sell 
the coal at a site to offset reclamation costs.  Prior to the amendments, coal waste reclamation 
was limited to onsite reclamation techniques such as grading material for stability, capping 
material with topsoil, revegetation and building clean water diversion structures to reduce site 
instability and erosion issues. 

In 2022, the General Assembly passed HB 1326 which declared that “the removal of waste coal 
from previously mined sites in the coalfield region of the Commonwealth... is in the public interest” 
and gave the Commission on Electric Utility Regulation (CEUR) the authority to review information 
on the approximate volume and number of waste coal piles present in the coalfield region and the 
options for cleaning up such waste coal piles. 

Previous waste coal reports and Inventory 
In 2022 Virginia Energy in response to House Bill 657 created a report that created a coal waste 
inventory in Virginia and outlined options for cleaning up coal waste sites.  Virginia Energy 
contracted with Marshall Miller & Associates (MM&A) to assist in creating the inventory and 
estimate volumes of coal waste piles.  Virginia Energy also contracted with Dr. Michael Karmis of 
Karmis LLC to produce a report that provides “a basic background of waste coal storage features 
and practices in the Southwest Virginia coalfields and addresses potential cleaning, utilization 
and reclamation options.” The study confirmed the presence of 151 waste coal sites which total 
over 80-million cubic yards of material.  Of this material around 14 million cubic yards are eligible 
for AML funded reclamation.  

There is a distinction to be made between waste coal and GOB coal, particularly as it pertains to 
the VCHEC plant. What is referred to as “waste coal” is generally managed impoundments that 
have been permitted since the implementation of SMCRA in 1977. While there will be variation in 
these structures, they are built specifically to store waste coal from permitted mining operations. 
In general, they are built to keep material stable and to minimize erosion and runoff issues. As a 
result, coal waste impoundments are not as prone the same environmental impacts as AML GOB 
piles, but they can be a source of GHG emissions and will have to be eliminated to ensure long-
term environmental protection. The Virginia Energy Coal Waste Inventory estimates that there 
are over 65 million cubic yards of coal waste material contained in such structures.11 

The exact acreage of refuse in the Southwest Virginia coal fields is difficult to estimate, but modern 
and fully stabilized and reclaimed disposal facilities, generated since the passage of the SMCRA 

 
11 Virginia Energy Coal Waste Informational Dashboard (Retrieved at 
https://vadmme.maps.arcgis.com/apps/dashboards/32b3cd5eac064becb7ff6ab787b19561 on 12/4/23) 

Relevant federal rules or programs

In 1999 the Office of Surface Mining and Reclamation Enforcement (OSMRE) amended 30 C.F.R.
707 and 874. The amendments relaxed requirements that previously required AML programs to
cover at least 50% of a project's costs. The new requirements allowed AML programs to finance
a portion of the costs while the sale of incidental coal removal would offset the remainder of the
project costs. In Virginia most of the removed coal is used for combustion at VCHEC.

Relevant state rules or programs

In January 2000 OSMRE approved Virginias Enhancement rule. This marked a transition in how
Virginia Energy approached gob pile reclamation by creating an option for removing a large
portion of waste material from the site. The contractor reclaiming the site was now allowed to sell
the coal at a site to offset reclamation costs. Prior to the amendments, coal waste reclamation
was limited to onsite reclamation techniques such as grading material for stability, capping
material with topsoil, revegetation and building clean water diversion structures to reduce site
instability and erosion issues.

In 2022, the General Assembly passed HB 1326 which declared that “the removal of waste coal
from previously mined sites in the coalfield region of the Commonwealth... is in the public interest”
and gave the Commission on Electric Utility Regulation (CEUR) the authority to review information
on the approximate volume and number of waste coal piles present in the coalfield region and the
options for cleaning up such waste coal piles.

Previous waste coal reports and Inventory

In 2022 Virginia Energy in response to House Bill 657 created a report that created a coal waste
inventory in Virginia and outlined options for cleaning up coal waste sites. Virginia Energy
contracted with Marshall Miller & Associates (MM&A) to assist in creating the inventory and
estimate volumes of coal waste piles. Virginia Energy also contracted with Dr. Michael Karmis of
Karmis LLC to produce a report that provides “a basic background of waste coal storage features
and practices in the Southwest Virginia coalfields and addresses potential cleaning, utilization
and reclamation options.” The study confirmed the presence of 151 waste coal sites which total
‘over 80-million cubic yards of material. Of this material around 14 million cubic yards are eligible
for AML funded reclamation.

There is a distinction to be made between waste coal and GOB coal, particularly as it pertains to
the VCHEC plant. What is referred to as ‘waste coal" is generally managed impoundments that
have been permitted since the implementation of SMCRA in 1977. While there will be variation in
these structures, they are built specifically to store waste coal from permitted mining operations.
In general, they are built to keep material stable and to minimize erosion and runoff issues. As a
result, coal waste impoundments are not as prone the same environmental impacts as AML GOB
piles, but they can be a source of GHG emissions and will have to be eliminated to ensure long-
term environmental protection. The Virginia Energy Coal Waste Inventory estimates that there
are over 65 million cubic yards of coal waste material contained in such structures."

The exact acreage of refuse in the Southwest Virginia coal fields is difficult to estimate, but modern
and fully stabilized and reclaimed disposal facilities, generated since the passage of the SMCRA

"Virginia Energy Coal Waste Informational Dashboard (Retrieved at
https:/ivadmme.maps.arcgis. com/apps/dashboards/32b3ed5eac064becb7ff6ab787b19561 on 12/4/23)

7




   
 

8 
 

Act in 1977, cover thousands of acres and abandoned refuse piles dot the landscape in almost 
every major mined watershed.   

AML program  
Since 1981 Virginia Energy has completed 84 projects that addressed coal waste issues.  The 
issues addressed include combustion/fire, pile instability and erosion.  The project type break out 
is as follows: 

• 15 Fire Related 
• 29 Enhancement 
• 24 Cap/Grade 
• 2 Removal to upland site 
• 14 Other (grading, drainage) 

Since the enhancement rule amendments, Virginia Energy has experienced substantial cost 
savings for coal waste pile reclamation due to the contractor’s ability to sell material from the site 
to offset project costs.  Virginia Energy’s obligations on enhancement GOB pile projects are 
limited to revegetation costs.  

Environmental Justice  

Per § 2.2-235 of the Code of Virginia, “[i]t is the policy of the Commonwealth to promote 
environmental justice and ensure that it is carried out throughout the Commonwealth, with a focus 
on environmental justice communities and fenceline communities”.   

The coalfields region of Virginia has seen reduced economic activity in recent years due to the 
decline in the thermal coal market.12 Many of the census tracts in the area qualify for economically 
distressed statuses, such as the Justice 40 designation associated with the federal Bipartisan 
Infrastructure Law (BIL) and the Inflation Reduction Act (IRA) and the historically economically 
disadvantaged community (HEDC) status created by the Virginia Clean Economy Act (VCEA).   

Additionally, the region has experienced environmental degradation as a result of historic coal 
extraction, including the environmental harms associated with waste coal piles. Whereas the 
entire economy of Virginia benefitted from the industrial activity coal energy facilitated and lower 
energy prices from the absence of waste coal clean up requirements prior to 1977, many of the 
environmental costs of coal production were confined to southwest Virginia. Most of the areas 
where waste coal piles are located would be considered environmental justice communities. An 
increase in clean-up efforts, whether through remediation programs or combustion at VCHEC, 
could be viewed as having positive effects for these communities through reduced environmental 
harms and increased economic opportunity. 

 

Pennsylvania 
The state of Pennsylvania has a substantial volume of waste coal piles that present similar 
challenges to the waste coal piles of southwest Virginia. A 2020 inventory of refuse piles kept by 

 
12 Thermal coal is used for electrical production and its extraction has declined substantially in the 
Commonwealth. Mining of metallurgical coal, which is used for industrial processes, most notably steel 
production, has remained steady as demand for steel is high and there are currently no viable alternatives 
that are less expensive or less GHG emitting. 

‘Act in 1977, cover thousands of acres and abandoned refuse piles dot the landscape in almost
every major mined watershed

AML program

Since 1981 Virginia Energy has completed 84 projects that addressed coal waste issues. The
issues addressed include combustion/fire, pile instability and erosion. The project type break out
is as follows:

+ 15 Fire Related
* 29 Enhancement

* 24 CaplGrade

* 2 Removal to upland site

+ 14 Other (grading, drainage)

Since the enhancement rule amendments, Virginia Energy has experienced substantial cost
savings for coal waste pile reclamation due to the contractor's abilty to sell material from the site
to offset project costs. Virginia Energy's obligations on enhancement GOB pile projects are
limited to revegetation costs.

Environmental Justice

Per § 2.2-235 of the Code of Virginia, “ijt is the policy of the Commonwealth to promote
environmental justice and ensure that itis carried out throughout the Commonwealth, with a focus
on environmental justice communities and fenceline communities”.

The coalfields region of Virginia has seen reduced economic activity in recent years due to the
decline in the thermal coal market. ? Many of the census tracts in the area qualify for economically
distressed statuses, such as the Justice 40 designation associated with the federal Bipartisan
Infrastructure Law (BIL) and the Inflation Reduction Act (IRA) and the historically economically
disadvantaged community (HEDC) status created by the Virginia Clean Economy Act (VCEA).

Additionally, the region has experienced environmental degradation as a result of historic coal
extraction, including the environmental harms associated with waste coal piles. Whereas the
entire economy of Virginia benefitted from the industrial activity coal energy facilitated and lower
energy prices from the absence of waste coal clean up requirements prior to 1977, many of the
environmental costs of coal production were confined to southwest Virginia. Most of the areas
where waste coal piles are located would be considered environmental justice communities. An
increase in clean-up efforts, whether through remediation programs or combustion at VCHEC,
could be viewed as having positive effects for these communities through reduced environmental
harms and increased economic opportunity.

Pennsylvania
The state of Pennsyivania has a substantial volume of waste coal piles that present similar
challenges to the waste coal piles of southwest Virginia. A 2020 inventory of refuse piles kept by

2 Thermal coal is used for electrical production and its extraction has declined substantially in the
Commonwealth. Mining of metallurgical coal, which is used for industrial processes, most notably steel
production, has remained steady as demand for steel is high and there are currently no viable alternatives
that are less expensive or less GHG emitting




   
 

9 
 

the Pennsylvania Department of Environmental Protection (DEP) identified 840 piles throughout 
Pennsylvania, which are estimated to consist of nearly 443.9 million metric tons of coal refuse, 
covering approximately 18,170 acres.13 Pennsylvania permits waste coal combustion for electrical 
generation as a Tier II resource in its Alternative Energy Portfolio Standards (AEPS). Previously 
out-of-state entities, such as VCHEC, could qualify for the Tier II credits but a law passed in 2021 
now restricts these credits to in-state operators only. A 2023 report produced by Lehigh University 
calculated that in-place coal refuse pile GHG emissions exceed by a factor of two to five times 
the corresponding emissions if burned under controlled conditions in Pennsylvania’s waste coal 
electricity facilities.14  

Comparison of VA and PA Waste Coal Assets 
The study that Virginia Energy engaged TRC to perform (see TRC Report Summary and 
Appendix 1) is intended to provide a similar calculation to the Pennsylvania study for Virginia and 
the VCHEC facility, however, there are some important differences to note between the 
Pennsylvania fleet of waste coal facilities and VCHEC. 

Operational Differences 

The Pennsylvania waste coal burners, although similar in design to VCHEC, have been burning 
waste coal since they were put into service. Over the years, they have fine-tuned their fuel 
handling and operations to facilitate this. VCHEC, however, has not burned as high a percentage 
of GOB as the Pennsylvania plants and has also been required, by permit, to burn 10% wood 
biomass. Burning GOB at VCHEC has resulted in challenges to the fuel handling equipment due 
to the excessive amounts of moisture and fines. VCHEC has already experienced escalations in 
Operation and Maintenance costs from burning GOB due to increased equipment wear from the 
higher ash content. Higher GOB burn rates will add costs from additional wear and landfill use. 

In Pennsylvania, the overall volume of GOB is larger with numerous, concentrated areas of piles. 
Coupled with most of the GOB-burning plants being much smaller than VCHEC, this has resulted 
in available, economical GOB being exhausted more slowly, however, some of the Pennsylvania 
plants are also beginning to procure material from greater distances with subsequent cost 
increases. 

Unlike the larger Pennsylvania stations, VCHEC does not own the fuel supply coming into the 
facility. Nor does VCHEC have covered, short term storage which would minimize the impact of 
wet fuel plugging the fuel handling systems for the boilers. Ownership of the fuel sources allows 
for complete sampling and analysis well in advance so proper blending can occur at the fuel 
loadout points. Heat content, moisture and particle size are all considered in their blending 
process with the goal of eliminating flowability issues in fuel conveying systems. In addition, some 
stations have large blending yards that further enhance the drying and blending capabilities. 

Emission Differences 

When constructed VCHEC had the most stringent air permit ever administered in the U.S. and 
the facility has air emission requirements that are much more restrictive than those for the 

 
13 Lehigh University Energy Research Center, Comparison Of The Impact On Greenhouse Gas 
Emissions Between Unabated Coal Refuse Piles And Reclamation-to-energy Power Plants, P2 
14 Lehigh University Energy Research Center, Comparison Of The Impact On Greenhouse Gas 
Emissions Between Unabated Coal Refuse Piles And Reclamation-to-energy Power Plants, P3 

the Pennsylvania Department of Environmental Protection (DEP) identified 840 piles throughout
Pennsylvania, which are estimated to consist of nearly 443.9 million metric tons of coal refuse,
covering approximately 18,170 acres. * Pennsylvania permits waste coal combustion for electrical
generation as a Tier Il resource in its Alternative Energy Portfolio Standards (AEPS). Previously
out-of-state entities, such as VCHEC, could qualify for the Tier II credits but a law passed in 2021
now restricts these credits to in-state operators only. A 2023 report produced by Lehigh University
calculated that in-place coal refuse pile GHG emissions exceed by a factor of two to five times
the corresponding emissions if burned under controlled conditions in Pennsyivania’s waste coal
electricity facilities. *

Comparison of VA and PA Waste Coal Assets
The study that Virginia Energy engaged TRC to perform (see TRC Report Summary and
Appendix 1) is intended to provide a similar calculation to the Pennsylvania study for Virginia and
the VCHEC facility, however, there are some important differences to note between the
Pennsylvania fleet of waste coal facilities and VCHEC.

Operational Differences

The Pennsylvania waste coal burners, although similar in design to VCHEC, have been burning
waste coal since they were put into service. Over the years, they have fine-tuned their fuel
handling and operations to facilitate this. VCHEC, however, has not burned as high a percentage
of GOB as the Pennsyivania plants and has also been required, by permit, to burn 10% wood
biomass. Burning GOB at VCHEC has resulted in challenges to the fuel handling equipment due
to the excessive amounts of moisture and fines. VCHEC has already experienced escalations in
Operation and Maintenance costs from burning GOB due to increased equipment wear from the
higher ash content. Higher GOB burn rates will add costs from additional wear and landfill use.

In Pennsylvania, the overall volume of GOB is larger with numerous, concentrated areas of piles.
Coupled with most of the GOB-burning plants being much smaller than VCHEC, this has resulted
in available, economical GOB being exhausted more slowly, however, some of the Pennsylvania
plants are also beginning to procure material from greater distances with subsequent cost
increases.

Unlike the larger Pennsylvania stations, VCHEC does not own the fuel supply coming into the
facility. Nor does VCHEC have covered, short term storage which would minimize the impact of
wet fuel plugging the fuel handling systems for the boilers. Ownership of the fuel sources allows
for complete sampling and analysis well in advance so proper blending can occur at the fuel
loadout points. Heat content, moisture and particle size are all considered in their blending
process with the goal of eliminating flowability issues in fuel conveying systems. In addition, some
stations have large blending yards that further enhance the drying and blending capabilities.

Emission Differences

When constructed VCHEC had the most stringent air permit ever administered in the U.S. and
the facility has air emission requirements that are much more restrictive than those for the

*8 Lehigh University Energy Research Center, Comparison Of The Impact On Greenhouse Gas
Emissions Between Unabated Coal Refuse Piles And Reclamation-to-energy Power Plants, P2
“4 Lehigh University Energy Research Center, Comparison Of The Impact On Greenhouse Gas
Emissions Between Unabated Coal Refuse Piles And Reclamation-to-energy Power Plants, P3

9




   
 

10 
 

Pennsylvania GOB burning plants. This requires higher performance from VCHEC’s air pollution 
control (APC) equipment. Dominion Energy has stated that it expects to maintain VCHEC’s 
environmental emission limits performance standards, even while burning higher amounts of 
GOB. 

Byproduct Differences 

The Pennsylvania waste coal burners are allowed to haul the high calcium CFB ash back to coal 
refuse remediation sites to help with overall acid neutralization. In Virginia, utilizing CFB ash for 
neutralization is not allowed, increasing the cost of landfilling as opposed to Pennsylvania. 

Options for addressing waste coal 
No action 
It is assumed that the eventual outcome of a coal waste pile is either combustion or erosion.  If 
left in place the gob piles will continue to degrade stream quality and air quality through erosion 
and combustion.  If the decision is made to leave the piles in place and not reclaim, the sites will 
remain a liability to Virginia Energy’s AML program. There is no other agency that routinely 
reclaims this type of hazard, and the responsibility for emergency abatement will fall to the agency 
and require the use of government funds.  If this option is chosen there will be environmental 
repercussions from lack of action.  Sites will eventually have to be addressed as individual piles 
that reach emergency status in the event of extreme instability or a fire.  The “do nothing option” 
ends up requiring the agency to quickly react to more extreme conditions and the reclamation 
costs are far more expensive for emergency fire projects.  To address hazards as they emerge at 
all remaining gob piles in the Virginia Energy coal waste inventory in the event of uncontrolled 
combustion could cost up to $268 million based on costs for emergency projects that address 
burning gob on a per/acre basis. 

Encapsulation/remediation 
Grading and capping the site with topsoil was a common method of reclamation before the 
enhancement rule allowed contractors to remove coal from the site to offset reclamation costs.  
This method consists of grading the gob into a stable configuration, constructing drainage controls 
around the site, capping the gob with topsoil and revegetating the site. Capping and grading a 
site addresses the potential for landslides and erosion issues but is considered a non-permanent 
form of reclamation because the material remains on site and is still prone to combustion.  The 
sites are a continuing liability and sometimes need to be addressed with maintenance action to 
correct erosion issues and failed drainage controls.   To cap and grade all remaining gob piles in 
the Virginia Energy coal waste inventory it would cost an estimated $100 million based on 
previous AML projects. Funding this work would create economic benefits, including additional 
jobs in the remediation sector. 

VCHEC 
VCHEC is a 610 MW electric generating facility located in Wise County, Virginia that utilizes a 
combination of waste coal, waste wood and run-of-mine coal as fuel. It entered service in 2012 
and has the potential to operate for more than fifty years. Since beginning commercial operations 

Pennsylvania GOB burning plants. This requires higher performance from VCHEC’s air pollution
control (APC) equipment. Dominion Energy has stated that it expects to maintain VCHEC's
environmental emission limits performance standards, even while burning higher amounts of
GOB.

Byproduct Differences

The Pennsylvania waste coal burners are allowed to haul the high calcium CFB ash back to coal
refuse remediation sites to help with overall acid neutralization. In Virginia, utilizing CFB ash for
neutralization is not allowed, increasing the cost of landfilling as opposed to Pennsylvania.

Options for addressing waste coal

No action

It is assumed that the eventual outcome of a coal waste pile is either combustion or erosion. If
left in place the gob piles will continue to degrade stream quality and air quality through erosion
and combustion. If the decision is made to leave the piles in place and not reclaim, the sites will
remain a liability to Virginia Energy's AML program. There is no other agency that routinely
reclaims this type of hazard, and the responsibility for emergency abatement will fall to the agency
and require the use of government funds. If this option is chosen there will be environmental
repercussions from lack of action. Sites will eventually have to be addressed as individual piles
that reach emergency status in the event of extreme instability or a fire. The “do nothing option”
ends up requiring the agency to quickly react to more extreme conditions and the reclamation
costs are far more expensive for emergency fire projects. To address hazards as they emerge at
all remaining gob piles in the Virginia Energy coal waste inventory in the event of uncontrolled
combustion could cost up to $268 million based on costs for emergency projects that address
burning gob on a perlacre basis.

Encapsulation/remediation

Grading and capping the site with topsoil was a common method of reclamation before the
enhancement rule allowed contractors to remove coal from the site to offset reclamation costs.
This method consists of grading the gob into a stable configuration, constructing drainage controls
around the site, capping the gob with topsoil and revegetating the site. Capping and grading a
site addresses the potential for landslides and erosion issues but is considered a non-permanent
form of reclamation because the material remains on site and is still prone to combustion. The
‘sites are a continuing liability and sometimes need to be addressed with maintenance action to
correct erosion issues and failed drainage controls. To cap and grade all remaining gob piles in
the Virginia Energy coal waste inventory it would cost an estimated $100 million based on
previous AML projects. Funding this work would create economic benefits, including additional
jobs in the remediation sector.

VCHEC

VCHEC is a 610 MW electric generating facility located in Wise County, Virginia that utilizes a
combination of waste coal, waste wood and run-of-mine coal as fuel. It entered service in 2012
and has the potential to operate for more than fifty years. Since beginning commercial operations

10




   
 

11 
 

in July 2012 until August 2021 VCHEC had generated more than 22.2 million MWh of electricity.15 
The Virginia Clean Economy Act (VCEA) of 2020 required the closure of all investor-owned utility 
coal plants by 2024, however, VCHEC, and one other facility that is jointly owned with a 
cooperative, were exempted and can operate until 2045 when all carbon-emitting plants are 
mandated to retire. In VCHEC’s case this exemption may be due to the environmental benefits 
described below. 

Environmental Impacts 

Combustion is currently the only viable option that allows for permanent restoration of affected 
areas as it removes the waste coal piles entirely where other remediation efforts leave the piles 
in place while reducing their environmental impacts. This avoids future generations having to 
address unremediated piles or reapply impermanent remediation measures to encapsulated 
piles. Waste coal combustion produces coal combustion residuals (CCRs) which is subject to 
federal and state laws for proper disposal, transferring the associated toxins from the waste coal 
piles to regulated storage facilities and potentially into safe reuse applications. 

Certain environmental benefits of remediating or combusting waste coal are confined to those 
places that have waste coal piles but others have state-wide or global benefits. The greenhouse 
gas reduction in combusting waste coal for electric production compared to allowing it to combust 
in place is a global benefit and aligns with the intent of the VCEA and other emissions-reducing 
regulations. In the event that VCHEC began using waste coal from other states for its operation, 
the GHG benefits would similarly be experienced as a global benefit. 

Economic Impacts 

Per Dominion, VCHEC supports approximately 121 direct jobs and an additional 180 indirect jobs, 
generating $25 million in labor income and $156 million in economic output in the region. 
Increased operation would likely result in higher indirect jobs as waste reclamation businesses 
could add staff to process and transport greater volumes of waste coal to the facility. Based on 
an Appalachian School of Law report, Dominion estimates that it would have cost over $250 
million to otherwise reclaim, transport and store the four million tons of GOB VCHEC has already 
converted to energy.1617 

Energy Considerations  

VCHEC is a dispatchable resource that can provide electricity at any time of day and ensure grid 
reliability. In February 2023, PJM, the regional transmission operator (RTO), for Virginia and 
twelve other states conducted research on resource adequacy through 2030 that showed 
"increasing reliability risks during the [energy] transition, due to a potential timing mismatch 
between resource retirements, load growth and the pace of new generation entry”.16 With existing 

 
15 Virginia Electric and Power Company, Report on Virginia City Hybrid Energy Center Pathways for 
Economic Viability submitted as part of SCC Docket PUR-2021-00114 Application of Virginia Electric and 
Power Company, For revision of rate adjustment clause: Rider S, Virginia City Hybrid Energy Center for 
the Rate Years Commencing April 1, 2022 and April 1, 2023 (November 2022), 1 
16 Virginia Electric and Power Company, Report on Virginia City Hybrid Energy Center Pathways for 
Economic Viability submitted as part of SCC Docket PUR-2021-00114 Application of Virginia Electric and 
Power Company, For revision of rate adjustment clause: Rider S, Virginia City Hybrid Energy Center for 
the Rate Years Commencing April 1, 2022 and April 1, 2023 (November 2022), 14 
17 Mark Belleville et al., Addressing Virginia’s Legacy GOB Piles, 22 Appalachian Journal of Law (2023). 

in July 2012 until August 2021 VCHEC had generated more than 22.2 million MWh of electricity. *°
The Virginia Clean Economy Act (VCEA) of 2020 required the closure of all investor-owned utility
coal plants by 2024, however, VCHEC, and one other facility that is jointly owned with a
cooperative, were exempted and can operate until 2045 when all carbon-emitting plants are
mandated to retire. In VCHEC’s case this exemption may be due to the environmental benefits
described below.

Environmental Impacts

Combustion is currently the only viable option that allows for permanent restoration of affected
areas as it removes the waste coal piles entirely where other remediation efforts leave the piles
in place while reducing their environmental impacts. This avoids future generations having to
address unremediated piles or reapply impermanent remediation measures to encapsulated
piles. Waste coal combustion produces coal combustion residuals (CCRs) which is subject to
federal and state laws for proper disposal, transferring the associated toxins from the waste coal
piles to regulated storage facilities and potentially into safe reuse applications.

Certain environmental benefits of remediating or combusting waste coal are confined to those
places that have waste coal piles but others have state-wide or global benefits. The greenhouse
gas reduction in combusting waste coal for electric production compared to allowing it to combust
in place is a global benefit and aligns with the intent of the VCEA and other emissions-reducing
regulations. In the event that VCHEC began using waste coal from other states for its operation,
the GHG benefits would similarly be experienced as a global benefit.

Economic Impacts

Per Dominion, VCHEC supports approximately 121 direct jobs and an additional 180 indirect jobs,
generating $25 million in labor income and $156 million in economic output in the region
Increased operation would likely result in higher indirect jobs as waste reclamation businesses
could add staff to process and transport greater volumes of waste coal to the facility. Based on
an Appalachian School of Law report, Dominion estimates that it would have cost over $250
million to otherwise reclaim, transport and store the four million tons of GOB VCHEC has already
converted to energy. "°"”

Eneray Considerations

VCHEC is a dispatchable resource that can provide electricity at any time of day and ensure grid
reliability. In February 2023, PJM, the regional transmission operator (RTO), for Virginia and
twelve other states conducted research on resource adequacy through 2030 that showed
\creasing reliability risks during the [energy] transition, due to a potential timing mismatch
between resource retirements, load growth and the pace of new generation entry’. "© With existing

*® Virginia Electric and Power Company, Report on Virginia City Hybrid Energy Center Pathways for
Economic Viability submitted as part of SCC Docket PUR-2021-00114 Application of Virginia Electric and
Power Company, For revision of rate adjustment clause: Rider S, Virginia City Hybrid Energy Center for
the Rate Years Commencing April 1, 2022 and April 1, 2023 (November 2022), 1

*® Virginia Electric and Power Company, Report on Virginia City Hybrid Energy Center Pathways for
Economic Viability submitted as part of SCC Docket PUR-2021-00114 Application of Virginia Electric and
Power Company, For revision of rate adjustment clause: Rider S, Virginia City Hybrid Energy Center for
the Rate Years Commencing April 1, 2022 and April 1, 2023 (November 2022), 14

*” Mark Belleville et al., Addressing Virginia's Legacy GOB Piles, 22 Appalachian Journal of Law (2023).

1




   
 

12 
 

dispatchable resources retiring at a faster rate than renewables are coming online, there is 
potential for the supply of energy to be insufficient to meet demand. Per Dominion’s 2023 IRP, it 
forecasts a need for additional dispatchable resources including 4GW of new natural gas 
facilities.17 Environmentalists have objected to these proposed facilities and increased operation 
of VCHEC may offer an environmentally beneficial alternative for a portion of this capacity while 
addressing the reliability concerns identified by PJM and Dominion, however, there are additional 
costs to an increased dispatch of VCHEC. Burning GOB at VCHEC has resulted in challenges to 
the fuel handling equipment due to the excessive amounts of moisture and fines. VCHEC has 
already experienced escalations in Operation and Maintenance costs from burning GOB due to 
increased equipment metal wear from the higher ash content. Higher GOB burn rates will add 
even more costs from wear and additional landfill use. 

The waste coal combusted at VCHEC is a Virginia-based resource that can help to ensure 
resiliency and security from market volatility or other external factors. Waste coal piles across the 
border in Kentucky and West Virginia would also represent relatively secure fuel sources as the 
VCHEC plant is their most viable path to market based on transportation factors. A key factor in 
the facility failures during Winter Strom Elliott was that supplies of natural gas were not delivered 
in sufficient quantities. VCHEC is capable of maintaining a local inventory of fuel and is therefore 
not as affected by weather or infrastructure availability as other generators further demonstrating 
its reliability value. However, in the event that market conditions, state incentives or other factors 
lead to higher GOB consumption at VCHEC, proper fuel procurement will be a challenge. As 
described in the Pennsylvania section, Dominion does not own the fuel supply coming into the 
facility and cannot fully optimize the fuel for combustion. 

Market conditions may become more favorable to VCHEC as other dispatchable units across 
PJM retire and the capacity and energy markets in PJM provide increased compensation to the 
remaining dispatchable units. Similarly, future spikes in natural gas prices may provide more 
favorable economic conditions for VCHEC and see waste coal’s value as a hedge fuel increase. 
Despite the high load increases forecasted in Dominion’s 2023 IRP, the dark spread, the 
difference between the price of coal and the market price of energy, is forecasted to be lower 
which currently offsets against the anticipated higher demand for energy.    

New Waste Coal to Generation Facilities 
VCHEC, even operating at full capacity, cannot combust all the waste coal material that is present 
in southwest Virginia. Building additional waste coal burning facilities would increase the amount 
of waste coal that could be permanently remediated. New facilities could be located near waste 
coal piles that are long distances from VCHEC, reducing the cost of transportation which affects 
those piles viability as a fuel for VCHEC. Such facilities could be more flexible, with potentially 
smaller and modular units that could be moved to different locations as onsite fuel is used up. At 
this time, such a solution does not appear commercially viable as existing waste coal units are 
dispatched at low levels under prevailing market prices. Increased operation of VCHEC would 
likely be a prudent first step before considering the expansion of the waste coal fleet. 

Potential Source of Rare Earth Minerals (REEs)  
Rare earth minerals (REEs) are a group of 17 chemical elements in the periodic table with unique 
properties that make them crucial components in a wide range of modern technologies, including 
electronics, renewable energy systems, electric vehicles, defense applications and more. The 
lack of domestic production of rare earth minerals and a heavy reliance on Chinese production 

dispatchable resources retiring at a faster rate than renewables are coming online, there is
potential for the supply of energy to be insufficient to meet demand, Per Dominion’s 2023 IRP, it
forecasts a need for additional dispatchable resources including 4GW of new natural gas
facilities.” Environmentalists have objected to these proposed facilities and increased operation
of VCHEC may offer an environmentally beneficial alternative for a portion of this capacity while
addressing the reliability concerns identified by PJM and Dominion, however, there are additional
costs to an increased dispatch of VCHEC. Burning GOB at VCHEC has resulted in challenges to
the fuel handling equipment due to the excessive amounts of moisture and fines. VCHEC has
already experienced escalations in Operation and Maintenance costs from burning GOB due to
increased equipment metal wear from the higher ash content. Higher GOB burn rates will add
even more costs from wear and additional landfill use.

The waste coal combusted at VCHEC is a Virginia-based resource that can help to ensure
resiliency and security from market volatility or other external factors. Waste coal piles across the
border in Kentucky and West Virginia would also represent relatively secure fuel sources as the
VCHEC plant is their most viable path to market based on transportation factors. A key factor in
the facility failures during Winter Strom Elliott was that supplies of natural gas were not delivered
in sufficient quantities. VCHEC is capable of maintaining a local inventory of fuel and is therefore
not as affected by weather or infrastructure availability as other generators further demonstrating
its reliability value. However, in the event that market conditions, state incentives or other factors
lead to higher GOB consumption at VCHEC, proper fuel procurement will be a challenge. As
described in the Pennsylvania section, Dominion does not own the fuel supply coming into the
facility and cannot fully optimize the fuel for combustion.

Market conditions may become more favorable to VCHEC as other dispatchable units across
PJM retire and the capacity and energy markets in PJM provide increased compensation to the
remaining dispatchable units. Similarly, future spikes in natural gas prices may provide more
favorable economic conditions for VCHEC and see waste coal's value as a hedge fuel increase.
Despite the high load increases forecasted in Dominion's 2023 IRP, the dark spread, the
difference between the price of coal and the market price of energy, is forecasted to be lower
which currently offsets against the anticipated higher demand for energy

New Waste Coal to Generation Facilities

VCHEC, even operating at full capacity, cannot combust all the waste coal material that is present
in southwest Virginia. Building additional waste coal burning facilities would increase the amount
of waste coal that could be permanently remediated. New facilities could be located near waste
coal piles that are long distances from VCHEC, reducing the cost of transportation which affects
those piles viability as a fuel for VCHEC. Such facilities could be more flexible, with potentially
smaller and modular units that could be moved to different locations as onsite fuel is used up. At
this time, such a solution does not appear commercially viable as existing waste coal units are
dispatched at low levels under prevailing market prices. Increased operation of VCHEC would
likely be a prudent first step before considering the expansion of the waste coal fleet.

Potential Source of Rare Earth Minerals (REEs)

Rare earth minerals (REEs) are a group of 17 chemical elements in the periodic table with unique
properties that make them crucial components in a wide range of modern technologies, including
electronics, renewable energy systems, electric vehicles, defense applications and more. The
lack of domestic production of rare earth minerals and a heavy reliance on Chinese production

12




   
 

13 
 

raise significant strategic concerns for the modern economy. Despite no active mines or known 
commercially viable deposits in Virginia, the state is actively involved in initiatives to identify such 
deposits.  

Although there are confirmed rare earth element (REE) occurrences in Virginia, the 
concentrations found are not economically feasible for commercial production. However, coal 
mine waste could be a potential source for extracting REEs, which could, in turn, assist with waste 
remediation. Coal mine waste in southwestern Virginia is being explored as a potential source of 
REEs. The Virginia Department of Energy’s Geology and Mineral Resources program is engaged 
in a number of grant-funded research projects addressing REEs and critical minerals, including 
the Evolve Central Appalachia (Evolve CAPP) project. The Evolve CAPP project which aims to 
identify Central Appalachian sources of rare earth elements and critical minerals has received 
$500,000 in federal funding to continue through the end of March 2024.18 The project‘s 
researchers collect and analyze REEs samples in the coal waste and find its beneficial uses for 
industries that utilize REEs. Moreover, pulling rare earths from coal waste also helps clean up the 
pollution.19 While critical mineral extraction is not currently commercially viable and would not fully 
remediate the coal waste, it is possible that in the future it would represent an additional value 
stream for waste coal reclamation projects. 

TRC Report Summary 
Virginia Energy engaged a contractor, TRC Companies (“TRC”), to conduct a study calculating 
the total GHG emissions (carbon dioxide equivalent or CO2e) from the inventory of waste coal 
piles in Virginia using methods derived from scholarly articles, peer-reviewed research and other 
scientific literature, and the total GHG emissions (CO2e) generated by waste coal combustion at 
VCHEC (see Appendix 1 for full report).20 

TRC estimates that there is potentially up to 14 million tons of CO2e emitting into the atmosphere 
every year from Virginia’s gob piles. Per their calculations, combusting a ton of waste coal results 
in a lifetime reduction of C02e of 52.6 tons. This is because as portions of waste coal piles 
spontaneously combust in place they release methane which is considered by EPA to be 81 times 
more potent as a greenhouse gas than carbon dioxide in the near-term (next 20 years) and 25-
28 times more potent over the long-term (100 years). When the waste coal is combusted the 
carbon is emitted primarily as carbon dioxide with a resulting benefit in terms of net GHG 
emissions expressed as CO2e. Based on this per ton reduction, waste reclamation through 
combustion at VCHEC in 2022 of 618,510 tons of coal refuse may have resulted in a GHG 
emissions reduction as high as 31.9m tons of CO2e. The value in this study exceeds the 
Pennsylvania values as that study only accounted for one year’s emissions from the waste coal 
piles and did not incorporate the ongoing emissions that would occur if it was not removed. GOB 
piles can persist for longer than a century without fully combusting and there is significant variation 
between piles in terms of how frequently they combust and the volume combusted. TRC assumed 

 
18 Busse, M. (2023). Quest for rare earth elements and critical minerals in Central Appalachia gets new 
boost. Cardinal News.  
19 Wayman, E. (2023). Rare earth elements could be pulled from coal waste. ScienceNews. 
20 Values are generally expressed as carbon dioxide equivalent (CO2e) as this normalizes the different 
GHG potencies of different gases. For example, one ton of carbon dioxide would equate to one ton CO2e 
while one ton of methane would equate to between 25 and 81 tons CO2e depending on the timespan 
under consideration. 

raise significant strategic concems for the modern economy. Despite no active mines or known
commercially viable deposits in Virginia, the state is actively involved in initiatives to identify such
deposits.

Although there are confirmed rare earth element (REE) occurrences in Virginia, the
concentrations found are not economically feasible for commercial production. However, coal
mine waste could be a potential source for extracting REEs, which could, in tur, assist with waste
remediation. Coal mine waste in southwestern Virginia is being explored as a potential source of
REEs. The Virginia Department of Energy's Geology and Mineral Resources program is engaged
in a number of grant-funded research projects addressing REEs and critical minerals, including
the Evolve Central Appalachia (Evolve CAPP) project. The Evolve CAPP project which aims to
identify Central Appalachian sources of rare earth elements and critical minerals has received
$500,000 in federal funding to continue through the end of March 2024."° The project's
researchers collect and analyze REEs samples in the coal waste and find its beneficial uses for
industries that utilize REEs. Moreover, pulling rare earths from coal waste also helps clean up the
pollution. While critical mineral extraction is not currently commercially viable and would not fully
remediate the coal waste, it is possible that in the future it would represent an additional value
stream for waste coal reclamation projects.

TRC Report Summary

Virginia Energy engaged a contractor, TRC Companies (“TRC”), to conduct a study calculating
the total GHG emissions (carbon dioxide equivalent or CO2e) from the inventory of waste coal
piles in Virginia using methods derived from scholarly articles, peer-reviewed research and other
scientific literature, and the total GHG emissions (CO2e) generated by waste coal combustion at
\VCHEC (see Appendix 1 for full report).2°

TRC estimates that there is potentially up to 14 million tons of CO2e emitting into the atmosphere
every year from Virginia's gob piles. Per their calculations, combusting a ton of waste coal results
in a lifetime reduction of C02e of 52.6 tons. This is because as portions of waste coal piles
spontaneously combust in place they release methane which is considered by EPA to be 81 times
more potent as a greenhouse gas than carbon dioxide in the near-term (next 20 years) and 25-
28 times more potent over the long-term (100 years). When the waste coal is combusted the
carbon is emitted primarily as carbon dioxide with a resulting benefit in terms of net GHG
emissions expressed as CO2e. Based on this per ton reduction, waste reclamation through
combustion at VCHEC in 2022 of 618,510 tons of coal refuse may have resulted in a GHG
emissions reduction as high as 31.9m tons of CO2e. The value in this study exceeds the
Pennsylvania values as that study only accounted for one year's emissions from the waste coal
piles and did not incorporate the ongoing emissions that would occur if it was not removed. GOB
piles can persist for longer than a century without fully combusting and there is significant variation
between piles in terms of how frequently they combust and the volume combusted. TRC assumed

*® Busse, M. (2023). Quest for rare earth elements and critical minerals in Central Appalachia gets new
boost. Cardinal News.

*® Wayman, E. (2023). Rare earth elements could be pulled from coal waste. ScienceNews.

® Values are generally expressed as carbon dioxide equivalent (CO2e) as this normalizes the different
GHG potencies of different gases. For example, one ton of carbon dioxide would equate to one ton CO2e
while one ton of methane would equate to between 25 and 81 tons CO2e depending on the timespan
under consideration,

13




   
 

14 
 

that the piles would continue to emit over a longer period and assigned a value of ten times the 
year one emissions over its full lifecycle. 

TRC concludes that “[i]t is very challenging to think of another economically viable and 
environmentally beneficial technology of any kind that could come close to providing a net CO2e 
benefit of this magnitude, at little cost to the Commonwealth of Virginia, while permanently 
eliminating further collateral environmental problems created by coal refuse”.21 

Policy options 

Business as usual 
In the event the Commonwealth took no further action on waste coal, remediation would continue 
to occur at the pace dictated by federal funding and the market conditions for VCHEC. Waste coal 
piles would persist as an environmental hazard for decades to come, barring a currently 
unforeseen technological advance in remediation, and no further economic development benefits 
would be realized. 

Incentivize remediation 
The state could offer funding to augment the remediation efforts that are currently funded through 
the federal AML program. This would increase the pace of remediation and create additional jobs 
in the remediation field. However, as described above, the practice of encapsulation currently 
employed does not significantly reduce the GHG emissions impact as it is focused on water quality 
protection.  

Any form of incentivization that is pursued should ensure that it achieves additionality as it is vital 
that funding generates new activity rather than simply increasing the compensation for activities 
at their current level. This could take the form of more piles encapsulated or more tons of waste 
coal combusted at VCHEC and any incentive mechanism should include effective verifications 
standards. 

Incentivize combustion 
Incentives could range from dedicated funding for waste coal consumption at the generator 
dispatch or reclamation operator level to goal-based incentives, such as carbon reduction credits.  

Dominion has provided a retrospective analysis of the effect that monetary incentives could have 
had on the capacity factor and subsequent GOB consumption of VCHEC over the past five years 
in a scenario that maximizes GOB consumption. They have estimated, based on the five-year 
historical average of pricing in the PJM region, that an incentive of $10 per nMWh of output would 
have enabled the VCHEC facility to operate at an average capacity factor of 58% between 2018-
2022, almost double the 31% capacity factor that was actually experienced during that time 
period. Under this methodology, the incentives are applied only on days that the facility would not 
normally run economically and the incentive required on those days is calculated as am amount 
only sufficient to get the facility dispatched into the market, allowing it to operate at a break-even 
rate with the utility receiving no profit from the sale of the incentivized power.  On days that the 
facility would operate economically, no incentive is applied and no profit is taken from the facility 

 
21 TRC Companies, Net Air Emission Benefits from the Remediation of Abandoned Coal Refuse Piles 
(December 2023), 4 

that the piles would continue to emit over a longer period and assigned a value of ten times the
year one emissions over its full lifecycle.

TRC concludes that “[ijt is very challenging to think of another economically viable and
environmentally beneficial technology of any kind that could come close to providing a net CO2e
benefit of this magnitude, at little cost to the Commonwealth of Virginia, while permanently
eliminating further collateral environmental problems created by coal refuse”.2*

Policy options

Business as usual

In the event the Commonwealth took no further action on waste coal, remediation would continue
to occur at the pace dictated by federal funding and the market conditions for VCHEC. Waste coal
piles would persist as an environmental hazard for decades to come, barring a currently

unforeseen technological advance in remediation, and no further economic development benefits
would be realized.

Incentivize remediation

The state could offer funding to augment the remediation efforts that are currently funded through
the federal AML program. This would increase the pace of remediation and create additional jobs
in the remediation field. However, as described above, the practice of encapsulation currently
‘employed does not significantly reduce the GHG emissions impact as itis focused on water quality
protection.

Any form of incentivization that is pursued should ensure that it achieves additionally as itis vital
that funding generates new activity rather than simply increasing the compensation for activities
at their current level. This could take the form of more piles encapsulated or more tons of waste
coal combusted at VCHEC and any incentive mechanism should include effective verifications
standards.

Incentivize combustion
Incentives could range from dedicated funding for waste coal consumption at the generator
dispatch or reclamation operator level to goal-based incentives, such as carbon reduction credits

Dominion has provided a retrospective analysis of the effect that monetary incentives could have
had on the capacity factor and subsequent GOB consumption of VCHEC over the past five years
in a scenario that maximizes GOB consumption. They have estimated, based on the five-year
historical average of pricing in the PJM region, that an incentive of $10 per nMWh of output would
have enabled the VCHEC facility to operate at an average capacity factor of 58% between 2018-
2022, almost double the 31% capacity factor that was actually experienced during that time
period. Under this methodology, the incentives are applied only on days that the facility would not
normally run economically and the incentive required on those days is calculated as am amount
only sufficient to get the facility dispatched into the market, allowing it to operate at a break-even
rate with the utility receiving no profit from the sale of the incentivized power. On days that the
facility would operate economically, no incentive is applied and no profit is taken from the facility

21 TRC Companies, Net Air Emission Benefits from the Remediation of Abandoned Coal Refuse Piles
(December 2023), 4

14




   
 

15 
 

to be used as a monetary offset on days it does not operate economically so profit is made on 
those day but at no cost to the incentivizing entity.  

Incentivizing the facility at the $10 per nMWh level would have resulted in the consumption of 
over 7.6 million tons of waste coal over the five-year period, over 4.5 million tons of which is GOB. 
Given the necessity to utilize run-of-mine coal to increase the quality of waste coal fuel utilized in 
VCHEC’s boilers, there would also have been over 2.5 million tons of additional run-of-mine coal 
consumed during this same period. When the carbon equivalent emissions from combustion of 
the entire portfolio of coal-based fuel (2.4 tons CO2e emissions per ton fuel consumed) are 
subtracted from the carbon equivalent emissions from the decomposition and oxidation of GOB 
in the environment (52.6 tons CO2e emissions per ton of GOB decomposed in the environment) 
there remains a net reduction over ten years of 44.9 tons CO2e per ton of GOB consumed, which 
equates to nearly 400 million tons of CO2e emissions avoided.22 At the $10 incentive level this 
would have equated to a value of $0.43 per ton of CO2e reduction, in addition to eliminating 
hundreds of thousands of tons of GOB, with an annual spend of $8.4 million. 

Table 1. Dominion estimated annual expenditure of incentivizing increased GOB consumption at 
VCHEC from 2018-2022 

  

 

Based on Table 1 there would have been an increase in GOB consumption with an incentive of 
up to $15 per mWh. After that point there is little gain for additional incentive. Operating the facility 
at a higher capacity would result in higher operations and maintenance costs but, these are likely 
to be minor expenses compared to the monetary incentive. It should be noted that the data 
presented reflects what would have happened from 2018-2022. Recent factors, in particular high 
inflation, may imply that the effective incentive range would be slightly higher moving forward. Any 
level of incentive would allow for increased capacity at VCHEC but, per this analysis, meeting the 
$10 per nMWh amount would allow for more substantial coal waste elimination and create a more 
sustainable market for waste coal suppliers with positive impacts in terms of jobs and capital 
investment. An incentive of this nature should be tailored to ensure that is maximizing GOB 
consumption at that plant, which is reflected in the Dominion analysis, and not simply incentivizing 
additional plant operation regardless of fuel type.    

 
22 EIA, Carbon Dioxide Emissions Coefficients, (retrieved at 
https://www.eia.gov/environment/emissions/co2_vol_mass.php on 12/27/2023) 

to be used as a monetary offset on days it does not operate economically so profit is made on
those day but at no cost to the incentivizing entity.

Incentivizing the facility at the $10 per nMWh level would have resulted in the consumption of
over 7.6 million tons of waste coal over the five-year period, over 4.5 million tons of which is GOB.
Given the necessity to utilize run-of-mine coal to increase the quality of waste coal fuel utilized in
VCHEC's boilers, there would also have been over 2.5 million tons of additional run-of-mine coal
consumed during this same period. When the carbon equivalent emissions from combustion of
the entire portfolio of coal-based fuel (2.4 tons CO2e emissions per ton fuel consumed) are
subtracted from the carbon equivalent emissions from the decomposition and oxidation of GOB
in the environment (52.6 tons CO2e emissions per ton of GOB decomposed in the environment)
there remains a net reduction over ten years of 44.9 tons CO2e per ton of GOB consumed, which
equates to nearly 400 million tons of CO2e emissions avoided.” At the $10 incentive level this
would have equated to a value of $0.43 per ton of CO2e reduction, in addition to eliminating
hundreds of thousands of tons of GOB, with an annual spend of $8.4 million.

Table 1. Dominion estimated annual expenditure of incentivizing increased GOB consumption at
VCHEC from 2018-2022

incentive | GOB Coal | Capacity ‘Average Total
$/nmwh | — Used Factor [9/7008] cost per Year
3 482,760 3i%_|s_-_|s ~

$ _5.00| 746,496 47% |$  3.96|$ 2,958,682.06
$15.00 959,040 61% $ 11.33 | $ 10,862,955.62
$20.00 971,352 62% $12.18 | $ 11,828,903.76
$25.00 979,776 62% $12.94 | $ 12,682,724.03
$30.00 983,016 62% $13.29 | $ 13,067,349.53

Based on Table 1 there would have been an increase in GOB consumption with an incentive of
up to $15 per mWh. After that point there is litle gain for additional incentive. Operating the facility
at a higher capacity would result in higher operations and maintenance costs but, these are likely
to be minor expenses compared to the monetary incentive. It should be noted that the data
presented reflects what would have happened from 2018-2022. Recent factors, in particular high
inflation, may imply that the effective incentive range would be slightly higher moving forward. Any
level of incentive would allow for increased capacity at VCHEC but, per this analysis, meeting the
$10 per nMWh amount would allow for more substantial coal waste elimination and create a more
sustainable market for waste coal suppliers with positive impacts in terms of jobs and capital
investment. An incentive of this nature should be tailored to ensure that is maximizing GOB
‘consumption at that plant, which is reflected in the Dominion analysis, and not simply incentivizing
additional plant operation regardless of fuel type.

22 BIA, Carbon Dioxide Emissions Coefficients, (retrieved at
https:/www.eia. gov/environment/emissions/co2_vol_mass.php on 12/27/2023)

15




   
 

16 
 

Based on estimates for both the value of carbon reduction and the cost for other GHG reduction 
measures, additional waste coal combustion at VCHEC appears to be very competitive at 
potentially less than a dollar a ton of CO2e. The VCEA requires that the SCC include the social 
cost of carbon as a benefit or a cost in any application to construct a new generating facility.23 
This figure can be calculated using different methodologies and the value assigned by the federal 
government has changed with different administrations. The report cited in the Code, the 
Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory 
Impact Analysis Under Executive Order 12866, published by the Interagency Working Group on 
Social Cost of Greenhouse Gases from the United States Government in August 2016, placed a 
value of $42 on the coal cost of carbon at the time of the VCEA in 2020.24 In November 2023, the 
EPA published a new study that places the social cost of carbon at $120 or greater depending on 
the scenario.25 The Trump administration used a value between $1 and $7 a metric ton for the 
social cost of carbon.  

Another means of comparison is the dollar per CO2 ton saving for renewable assets. A 2018 
Harvard University study calculated that the cost of converting from existing coal generation to 
utility-scale solar was $29 per ton of CO2 reduction.2627  A 2022 study by Columbia University’s 
Center of Global Energy Policy calculated that the cost of converting from existing natural gas 
generation to utility-scale solar in California was $60 per ton of CO2 reduction.28 

The benefits of remediating coal piles through combustion at VCHEC are not uniform across all 
the affected communities. Those communities could be based on region, for example southwest 
Virginia compared to the whole Commonwealth, funding source, for example, taxpayers or 
ratepayers, or other factors. In terms of region, the GHG reductions associated with VCHEC are 
experienced across the Commonwealth while other environmental benefits, such as improved 
water quality, would primarily be experienced by the residents of the coalfields. Similarly, 
Dominion ratepayers would experience the GHG benefits of VCHEC but not the other 
environmental benefits as the coal piles are outside of Dominion’s service territory. Utility 
customers could benefit from increased capacity from an existing, dispatchable resource through 
avoidance of some new construction of fossil fuel plants and increased output from a plant that is 
already connected to high-capacity transmission. Including the proportion of generation 
attributable to waste coal from VCHEC as an eligible resource under VCEA could enhance the 
economics of the facility. While waste coal combusted at VCHEC is neither a renewable nor a 
zero-carbon resource when used in energy production, the conversion of methane to carbon 

 
23 § 56-585.1 A(6) 
24 Interagency Working Group on Social Cost of Greenhouse Gases, United States Government, 
Technical Support Document: - Technical Update of the Social Cost of Carbon for Regulatory Impact 
Analysis - Under Executive Order 12866 (August 2016), 4 
25 EPA, Supplementary Material for the Regulatory Impact Analysis for the Final Rulemaking, “Standards 
of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing 
Sources: Oil and Natural Gas Sector Climate Review” EPA Report on the Social Cost of Greenhouse 
Gases: Estimates Incorporating Recent Scientific Advances (November 2023) 
26 Based on an approximate 25% inflation rate between 2017 and 2023 that would place the figure at 
$36.25 in today’s dollars. 
27 Gillingham, Kenneth and James Stock (2018) The Cost of Reducing Greenhouse Gas Emissions. 
Journal of Economic Perspectives, 32(5): 1-20. 
28 Columbia University Center on Global Energy Policy, Levelized Cost Of Carbon Abatement: An 
Improved Cost-assessment Methodology For A Net-zero Emissions World (October 2020) 

Based on estimates for both the value of carbon reduction and the cost for other GHG reduction
measures, additional waste coal combustion at VCHEC appears to be very competitive at
potentially less than a dollar a ton of CO2e. The VCEA requires that the SCC include the social
cost of carbon as a benefit or a cost in any application to construct a new generating facility.”°
This figure can be calculated using different methodologies and the value assigned by the federal
government has changed with different administrations. The report cited in the Code, the
Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory
Impact Analysis Under Executive Order 12866, published by the Interagency Working Group on
Social Cost of Greenhouse Gases from the United States Government in August 2016, placed a
value of $42 on the coal cost of carbon at the time of the VCEA in 2020.” In November 2023, the
EPA published a new study that places the social cost of carbon at $120 or greater depending on
the scenario. The Trump administration used a value between $1 and $7 a metric ton for the
social cost of carbon.

Another means of comparison is the dollar per CO2 ton saving for renewable assets. A 2018
Harvard University study calculated that the cost of converting from existing coal generation to
utilty-scale solar was $29 per ton of CO2 reduction.” A 2022 study by Columbia University's
Center of Global Energy Policy calculated that the cost of converting from existing natural gas
generation to utility-scale solar in California was $60 per ton of CO2 reduction. ”*

The benefits of remediating coal piles through combustion at VCHEC are not uniform across all
the affected communities. Those communities could be based on region, for example southwest
Virginia compared to the whole Commonwealth, funding source, for example, taxpayers or
ratepayers, or other factors. In terms of region, the GHG reductions associated with VCHEC are
experienced across the Commonwealth while other environmental benefits, such as improved
water quality, would primarily be experienced by the residents of the coalfields. Similarly,
Dominion ratepayers would experience the GHG benefits of VCHEC but not the other
environmental benefits as the coal piles are outside of Dominion’s service territory. Utility
customers could benefit from increased capacity from an existing, dispatchable resource through
avoidance of some new construction of fossil fuel plants and increased output from a plant that is
already connected to high-capacity transmission. Including the proportion of generation
attributable to waste coal from VCHEC as an eligible resource under VCEA could enhance the
economics of the facility. While waste coal combusted at VCHEC is neither a renewable nor a
zero-carbon resource when used in energy production, the conversion of methane to carbon

 § 56-585.1 A(6)
24 Interagency Working Group on Social Cost of Greenhouse Gases, United States Government,
Technical Support Document: - Technical Update of the Social Cost of Carbon for Regulatory Impact
Analysis - Under Executive Order 12866 (August 2016), 4

25 EPA, Supplementary Material for the Regulatory Impact Analysis for the Final Rulemaking, “Standards
of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing
Sources: Oil and Natural Gas Sector Climate Review” EPA Report on the Social Cost of Greenhouse
Gases: Estimates Incorporating Recent Scientific Advances (November 2023)

28 Based on an approximate 25% inflation rate between 2017 and 2023 that would place the figure at
$36.25 in today's dollars.

27 Gillingham, Kenneth and James Stock (2018) The Cost of Reducing Greenhouse Gas Emissions.
Journal of Economic Perspectives, 32(5): 1-20.

28 Columbia University Center on Global Energy Policy, Levelized Cost Of Carbon Abatement: An
Improved Cost-assessment Methodology For A Net-zero Emissions World (October 2020)

16




   
 

17 
 

dioxide in the combustion process for energy production provides a clear benefit in terms of 
reduced GHG emissions and would appear to meet the ultimate intent of the legislation. 

At its current output VCHEC makes significant contributions to the economy of southwest Virginia 
and these economic benefits would be amplified if more waste coal were being collected and 
combusted. While incentives to increase activity at VCHEC or accelerate remediation programs 
would be beneficial to the economy of southwest Virginia there would be costs to other citizens 
of the Commonwealth, through taxes or rates, that need to be considered. As described in the 
AML Program section reclamation for combustion does have the benefit of reducing the amount 
of taxpayer-funded engineering work to remediate piles in place. 

While it is possible that a more economical and environmentally beneficial process for remediating 
waste coal piles will emerge in the future, there are no strong prospects at this time and the piles 
will continue to cause significant environmental damage in the intervening period. Incentivization 
of remediation efforts and increased combustion at VCHEC could be considered public interest 
actions based on the declaration of the 2022 General Assembly in HB 1326. 

Further Study 
There are limitations to the available data that was employed in this report and the TRC emissions 
study.  Most notably there is an absence of data specific to the waste coal piles of southwest 
Virginia with current emissions estimates based on EPA literature that does not directly address 
the Virginia coal waste. While it is reasonable to assume that the waste coal piles in Virginia emit 
at comparable rates, site specific data would clarify the emissions profile of the Virginia waste 
piles and help to refine the value proposition for the different policy options presented above. An 
in-depth study could also quantify the effects of waste coal piles on water quality and other 
environmental impacts. This could allow the Commonwealth to prioritize piles for remediation 
based on emissions, water quality impacts or other factors. 

TRC has provided an estimate for executing a detailed sampling and measurements plan and 
protocol (see Appendix 2). This estimate is provided for reference only and neither the 
Commonwealth nor TRC are obligated in any manner to execute a contract. The project 
description includes identifying spontaneous combustion occurring at waste coal piles and onsite 
emissions testing and the preliminary estimate is $100,000. In the event that further study is 
deemed necessary, available funding should be adjusted to reflect the actual requirements and 
expectations set out by the General Assembly. 

Recommendations 
1. The General Assembly should consider incentivization of waste coal combustion. There 

is a clear GHG emissions benefit to combusting material and the only alternative method 
of remediation does not address the GHG emissions or substantially eliminate the waste 
coal. There are also ancillary economic benefits in maintaining a dispatchable 
generating facility in VCHEC and increasing economic activity in southwest Virginia. 
Waste coal combustion incentivization should be used as a point of comparison for other 
proposals to reduce GHG emissions, remediate environmental hazards or create 
economic development opportunities in southwest Virginia.  
 

dioxide in the combustion process for energy production provides a clear benefit in terms of
reduced GHG emissions and would appear to meet the ultimate intent of the legislation.

Atits current output VCHEC makes significant contributions to the economy of southwest Virginia
and these economic benefits would be amplified if more waste coal were being collected and
combusted. While incentives to increase activity at VCHEC or accelerate remediation programs
would be beneficial to the economy of southwest Virginia there would be costs to other citizens
of the Commonwealth, through taxes or rates, that need to be considered. As described in the
AML Program section reclamation for combustion does have the benefit of reducing the amount
of taxpayer-funded engineering work to remediate piles in place.

While it is possible that a more economical and environmentally beneficial process for remediating
waste coal piles will emerge in the future, there are no strong prospects at this time and the piles
will continue to cause significant environmental damage in the intervening period. Incentivization
of remediation efforts and increased combustion at VCHEC could be considered public interest
actions based on the declaration of the 2022 General Assembly in HB 1326.

Further Study

There are limitations to the available data that was employed in this report and the TRC emissions
study. Most notably there is an absence of data specific to the waste coal piles of southwest
Virginia with current emissions estimates based on EPA literature that does not directly address
the Virginia coal waste. While it is reasonable to assume that the waste coal piles in Virginia emit
at comparable rates, site specific data would clarify the emissions profile of the Virginia waste
piles and help to refine the value proposition for the different policy options presented above. An
in-depth study could also quantify the effects of waste coal piles on water quality and other
environmental impacts. This could allow the Commonwealth to prioritize piles for remediation
based on emissions, water quality impacts or other factors.

TRC has provided an estimate for executing a detailed sampling and measurements plan and
protocol (see Appendix 2). This estimate is provided for reference only and neither the
Commonwealth nor TRC are obligated in any manner to execute a contract. The project
description includes identifying spontaneous combustion occurring at waste coal piles and onsite
emissions testing and the preliminary estimate is $100,000. In the event that further study is
deemed necessary, available funding should be adjusted to reflect the actual requirements and
expectations set out by the General Assembly.

Recommendations
1. The General Assembly should consider incentivization of waste coal combustion. There

is a clear GHG emissions benefit to combusting material and the only alternative method
of remediation does not address the GHG emissions or substantially eliminate the waste
coal. There are also ancillary economic benefits in maintaining a dispatchable
generating facility in VCHEC and increasing economic activity in southwest Virginia,
Waste coal combustion incentivization should be used as a point of comparison for other
proposals to reduce GHG emissions, remediate environmental hazards or create
economic development opportunities in southwest Virginia.

17




   
 

18 
 

2. The Commonwealth should pursue all suitable federal funding opportunities for 
remediation efforts. 
 

3. Virginia Energy will continue to monitor technological advances or market developments 
that open new pathways to address waste coal and report such developments, including 
the prospects for critical mineral extraction from waste coal. 
 

4. In the event that further study is deemed necessary to provide greater detail on the GHG 
emissions and other environmental impacts associated with waste coal and its 
combustion, a more detailed technical study, to include field testing of waste coal piles, 
could be conducted. Available funding should be adjusted to reflect the actual 
requirements and expectations set out by the General Assembly. 

Conclusion 
Waste coal piles present a serious and ongoing hazard to the environment and public safety in 
southwest Virginia. The remediation of waste coal piles through encapsulation and similar projects 
protects water quality but has a weaker effect on emissions reduction and does not ultimately 
eliminate the waste coal. Currently, waste coal combustion is the only viable means to entirely 
remove the waste coal piles and it creates a significant emissions benefit. Waste coal combustion 
appears to have great potential to reduce environmental harms and is deserving of consideration 
and comparison with other efforts to enhance the environment and the economy of the 
Commonwealth. 

Appendix 1 TRC Report 

Appendix 2 TRC Conceptual Recommendations to Improve CO2e 
Emissions Data from Abandoned GOB Piles in VA 
 

2. The Commonwealth should pursue all suitable federal funding opportunities for
remediation efforts.

3. Virginia Energy will continue to monitor technological advances or market developments
that open new pathways to address waste coal and report such developments, including
the prospects for critical mineral extraction from waste coal.

4. Inthe event that further study is deemed necessary to provide greater detail on the GHG
emissions and other environmental impacts associated with waste coal and its
combustion, a more detailed technical study, to include field testing of waste coal piles,
could be conducted. Available funding should be adjusted to reflect the actual
requirements and expectations set out by the General Assembly.

Conclusion

Waste coal piles present a serious and ongoing hazard to the environment and public safety in
southwest Virginia. The remediation of waste coal piles through encapsulation and similar projects
protects water quality but has a weaker effect on emissions reduction and does not ultimately
eliminate the waste coal. Currently, waste coal combustion is the only viable means to entirely
remove the waste coal piles and it creates a significant emissions benefit. Waste coal combustion
appears to have great potential to reduce environmental harms and is deserving of consideration
and comparison with other efforts to enhance the environment and the economy of the
Commonwealth.

Appendix 1 TRC Report

Appendix 2 TRC Conceptual Recommendations to Improve CO2e
Emissions Data from Abandoned GOB Piles in VA

18




 

1 
 

 

Virginia Energy 

Net Air Emission Benefits from the 

Remediation of Abandoned Coal Refuse Piles 

December 2023 

 
Robert G. Fraser, QEP and Patrick Fennell, PE, TRC Environmental Inc. 

 

Executive Summary 
 

Abandoned and managed coal refuse piles represent a legacy environmental hazard in Virginia as well 

as throughout the Appalachian coal producing region of the United States. Due to the sheer magnitude 

of legacy coal refuse in Virginia and Appalachia in general, existing coal refuse piles represent a well-

documented threat to the natural environment1. While the adverse impacts of rainwater runoff are well 

documented, the inventory of abandoned and, to a lesser extent, managed coal refuse also represents 

a substantial ongoing source of uncontrolled air emissions, including planet warming greenhouse gases 

and other fugitive air pollutants2. As measured in terms of carbon dioxide equivalent (CO2e), annual 

greenhouse gas (GHG) emissions due to legacy coal refuse piles can no longer be ignored simply 

because the material has were historically deposited, were of little commercial value, and/or the 

companies that deposited this waste as much as a century ago are long gone, leaving behind only a 

lasting legacy of pollution. Virginia Department of Energy (Virginia Energy) sponsored this study 

originally to evaluate Abandoned Mine Land (AML) sites for which the Commonwealth is responsible.  

However, upon further discussion it was agreed that consideration should also be given to air 

emissions potential of post 1977 Surface Mining Control and Reclamation Act (SMCRA) waste coal 

surface impoundments in VA, in order to characterize the full scope and extant of all coal refuse in the 

State. SMCRA created an Abandoned Mine Land fund to pay for the cleanup of mine lands abandoned 

before the passage of the statute in 1978. 80% of AML funds are distributed to states with an approved 

reclamation program to fund reclamation activities. The remaining 20% are used to respond to emergencies 

such as landslides, land subsidence and fires, and to carry out high priority cleanups in states without 

approved programs. Virginia Energy is primarily responsible for ultimate reclamation of the estimated 

14,956,951 cubic yards (~ 16 million tons) of pre-SMCRA coal refuse abandoned in VA that is subject 

to AML funding.  However, it is also useful to consider Virginia Energy’s estimate that an additional 64 

million cubic yards of coal refuse is also being managed in regulated impoundments, for a total of about 80 

million cubic yards of total VA coal refuse potentially emitting GHG (or other) air emissions to the 

environment (VA DOE Report, 12/1/22 32).  

 

This study seeks to characterize the magnitude of GHG and other air pollutants being emitted via the 

air pathway to the environment every day from abandoned and managed coal refuse piles in Virginia. It 

is well documented that abandoned coal refuse piles are subject to a natural oxidation process leading 

to a process of spontaneous combustion, which releases fine particulate and products of incomplete 

combustion including carbon dioxide (CO2) and methane (CH4) to the atmosphere3. Fugitive (area-

source) criteria and hazardous air pollutant emissions from abandoned coal refuse sites affect air 

quality locally as well as GHG emissions globally. The gradual emission of GHGs (such as methane 

and CO2) from the natural process of partial oxidation of existing abandoned coal refuse, if unabated, 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

Virginia Energy
Net Air Emission Benefits from the

Remediation of Abandoned Coal Refuse Piles
December 2023

Robert G. Fraser, QEP and Patrick Fennell, PE, TRC Environmental Inc.

Executive Summary

Abandoned and managed coal refuse piles represent a legacy environmental hazard in Virginia as well
as throughout the Appalachian coal producing region of the United States. Due to the sheer magnitude
of legacy coal refuse in Virginia and Appalachia in general, existing coal refuse piles represent a well-
documented threat to the natural environment’. While the adverse impacts of rainwater runoff are well
documented, the inventory of abandoned and, to a lesser extent, managed coal refuse also represents
a substantial ongoing source of uncontrolled air emissions, including planet warming greenhouse gases
and other fugitive air pollutants’. As measured in terms of carbon dioxide equivalent (COze), annual
greenhouse gas (GHG) emissions due to legacy coal refuse piles can no longer be ignored simply
because the material has were historically deposited, were of little commercial value, and/or the
companies that deposited this waste as much as a century ago are long gone, leaving behind only a
lasting legacy of pollution. Virginia Department of Energy (Virginia Energy) sponsored this study
originally to evaluate Abandoned Mine Land (AML) sites for which the Commonwealth is responsible.
However, upon further discussion it was agreed that consideration should also be given to air
emissions potential of post 1977 Surface Mining Control and Reclamation Act (SMCRA) waste coal
surface impoundments in VA, in order to characterize the full scope and extant of all coal refuse in the
State. SMCRA created an Abandoned Mine Land fund to pay for the cleanup of mine lands abandoned
before the passage of the statute in 1978. 80% of AML funds are distributed to states with an approved
reclamation program to fund reclamation activities. The remaining 20% are used to respond to emergencies
such as landslides, land subsidence and fires, and to carry out high priority cleanups in states without
approved programs. Virginia Energy is primarily responsible for ultimate reclamation of the estimated
14,956,951 cubic yards (~ 16 million tons) of pre-SMCRA coal refuse abandoned in VA that is subject
to AML funding. However, it is also useful to consider Virginia Energy's estimate that an additional 64
million cubic yards of coal refuse is also being managed in regulated impoundments, for a total of about 80
million cubic yards of total VA coal refuse potentially emitting GHG (or other) air emissions to the
environment (VA DOE Report, 12/1/22 ®)

This study seeks to characterize the magnitude of GHG and other air pollutants being emitted via the
air pathway to the environment every day from abandoned and managed coal refuse piles in Virginia. It
is well documented that abandoned coal refuse piles are subject to a natural oxidation process leading
to a process of spontaneous combustion, which releases fine particulate and products of incomplete
combustion including carbon dioxide (CO2) and methane (CH,) to the atmosphere®. Fugitive (area-
source) criteria and hazardous air pollutant emissions from abandoned coal refuse sites affect air
quality locally as well as GHG emissions globally. The gradual emission of GHGs (such as methane

and COz) from the natural process of partial oxidation of existing abandoned coal refuse, if unabated,
1




 

2 
 

 

will remain virtually “forever emitters” of GHG and other air pollutants due to the sheer quantities of coal 

refuse in the VA inventories. When characterizing potential adverse air quality emissions from 

abandoned coal refuse piles, it is particularly useful to compare potential in-situ annual and potential 

lifetime air pollution impacts with the highly controlled and well documented air emissions from 

permanently remediating an equivalent annual of coal refuse by the reclamation-to-energy industry. For 

purposes of this study, we have estimated possible emissions assuming that post SMCRA waste coal 

impoundments likely also emit air pollutants at a similar rate.  

 
The Appalachian region has relied for years on the coal refuse reclamation-to-energy industry to 

permanently remediate abandoned coal mining waste, which represents a cost-effective and permanent 

solution to this significant environmental problem4. Virginia has been permanently remediating existing 

in-state GOB (“Garbage of Bituminous”) pre SMCRA abandoned waste coal piles by responsibly 

destroying them while recovering needed energy via controlled combustion at the state-of-the-art Virginia 

City Hybrid Energy Center (VCHEC). According to representatives of VCHEC, the facility accepts both 

pre-SMCRA and post SMCRA coal refuse; the global GHG budget makes no such distinction.  In 

addition to addressing the multitude of soil and water environmental benefits obtained by permanent 

removal (total remediation) of these existing legacy tailings piles and managed impoundments, as cited in 

prior studies, the highly controlled combustion-remediation of coal refuse eliminates its ability to emit 

additional air pollutants every year, as it has since being originally piled. Combustion of coal refuse in a 

highly controlled manner in Virginia during 2022 permanently removed an estimated 299,000 tons of 

actively emitting abandoned coal refuse from the global emission inventory every year5, plus another 

319,000 tons of post SMCRA coal refuse. There is no question that coal refuse reclamation-to-energy 

plants, by permanently breaking the fossil GHG decomposition emission chain, also emit CO2. It is 

therefore the purpose of this study to numerically compare air quality and GHG emissions from ongoing 

permanent remediation of coal refuse in facilities like VCHEC to the uncontrolled and ongoing air 

emissions of allowing existing coal refuse piles and impoundments to continue emitting methane and 

other air pollutants in situ (including potential re-planting alternatives). 

 

This study estimates that coal refuse destruction by the reclamation-to-energy industry in Virginia alone 

reduces the equivalent net GHG emissions that would otherwise be emitted from the same amount of 

coal refuse left in situ by at least < 2.7 Million tons > of CO2e in a single year, and as much as < 32.5 

million tons > of CO2e over an assumed lifecycle vs, coal refuse piles left in-situ. The emission factors 

characterized in this report represent an average of annual GHG emissions for portions of GOB piles 

from various emission factors cited from the literature on an annual basis.  However, that same GOB 

pile will continue to emit CO2e the next year, and the next year and so on until all of its total carbon 

content has been completely diminished, whereas the coal refuse-to-energy industry destroys its ability 

to emit any more CO2e forever. For this reason, we multiplied annual emissions from a typical GOB Pile 

by a factor of ten in an effort to conservatively characterize its eventual potential lifetime emissions for 

comparison with the net benefit of permanent destruction once and for all. The Lifetime Potential CO2e 

emissions from a GOB Pile abandoned in situ is an area that would benefit from further study.  The 

numerical GHG emissions reduction over many years as CO2e is summarized in Table ES-1 below. 

The avoided GHG emissions estimated from the permanent remediation of abandoned coal refuse in 

Virginia are presented below in (red)6,7,8. 

  

 

 

 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

will remain virtually “forever emitters" of GHG and other air pollutants due to the sheer quantities of coal
refuse in the VA inventories. When characterizing potential adverse air quality emissions from
abandoned coal refuse piles, it is particularly useful to compare potential in-situ annual and potential
lifetime air pollution impacts with the highly controlled and well documented air emissions from
permanently remediating an equivalent annual of coal refuse by the reclamation-to-energy industry. For
purposes of this study, we have estimated possible emissions assuming that post SMCRA waste coal
impoundments likely also emit air pollutants at a similar rate.

The Appalachian region has relied for years on the coal refuse reclamation-to-energy industry to
permanently remediate abandoned coal mining waste, which represents a cost-effective and permanent
solution to this significant environmental problem’. Virginia has been permanently remediating existing
in-state GOB ("Garbage of Bituminous") pre SMCRA abandoned waste coal piles by responsibly
destroying them while recovering needed energy via controlled combustion at the state-of-the-art Virginia
City Hybrid Energy Center (VCHEC). According to representatives of VCHEC, the facility accepts both
pre-SMCRA and post SMCRA coal refuse; the global GHG budget makes no such distinction. In
addition to addressing the multitude of soil and water environmental benefits obtained by permanent
removal (total remediation) of these existing legacy tailings piles and managed impoundments, as cited in
prior studies, the highly controlled combustion-remediation of coal refuse eliminates its ability to emit
additional air pollutants every year, as it has since being originally piled. Combustion of coal refuse in a
highly controlled manner in Virginia during 2022 permanently removed an estimated 299,000 tons of
actively emitting abandoned coal refuse from the global emission inventory every year®, plus another
319,000 tons of post SMCRA coal refuse. There is no question that coal refuse reclamation-to-energy
plants, by permanently breaking the fossil GHG decomposition emission chain, also emit COs. It is
therefore the purpose of this study to numerically compare air quality and GHG emissions from ongoing
permanent remediation of coal refuse in facilities like VCHEC to the uncontrolled and ongoing air
emissions of allowing existing coal refuse piles and impoundments to continue emitting methane and
other air pollutants in situ (including potential re-planting alternatives).

This study estimates that coal refuse destruction by the reclamation-to-energy industry in Virginia alone
reduces the equivalent net GHG emissions that would otherwise be emitted from the same amount of
coal refuse left in situ by at least < 2.7 Million tons > of COze in a single year, and as much as < 32.5
million tons > of CO2e over an assumed lifecycle vs, coal refuse piles left in-situ. The emission factors
characterized in this report represent an average of annual GHG emissions for portions of GOB piles
from various emission factors cited from the literature on an annual basis. However, that same GOB
pile will continue to emit COze the next year, and the next year and so on until all of its total carbon
content has been completely diminished, whereas the coal refuse-to-energy industry destroys its ability
to emit any more CO2¢ forever. For this reason, we multiplied annual emissions from a typical GOB Pile
by a factor of ten in an effort to conservatively characterize its eventual potential lifetime emissions for
comparison with the net benefit of permanent destruction once and for all. The Lifetime Potential COze
emissions from a GOB Pile abandoned in situ is an area that would benefit from further study. The
numerical GHG emissions reduction over many years as CO,¢ is summarized in Table ES-1 below.
The avoided GHG emissions estimated from the permanent remediation of abandoned coal refuse in
Virginia are presented below in (red)°7°,




 

3 
 

 

Table ES-1 

 
 

         
 

Pollutant 
Global 

Warming 
Potential(2) 

Weathering + Burning/Smoldering 
Typical GOB In-Situ 

618,510 Tons of Coal Refuse 
GOB Combusted by  

VCHEC CFB Boilers - 2022 

Net Air Quality Benefit of Remediation via 
Controlled Combustion 

 (tons) 

Emission 
Factor 

 (ton/ton 
Coal 

Refuse 
Oxidizing) 

Estimated  
Emissions 

for 618,510 
tons of 

Coal Refuse 
Weathering 

 (tons) 

Estimated  
Emissions 

for 
618,510 
tons of 

Coal 
Refuse 

Smoldering 
/ Burning 

 (tons) 

Estimated 
Total 

Annual 
Emissions 
Associated 

with  
618,510 
tons of 

GOB 
Remaining 

in-situ 
(tons) 

Assumed 1-
yr GOB Pile 
Emissions 
Multiplied 

by 10 to 
reflect 

Potential  
Lifecycle 

Emissions 
to 

Completely 
Decompose  

618,510 
tons  (tons) 

Emission 
Factor 

 
(lb/MMBtu) 

Estimated 
VCHEC Coal 
Refuse GHG 

Emissions 
Attributed 

to 
Remediation 

of 618,510 
tons   

 (tons) 

Net 
Comparison 

based on 
Estimated 
Emissions 
per ton of 

Coal Refuse 
Being 

Oxidized in 
Situ 

 (tons) 

Net 
Comparison 

based on 
Estimated 
Potential 
Lifecycle 

Emissions 
 (tons) 

Tons of 
Estimated 
Potential 

Lifecycle net 
GHG 

Emissions 
(as CO2e) 
per ton of 

Waste Coal 
Permanently 
neutralized 

CO2 1 1.180⁽⁴⁾ 14,602 729,842 744,443.6 7,298,418 181.5⁽⁵ ̛ ⁶⁾ 645,506 (84,336) (6,652,912) (10.8) 

CH4 25 0.163 (33) 2,016 100,817 102,833.5 1,008,171 3.37E-2⁽⁵ ̛ ⁶⁾ 120 (100,697) (1,008,051) (1.6) 

CO2e     65,010 3,250,270 3,315,280 33,152,804   648,505 (2,666,775) (32,504,299) (52.6) 

                        
1. From VCHEC 2022 

2. 40 CFR 98 Subpart A Table A-1       

3. Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste Dumps in Silesia, Poland, Fabiańska M, Ciesielczuk J, Nádudvari Á, Misz-Kennan M, Kowalski A, 
Kruszewski Ł. Environ Geochem Health. 2019 Apr;41(2):575-601. doi: 10.1007/s10653-018-0153-5. Epub 2018 Jul 24. 

4. Gielisch H, Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. Environmental Risk Assessment and Remediation 2017; 2(1): 5-8; 

  https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-problem-8871.html  

33  ARIPPA substituted value for CH4 reduced from 0.7625 to 0.163, substituted to add conservatism and consistency with reported values    

                        

 

 

The coal refuse to reclamation industry in VA (VCHEC) permanently remediated a total of 618,510 tons 

of total coal refuse in 2022.  The values presented in Table ES-1 show that permanent remediation of 

this amount of coal refuse in Virginia by the coal refuse reclamation-to-energy is responsible for as 

much as the net lifecycle estimated reduction of over 32  million tons of CO2e that might otherwise 

have eventually been emitted to the Global Warming global budget. On this basis, similar net lifecycle 

CO2e emissions to the environment will continue to be reduced by a similar amount every year that 

permanent remediation at VCHEC continues at comparable levels. According to VCHEC 

representatives, VCHEC is capable of significantly increased capacity firing VA Coal refuse.  Coal 

refuse reclamation-to-energy plants are very efficient in terms of converting nearly 100% of the 

hydrocarbon component of coal refuse to CO2 while efficiently producing useful power.  When they do 

so, they destroy the ability of that amount of coal refuse to emit that same carbon as methane rather 

than CO2, including over many more years.  

 
The net climate change benefit of the coal refuse reclamation-to-energy industry is that of converting 

methane that would otherwise be eventually emitted from waste coal decomposition over many years 

directly and efficiently to CO2. Methane is considered to be about 81 times more potent in terms 

of warming the climate in the near-term (during the next 20 years after its release to the 

atmosphere)9, and when normalized over 100 years for direct comparison to CO2 emissions as 

standardized by the U.S. Environmental Protection Agency (USEPA), is characterized as 25-28 times 

more potent of a greenhouse gas over the long-term10.  For this study we have assumed that CH4 is 

only 25 times as potent a GHG as CO2. The permanent elimination of naturally occurring methane 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

Table ES-1
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‘oe oe || Ee vrai | rematen | esteee |e
Tm | oni |
 eereereepmaramn mm a hn

The coal refuse to reclamation industry in VA (VCHEC) permanently remediated a total of 618,510 tons
of total coal refuse in 2022. The values presented in Table ES-1 show that permanent remediation of
this amount of coal refuse in Virginia by the coal refuse reclamation-to-energy is responsible for as
much as the net lifecycle estimated reduction of over 32 million tons of COze that might otherwise
have eventually been emitted to the Global Warming global budget. On this basis, similar net lifecycle
C02¢ emissions to the environment will continue to be reduced by a similar amount every year that
permanent remediation at VCHEC continues at comparable levels. According to VCHEC
representatives, VCHEC is capable of significantly increased capacity firing VA Coal refuse. Coal
refuse reclamation-to-energy plants are very efficient in terms of converting nearly 100% of the
hydrocarbon component of coal refuse to CO2while efficiently producing useful power. When they do
so, they destroy the ability of that amount of coal refuse to emit that same carbon as methane rather
than COz, including over many more years.

The net climate change benefit of the coal refuse reclamation-to-energy industry is that of converting
methane that would otherwise be eventually emitted from waste coal decomposition over many years
directly and efficiently to CO2. Methane is considered to be about 81 times more potent in terms
of warming the climate in the near-term (during the next 20 years after its release to the
atmosphere)’, and when normalized over 100 years for direct comparison to CO, emissions as
standardized by the U.S. Environmental Protection Agency (USEPA), is characterized as 25-28 times
more potent of a greenhouse gas over the long-term. For this study we have assumed that CHs is
only 25 times as potent a GHG as CO”. The permanent elimination of naturally occurring methane

3




 

4 
 

emissions from existing coal refuse piles and impoundments (as a virtually forever emission source) 

has a much greater benefit to reversing global climate change than the one-time and final conversion of 

existing coal refuse to CO2 and useful energy. As such, it is important to compare the bottom row in 

Table 1, which sums net GHG emissions in units of net CO2e per ton remediated comparing lifecycle 

emissions of the same amount of coal refuse either allowed to remain in situ passively emitting 

uncontrolled air pollutants or remediated forever via responsible and highly regulated energy recovery 

by the coal refuse reclamation-to-energy industry. 

 

The coal refuse reclamation-to-energy industry was found to eliminate as much as 52 net tons of 

potential lifecycle CO2e emissions per ton of Virginia GOB coal refuse that it permanently eliminates 

from the environment and converts almost completely to CO2 and useful energy. Emissions of CH4 and 

CO2 from waste coal decomposition would otherwise continue to be released into the environment over 

the coal refuse emission lifecycle. In 2022, VCHEC combusted 618,510 tons of total coal refuse, 

resulting in as much as a potential net lifecycle reduction of CO2e that might have otherwise eventually 

been emitted uncontrolled from coal refuse of (32,504,299) net tons CO2e reduced. On a per ton of 

coal refuse basis, a net reduction of at least (2,666,775) tons of potential CO2e is being reduced by 

VCHEC annually (while leaving residual GOB in situ to continue emitting). According to the facility, 

VCHEC has additional capacity to remediate more. Operations at these levels will yield proportional 

levels of net environmental benefits every year that this industry continues its important mine-land and 

waste coal reclamation mission.  

 

As demonstrated in this study, combusting the same quantity of coal refuse permanently remediated by 

the coal refuse reclamation-to-energy industry in 2022 (618,510 tons) has been estimated to result in a 

potential lifecycle net CO2e reduction benefit of as much as 32.5 million net tons of lifecycle CO2e 

emissions EVERY YEAR that it does so. Very simply, while the combustion of coal refuse certainly does 

emit the greenhouse gas CO2 now, doing so avoids the more harmful ongoing GHG emissions of the 

potent greenhouse gas methane that would otherwise have been emitted during that same GOB Pile’s 

lifecycle from abandoned coal refuse if allowed to remain in existing impoundments or piles. It is very 

challenging to think of another economically viable and environmentally beneficial technology of any kind 

that could come close to providing a net CO2e benefit of this magnitude, at little cost to the 

Commonwealth of Virginia, while permanently eliminating further collateral environmental problems 

created by coal refuse, as part of a national strategy to achieve “net zero” GHG emissions by 2050. 

 

Introduction 

It has long been recognized that the enormous inventory of coal refuse piles abandoned by the legacy 

coal mining industry in Appalachia represents an ongoing ecological threat to the environment. 

Adverse environmental impacts to soil, stormwater runoff, surface water, and groundwater from these 

un-remediated, abandoned environmental hazards are well documented11. Comparatively fewer 

examinations of the adverse air quality and CO2e greenhouse gas emission impacts of un-remediated 

abandoned refuse piles have been identified in the literature. It is the premise of this study that post-

SMCRA impoundments are designed to mitigate impacts to soil and water resources, but likely also 

may emit air pollutants at some as-yet undocumented rate.  

 

During the 1970s through the 1990s, environmental advocates and government agencies promoted 

and enabled investment in coal refuse reclamation-to-energy facilities capable of remediating 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

emissions from existing coal refuse piles and impoundments (as a virtually forever emission source)
has a much greater benefit to reversing global climate change than the one-time and final conversion of
existing coal refuse to CO2 and useful energy. As such, it is important to compare the bottom row in
Table 1, which sums net GHG emissions in units of net CO.e per ton remediated comparing lifecycle
emissions of the same amount of coal refuse either allowed to remain in situ passively emitting
uncontrolled air pollutants or remediated forever via responsible and highly regulated energy recovery
by the coal refuse reclamation-to-energy industry,

The coal refuse reclamation-to-energy industry was found to eliminate as much as 52 net tons of
potential lifecycle COz¢ emissions per ton of Virginia GOB coal refuse that it permanently eliminates
from the environment and converts almost completely to CO2 and useful energy. Emissions of CHs and
CO; from waste coal decomposition would otherwise continue to be released into the environment over
the coal refuse emission lifecycle. In 2022, VCHEC combusted 618,510 tons of total coal refuse,
resulting in as much as a potential net lifecycle reduction of COze that might have otherwise eventually
been emitted uncontrolled from coal refuse of (32,504,299) net tons COze reduced. On a per ton of
coal refuse basis, a net reduction of at least (2,666,775) tons of potential COze is being reduced by
VCHEC annually (while leaving residual GOB in situ to continue emitting). According to the facility,
VCHEC has additional capacity to remediate more. Operations at these levels will yield proportional
levels of net environmental benefits every year that this industry continues its important mine-land and
waste coal reclamation mission

‘As demonstrated in this study, combusting the same quantity of coal refuse permanently remediated by
the coal refuse reclamation-to-energy industry in 2022 (618,510 tons) has been estimated to result in a
potential lifecycle net COze reduction benefit of as much as 32.5 million net tons of lifecycle COze
emissions EVERY YEAR that it does so. Very simply, while the combustion of coal refuse certainly does
emit the greenhouse gas CO2 now, doing so avoids the more harmful ongoing GHG emissions of the
potent greenhouse gas methane that would otherwise have been emitted during that same GOB Pile’s
lifecycle from abandoned coal refuse if allowed to remain in existing impoundments or piles. It is very
challenging to think of another economically viable and environmentally beneficial technology of any kind
that could come close to providing a net COze benefit of this magnitude, at little cost to the
Commonwealth of Virginia, while permanently eliminating further collateral environmental problems
created by coal refuse, as part of a national strategy to achieve “net zero" GHG emissions by 2050

Introduction

Ithas long been recognized that the enormous inventory of coal refuse piles abandoned by the legacy
coal mining industry in Appalachia represents an ongoing ecological threat to the environment.
Adverse environmental impacts to soil, stormwater runoff, surface water, and groundwater from these
un-remediated, abandoned environmental hazards are well documented". Comparatively fewer
‘examinations of the adverse air quality and CO2e greenhouse gas emission impacts of un-remediated
abandoned refuse piles have been identified in the literature. It is the premise of this study that post-
SMCRA impoundments are designed to mitigate impacts to soil and water resources, but likely also
may emit air pollutants at some as-yet undocumented rate.

During the 1970s through the 1990s, environmental advocates and government agencies promoted
and enabled investment in coal refuse reclamation-to-energy facilities capable of remediating

4




 

5 
 

abandoned coal refuse by recovering the useful thermal energy of this abandoned waste material to 

produce needed electricity. At present, the Virginia City Hybrid Energy Center (VCHEC) is currently 

(CY2022) permanently remediating an estimated 618,510 tons of Virginia coal refuse every year, and 

is capable of processing more in the future. Unfortunately, lack of understanding that such coal refuse 

reclamation-to-energy facilities operate, in large part, to address legacy environmental damage in 

Virginia has become confused with the environmental movement to shutter utility-scale coal-fired 

electric generating units (EGU’s).  

 

Today, we broadly recognize the goal of achieving “net zero” GHG emissions by 2040-205012. In 

recent years, there has been a groundswell of public sentiment that coal combustion should be phased 

out of existence in favor of renewables that do not emit the greenhouse gas CO2. Lost in the 

translation is the unique environmental role, including important net reductions in air pollutants and 

GHG emissions, provided by the coal refuse reclamation-to-energy industry. While the industry 

continues to help reverse coal refuse pile runoff pollution to water and soil, it is now incumbent to re- 

evaluate this industry in the context of achieving net GHG reductions as part of the fight to reduce 

anthropogenic contributions to climate change. This statement is likely counter-intuitive, however 

abandoned waste coal in Virginia emits the very potent greenhouse gas methane over its lifecycle, 

which will continue to frustrate efforts to attain net zero GHG emissions by 2050, since left in-situ 

legacy waste coal piles are essentially “forever sources” of CO2e. This chain can only be practically 

broken by re-mining waste coal and permanently destroying this source of methane via efficient 

combustion to the much less potent GHG CO2, once and for all. 
 

This study seeks to document the coal refuse reclamation-to-energy industry’s significant contribution 

to the net reduction of global CO2e concentrations by permanently remediating abandoned and 

managed coal refuse in Virginia. The coal refuse reclamation-to-energy industry has found a way to 

finance the permanent cleanup of abandoned coal refuse, reducing presently occurring emissions of 

anthropogenic methane (a very potent GHG), while also displacing net GHG emissions from other 

fossil generation sources actively being phased out. Absent the coal refuse reclamation-to-energy 

industry, legacy coal refuse piles would remain essentially abandoned to the environment and will 

frustrate regional air quality and climate change goals for multiple additional generations as the 

abandoned piles themselves continue to emit products of incomplete combustion, CO2, and the potent 

greenhouse gas methane13. Based on published emission estimates from the literature, the authors 

have compared CO2e emissions from the remediation of 618,510 tons of waste coal annually (as at 

present) by the coal refuse reclamation-to-energy industry in Virginia vs. lifecycle CO2e emissions 

being naturally emitted to the environment by not remediating that same amount of coal refuse. The 

emissions of methane from abandoned coal refuse piles, based on measurements by USEPA14 and 

others, are at least 25 times more potent GHG emissions than the CO2 emitted from controlled and 

permanent combustion of coal refuse for remediation. This study indicates that, based on published 

literature, the coal refuse reclamation-to-energy industry in Virginia plays a very important role in 

reducing global and regional emissions of CO2e. 

 

Background 

The Eastern US Coal Mines fueled America’s Industrial Revolution of the 1800s as well as 

electricity demand through the 1990s. Eastern Bituminous coal from SW VA was mined as a 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

abandoned coal refuse by recovering the useful thermal energy of this abandoned waste material to
produce needed electricity. At present, the Virginia City Hybrid Energy Center (VCHEC) is currently
(CY2022) permanently remediating an estimated 618,510 tons of Virginia coal refuse every year, and
is capable of processing more in the future. Unfortunately, lack of understanding that such coal refuse
reclamation-to-energy facilities operate, in large part, to address legacy environmental damage in
Virginia has become confused with the environmental movement to shutter utility-scale coal-fired
electric generating units (EGU's).

Today, we broadly recognize the goal of achieving “net zero” GHG emissions by 2040-2050". In
recent years, there has been a groundswell of public sentiment that coal combustion should be phased
out of existence in favor of renewables that do not emit the greenhouse gas COz. Lost in the
translation is the unique environmental role, including important net reductions in air pollutants and
GHG emissions, provided by the coal refuse reclamation-to-energy industry. While the industry
continues to help reverse coal refuse pile runoff pollution to water and soil, it is now incumbent to re-
evaluate this industry in the context of achieving net GHG reductions as part of the fight to reduce
anthropogenic contributions to climate change. This statement is likely counter-intuitive, however
abandoned waste coal in Virginia emits the very potent greenhouse gas methane over its lifecycle,
which will continue to frustrate efforts to attain net zero GHG emissions by 2050, since left in-situ
legacy waste coal piles are essentially “forever sources’ of CO,e. This chain can only be practically
broken by re-mining waste coal and permanently destroying this source of methane via efficient
combustion to the much less potent GHG COz, once and for all

This study seeks to document the coal refuse reclamation-to-energy industry's significant contribution
to the net reduction of global CO.e concentrations by permanently remediating abandoned and
managed coal refuse in Virginia. The coal refuse reclamation-to-energy industry has found a way to
finance the permanent cleanup of abandoned coal refuse, reducing presently occurring emissions of
anthropogenic methane (a very potent GHG), while also displacing net GHG emissions from other
fossil generation sources actively being phased out. Absent the coal refuse reclamation-to-energy
industry, legacy coal refuse piles would remain essentially abandoned to the environment and will
frustrate regional air quality and climate change goals for multiple additional generations as the
abandoned piles themselves continue to emit products of incomplete combustion, CO, and the potent
greenhouse gas methane"®. Based on published emission estimates from the literature, the authors
have compared COze emissions from the remediation of 618,510 tons of waste coal annually (as at
present) by the coal refuse reclamation-to-energy industry in Virginia vs. lifecycle CO,e emissions
being naturally emitted to the environment by not remediating that same amount of coal refuse. The
emissions of methane from abandoned coal refuse piles, based on measurements by USEPA" and
others, are at least 25 times more potent GHG emissions than the CO2 emitted from controlled and
permanent combustion of coal refuse for remediation. This study indicates that, based on published
literature, the coal refuse reclamation-to-energy industry in Virginia plays a very important role in
reducing global and regional emissions of COz<.

Background

The Eastern US Coal Mines fueled America’s Industrial Revolution of the 1800s as well as.
electricity demand through the 1990s. Eastern Bituminous coal from SW VA was mined as a

5




 

6 
 

low-cost fuel to produce steam power and later electricity for the factories and lifestyle that built 

the American economy. 

 

The early technology of burning coal on stoker grates created demand for “stoker coal”, meaning 

lump coal with minimal fines and tramp material content. To produce stoker coal, run-of-mine 

coal was processed and sized, including removal and discard of inert material (such as pyrites 

and rock) as well as coal fines prior to shipment. In every case, coal mined in Virginia needed to 

be transported to its point of use via some combination of barges, railroads and trucks. 

Depending on logistics, transportation often cost as much as the coal itself. These economics 

drove the practice of “coal washing” prior to transportation as a cost reduction measure. When 

mining coal, the useful fuel was often contaminated with naturally occurring inert materials such 

as soil, rocks and stone. There was no value to the end user in paying to ship inert, non-

combustible impurities that were mined together with the coal, and the inert content also lowered 

its heating value which made the delivered product less desirable/valuable. For these reasons, it 

became economically advantageous to “wash” out as much of these “fines” and inert 

contaminants as practical prior to shipment. It was also noted that much of the sulfur content in 

as-mined coal was contained within the inert pyrites, and that pre-washing the coal prior to 

shipment also reduced its sulfur content.  

 

In coal washing, a specific gravity separation was performed to remove unwanted fines and 

heavier inert materials such as shale rock and pyrites as unmarketable waste. After removal of 

these fines and incombustible inert materials, the coal to be shipped became more valuable in 

that it contained more British thermal units (Btu) per ton shipped, less fines, ash and sulfur. The 

result was that the waste materials from overburden, size separation and washing prior to 

shipment had little heating value and no residual commercial value; they were simply discarded 

as unlined landfills near the mine or preparation plant as waste over approximately 100 years of 

mining operations, creating enormous legacy coal refuse piles in Virginia as well as throughout 

Appalachia. 

 

Coal mining refuse (a.k.a. culm, gob, tailings, boney, silt, among other names) tends to be 

wetter, as fines retain more moisture, and higher in ash and sulfur content than the native coal 

originally mined. The typical remaining heating value of coal refuse, especially after years of 

weathering, is at least less than half the specification for steam coal, averaging only about 5,750 

Btu/lb (USEPA AP-42) vs. about 11,000-12,000 Btu/lb for commercial Eastern Bituminous coal). 

We note that the actual heating value of coal refuse varies pile-to-pile and mine-to-mine, and 

even varies within piles as various layers were deposited on top of each other over many years. 

Due to this variability, coal refuse can range from less than 3,000 Btu/lb to over 7,000 Btu/lb.  

We have therefore assumed the US EPA AP-42 value of 5,750 Btu/lb as representative of coal 

refuse generally.   

 

Up until the late 1970s, there was no industrial coal combustion technology capable of utilizing 

low heating value coal refuse. It was, therefore, a true waste byproduct with no economic value 

to anyone. As a result, coal refuse was simply landfilled, piled up and abandoned to the 

elements. Under the Surface Mining Control and Reclamation Act of 1977 (SMCRA), 

landowners and companies responsible for abandoning legacy coal refuse piles are no longer 

liable for remediating these abandoned piles that now litter the historic coal fields of Virginia. 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

low-cost fuel to produce steam power and later electricity for the factories and lifestyle that built
the American economy.

The early technology of burning coal on stoker grates created demand for “stoker coal”, meaning
lump coal with minimal fines and tramp material content. To produce stoker coal, run-of-mine
coal was processed and sized, including removal and discard of inert material (such as pyrites
and rock) as well as coal fines prior to shipment. In every case, coal mined in Virginia needed to
be transported to its point of use via some combination of barges, railroads and trucks.
Depending on logistics, transportation often cost as much as the coal itself. These economics
drove the practice of “coal washing" prior to transportation as a cost reduction measure. When
mining coal, the useful fuel was often contaminated with naturally occurring inert materials such
as soil, rocks and stone. There was no value to the end user in paying to ship inert, non-
combustible impurities that were mined together with the coal, and the inert content also lowered
its heating value which made the delivered product less desirable/valuable. For these reasons, it
became economically advantageous to “wash” out as much of these “fines” and inert
contaminants as practical prior to shipment. It was also noted that much of the sulfur content in
as-mined coal was contained within the inert pyrites, and that pre-washing the coal prior to
shipment also reduced its sulfur content.

In coal washing, a specific gravity separation was performed to remove unwanted fines and
heavier inert materials such as shale rock and pyrites as unmarketable waste. After removal of
these fines and incombustible inert materials, the coal to be shipped became more valuable in
that it contained more British thermal units (Btu) per ton shipped, less fines, ash and sulfur. The
result was that the waste materials from overburden, size separation and washing prior to
shipment had little heating value and no residual commercial value; they were simply discarded
as unlined landfills near the mine or preparation plant as waste over approximately 100 years of
mining operations, creating enormous legacy coal refuse piles in Virginia as well as throughout
Appalachia.

Coal mining refuse (a.k.a. culm, gob, tailings, boney, silt, among other names) tends to be
wetter, as fines retain more moisture, and higher in ash and sulfur content than the native coal
originally mined. The typical remaining heating value of coal refuse, especially after years of
weathering, is at least less than half the specification for steam coal, averaging only about 5,750
Btu/lb (USEPA AP-42) vs. about 11,000-12,000 Btu/lb for commercial Eastern Bituminous coal).
We note that the actual heating value of coal refuse varies pile-to-pile and mine-to-mine, and
even varies within piles as various layers were deposited on top of each other over many years.
Due to this variability, coal refuse can range from less than 3,000 Btullb to over 7,000 Btullb.
We have therefore assumed the US EPA AP-42 value of 5,750 Btullb as representative of coal
refuse generally.

Up until the late 1970s, there was no industrial coal combustion technology capable of utilizing
low heating value coal refuse. It was, therefore, a true waste byproduct with no economic value
to anyone. As a result, coal refuse was simply landfilled, piled up and abandoned to the
elements. Under the Surface Mining Control and Reclamation Act of 1977 (SMCRA),
landowners and companies responsible for abandoning legacy coal refuse piles are no longer
liable for remediating these abandoned piles that now litter the historic coal fields of Virginia.

6




 

7 
 

This pre-SMCRA abandoned coal refuse is categorized as AML (abandoned mine land) material 

in VA, and is colloquially referred to as GOB, while post SMCRA coal refuse is colloquially 

referred to as “Non-GOB waste coal”.  Importantly, the coal refuse is substantially the same 

material regardless of its date of placement, and is indistinguishable in terms of its potential to 

emit CO2e to the atmosphere as it naturally decomposes. The traditional cost of remediating just 

the existing AML piles in VA is currently estimated by Virginia Energy at more than $360 million 

to the State and Federal government, with limited resources to resolve this massive 

environmental problem. Even with 25 states expected to receive more than $11 billion in 

additional federal funding to reclaim abandoned mine land (AML) sites over the next 15 years 

under the bipartisan Infrastructure Investment and Jobs Act of 2021, this amount will be 

insufficient to even nearly fund the currently identified AML problems throughout Appalachia.16  

TRC has no case-specific CO2e estimates for Non-GOB waste impoundment air emissions, but 

for purposes of this study we consider that since the material is virtually identical that it exhibits 

similar reactivity, rates of decay and potential air emissions during impoundment.  

 

In the late 1970s, partially in response to the Arab Oil Embargo, a new technology called 

circulating fluidized bed (CFB) combustion emerged with the promise of being able to cleanly 

burn a wide range of difficult-to-burn fuels, including low Btu, high-sulfur and high inert content 

coal refuse. For the very first time, this technology enabled responsible re-mining and energy 

recycling of abandoned coal refuse piles and newly generated coal refuse while producing 

electricity for sale to pay for the permanent remediation of these legacy environmental scars. 

Since that time, the industry has remediated more than 250 million tons of polluting coal refuse 

across Appalachia. The continued operation of these coal refuse reclamation-to-energy facilities, 

including VCHEC in VA, provide ongoing environmental reclamation and clean up benefits to 

land, water, air quality and greenhouse gas emissions to the environment while offsetting the 

funding shortfall for permanent remedial cleanup of polluting legacy coal refuse piles. 

 

Permanent Coal Refuse Remediation 
 

Absent permanent remediation, the legacy abandoned coal refuse piles littering Appalachia (including 

VA) represent virtually “forever emitters” of air pollutants and greenhouse gases due to their shear depth 

and volume. Such pollutants include windblown fugitive particulate fines (referred to as the inhalable 

pollutant, PM10), hazardous air pollutants such as mercury, hydrogen sulfide or arsenic deposited as 

formerly trace constituents of mined coal, and Clean Air Act (CAA) regulated criteria air pollutants, as 

they have been for over 100 years since being originally discarded. This is an important concept. When 

a ton of coal refuse is instantly forever eliminated via useful energy recovery, it can never again emit air 

pollutants or greenhouse gases, let alone continue to contribute to acidification of soil and water 

resources. This concept has similarities to our approaches to cleanup of buried drums of hazardous 

waste or historic disposal of coal ash landfills or municipal solid waste in unlined landfills. It is because of 

the sheer magnitude of coal mine waste generated over many years that coal refuse such as Garbage of 

Bituminous (GOB) has been allowed to fill pristine valleys, create new mountains, remain abandoned in-

situ and left to subsequent generations.  

 

When considering the air emissions profile of these unmitigated coal refuse piles, it is meaningful to 

contrast them with their permanent forever destruction by the coal refuse reclamation-to-energy industry. 

We must consider the air quality benefits of permanent remediation of coal refuse under highly controlled 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

This pre-SMCRA abandoned coal refuse is categorized as AML (abandoned mine land) material
in VA, and is colloquially referred to as GOB, while post SMCRA coal refuse is colloquially
referred to as "Non-GOB waste coal’. Importantly, the coal refuse is substantially the same
material regardless of its date of placement, and is indistinguishable in terms of its potential to
‘emit COze to the atmosphere as it naturally decomposes. The traditional cost of remediating just
the existing AML piles in VA is currently estimated by Virginia Energy at more than $360 million
to the State and Federal government, with limited resources to resolve this massive
environmental problem. Even with 25 states expected to receive more than $11 billion in
additional federal funding to reclaim abandoned mine land (AML) sites over the next 15 years
under the bipartisan Infrastructure Investment and Jobs Act of 2021, this amount will be
insufficient to even nearly fund the currently identified AML problems throughout Appalachia. '®
TRC has no case-specific COze estimates for Non-GOB waste impoundment air emissions, but
for purposes of this study we consider that since the material is virtually identical that it exhibits
similar reactivity, rates of decay and potential air emissions during impoundment.

In the late 1970s, partially in response to the Arab Oil Embargo, a new technology called
circulating fluidized bed (CFB) combustion emerged with the promise of being able to cleanly
burn a wide range of difficult-to-burn fuels, including low Btu, high-sulfur and high inert content
coal refuse. For the very first time, this technology enabled responsible re-mining and energy
recycling of abandoned coal refuse piles and newly generated coal refuse while producing
electricity for sale to pay for the permanent remediation of these legacy environmental scars.
Since that time, the industry has remediated more than 250 million tons of polluting coal refuse
across Appalachia. The continued operation of these coal refuse reclamation-to-energy facilities,
including VCHEC in VA, provide ongoing environmental reclamation and clean up benefits to
land, water, air quality and greenhouse gas emissions to the environment while offsetting the
funding shortfall for permanent remedial cleanup of polluting legacy coal refuse piles.

Permanent Coal Refuse Remediation

Absent permanent remediation, the legacy abandoned coal refuse piles littering Appalachia (including
VA) represent virtually “forever emitters” of air pollutants and greenhouse gases due to their shear depth
and volume. Such pollutants include windblown fugitive particulate fines (referred to as the inhalable
pollutant, PMc), hazardous air pollutants such as mercury, hydrogen sulfide or arsenic deposited as
formerly trace constituents of mined coal, and Clean Air Act (CAA) regulated criteria air pollutants, as
they have been for over 100 years since being originally discarded. This is an important concept. When
a ton of coal refuse is instantly forever eliminated via useful energy recovery, it can never again emit air
pollutants or greenhouse gases, let alone continue to contribute to acidification of soil and water
resources. This concept has similarities to our approaches to cleanup of buried drums of hazardous
waste or historic disposal of coal ash landfills or municipal solid waste in unlined landfills. It is because of
the sheer magnitude of coal mine waste generated over many years that coal refuse such as Garbage of
Bituminous (GOB) has been allowed to fill pristine valleys, create new mountains, remain abandoned in-
situ and left to subsequent generations.

When considering the air emissions profile of these unmitigated coal refuse piles, it is meaningful to

contrast them with their permanent forever destruction by the coal refuse reclamation-to-energy industry.

We must consider the air quality benefits of permanent remediation of coal refuse under highly controlled
7




 

8 
 

CFB combustion conditions, employing USEPA Best Available [emissions] Control Technology (BACT) 

against the uncontrolled combustion pyrolysis continuously emitting air and climate pollutants within 

legacy abandoned coal refuse piles. 

 
Emissions from the coal refuse reclamation-to-energy industry are often inappropriately compared to 

traditional coal-fired electric utility generating units (EGUs); however, the coal refuse reclamation-to- 

energy industry produces fundamentally different environmental benefits than coal-fired EGUs because 

they primarily provide mine land reclamation services while co-producing useful energy.  These 

facilities do not directly compete in this regard with electric generating unit (EGU) coal-fired power 

plants, which are presently being phased out of operation largely due to their CO2 GHG contributions to 

global climate change. Those pulverized coal-fired generating units are not capable of remediating 

abandoned coal refuse to clean up the environment in the same manner as CFB boiler technology. 

Coal that is mined to produce power in pulverized coal-fired power plants has been effectively 

sequestering carbon beneath the earth for millions of years. Mining, processing, and combustion of that 

previously sequestered carbon of newly mined coal indeed re-emits long dormant CO2. Abandoned 

refuse piles, however, have already been mined and left behind as an abandoned environmental legacy 

pollutant, free to continue emitting greenhouse gases and other harmful air emissions without any 

further human intervention over hundreds of years. 

 
While air pollutants and GHGs are emitted at once during controlled combustion in a CFB boiler, those 

boilers incorporate Best Available emissions Control Technology (BACT), are optimized to achieve 

complete combustion of hydrocarbons, and are highly regulated by both state and federal air emissions 

requirements. Air emissions from abandoned coal refuse piles are not. Societal goals such as net zero 

GHG emissions by 2050 will be frustrated by this waste coal “sleeper” source of nearly continuous 

“forever” emissions of methane unless abandoned coal refuse is re-mined and permanently converted 

from a source of pollution to useful energy, enabling further displacement of newly extracted fossil fuel 

emissions. 

 
As examined quantitatively in this study, USEPA and others have measured and characterized air 

emissions from smoldering and spontaneously combusting rogue coal refuse piles17. Coal refuse energy 

recovery and permanent remediation facilities operate very responsibly, are aggressively regulated, and 

operate in continuous compliance with all applicable state and federal air quality regulations and 

standards. State and Federal Environmental Regulatory Authorities monitor these facilities to ensure that 

they do not cause or contribute to a “condition of air pollution”, while air emissions from abandoned coal 

refuse piles are unregulated and accepted as “naturally occurring” sources of air pollutant emissions. 

Their ability to slowly emit polluting emissions over enormous surface areas and almost unimaginable 

volumes constitute a source of ground-level anthropogenic air emissions that should also be evaluated 

through the lens of local air quality impacts, including Environmental Justice Communities in the 

abandoned coal fields of Appalachia. 

 
For any hydrocarbon fuel to be theoretically completely combusted to CO2 and water vapor (H2O) 

requires the ability to provide at least the ideal, or stoichiometric, air-to-fuel ratio and high combustion 

temperatures needed to completely convert the hydrocarbons in the fuel. Insufficient, off-stochiometric 

air-to-fuel ratios and/or smoldering at low temperatures cause incomplete combustion of fuel. This 

means when there is insufficient oxygen, any fossil fuel will be only partially combusted, emitting 

intermediate products of incomplete combustion such as the potent greenhouse gas methane, hydrogen 

sulfide (H2S), and likely the even more potent greenhouse gas nitrous oxide (N2O) instead of nitrogen 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

CFB combustion conditions, employing USEPA Best Available [emissions] Control Technology (BACT)
against the uncontrolled combustion pyrolysis continuously emitting air and climate pollutants within
legacy abandoned coal refuse piles.

Emissions from the coal refuse reclamation-to-energy industry are often inappropriately compared to
traditional coal-fired electric utility generating units (EGUs); however, the coal refuse reclamation-to-
energy industry produces fundamentally different environmental benefits than coal-fired EGUs because
they primarily provide mine land reclamation services while co-producing useful energy. These
facilities do not directly compete in this regard with electric generating unit (EGU) coal-fired power
plants, which are presently being phased out of operation largely due to their CO2 GHG contributions to
global climate change. Those pulverized coal-fired generating units are not capable of remediating
abandoned coal refuse to clean up the environment in the same manner as CFB boiler technology.
Coal that is mined to produce power in pulverized coal-fired power plants has been effectively
sequestering carbon beneath the earth for millions of years. Mining, processing, and combustion of that
previously sequestered carbon of newly mined coal indeed re-emits long dormant CO2. Abandoned
refuse piles, however, have already been mined and left behind as an abandoned environmental legacy
pollutant, free to continue emitting greenhouse gases and other harmful air emissions without any
further human intervention over hundreds of years.

While air pollutants and GHGs are emitted at once during controlled combustion in a CFB boiler, those
boilers incorporate Best Available emissions Control Technology (BACT), are optimized to achieve
complete combustion of hydrocarbons, and are highly regulated by both state and federal air emissions
requirements. Air emissions from abandoned coal refuse piles are not. Societal goals such as net zero
GHG emissions by 2050 will be frustrated by this waste coal “sleeper” source of nearly continuous
“forever" emissions of methane unless abandoned coal refuse is re-mined and permanently converted
from a source of pollution to useful energy, enabling further displacement of newly extracted fossil fuel
emissions.

‘As examined quantitatively in this study, USEPA and others have measured and characterized air
emissions from smoldering and spontaneously combusting rogue coal refuse piles"”. Coal refuse energy
recovery and permanent remediation facilities operate very responsibly, are aggressively regulated, and
operate in continuous compliance with all applicable state and federal air quality regulations and
standards. State and Federal Environmental Regulatory Authorities monitor these facilities to ensure that
they do not cause or contribute to a “condition of air pollution”, while air emissions from abandoned coal
refuse piles are unregulated and accepted as “naturally occurring” sources of air pollutant emissions.
Their ability to slowly emit polluting emissions over enormous surface areas and almost unimaginable
volumes constitute a source of ground-level anthropogenic air emissions that should also be evaluated
through the lens of local air quality impacts, including Environmental Justice Communities in the
abandoned coal fields of Appalachia.

For any hydrocarbon fuel to be theoretically completely combusted to CO and water vapor (H20)
requires the ability to provide at least the ideal, or stoichiometric, air-to-fuel ratio and high combustion
temperatures needed to completely convert the hydrocarbons in the fuel. Insufficient, off-stochiometric.
air-to-fuel ratios and/or smoldering at low temperatures cause incomplete combustion of fuel. This
means when there is insufficient oxygen, any fossil fuel will be only partially combusted, emitting
intermediate products of incomplete combustion such as the potent greenhouse gas methane, hydrogen
sulfide (H2S), and likely the even more potent greenhouse gas nitrous oxide (N20) instead of nitrogen

8




 

9 
 

dioxide (NO2). 

 
The combustion of coal refuse in piles, lacking the stoichiometric amount of air to complete combustion 

therefore releases different, more polluting, and much more potent GHG intermediates such as 

methane and nitrous oxide, uncontrolled mercury (which is highly controlled in CFB boilers18), odorous 

and toxic hydrogen sulfide (H2S), carbon monoxide (CO), uncontrolled fine particulate (PM10) and 

others directly to the local airshed as ground-level “area sources” of air pollutants transported by the 

wind. Sulfur emissions can be identified by their distinct odor, which is easily recognized near coal 

refuse piles. This is important because in the alternative, coal refuse reclamation-to-energy facilities 

are equipped with advanced air pollution control systems, including Government oversight, emissions 

monitoring and reporting to maintain continuous regulatory compliance with stringent emission 

limitations, and only emit highly controlled flue gases at elevated temperature and velocity from tall 

stacks that are maintained according to USEPA Good Engineering Practice (GEP) to protect human 

health and welfare via compliance with NIH and USEPA National Ambient Air Quality Standards 

(NAAQS)19. 

 
Coal refuse pile emissions on the other hand are largely forgotten, neglected and unpermitted emission 

sources that naturally emit toxic and criteria air pollutants with minimal dilution at ground level, where 

downwind residents of affected communities live and breathe. Being emitted at surface level, and 

particularly for air pollutants that are heavier than air, they can form choking clouds of smoke-laced 

pollutants that can be detected as visible haze and the odor of sulfur downgradient and  downwind. 

These forms of incomplete combustion, which are emitted in Virginia every hour of every day, are far 

more problematic than the highly controlled combustion environment and resultant controlled emissions 

of a CAA-permitted coal refuse reclamation-to-energy CFB combustion unit. 

 
Based on these factors, the authors sought to characterize a literature-based net comparison of the GHG 

and other air pollutant quantities of “forever” air emissions continuously emitted from legacy abandoned 

coal refuse piles with the documented net air emissions produced by VCHEC and other coal refuse 

reclamation-to-energy facilities as they permanently remediate (destroy) abandoned coal refuse while 

recovering it’s useful thermal energy20. Our comparison shows that the coal refuse reclamation-to-

energy industry throughout Appalachia prevents millions of the tons of CO2e and other partial 

combustion products being otherwise emitted by abandoned coal refuse piles at ground level every 

single year. The very real CO2e net reduction offsets will, in the future, become a necessary component 

of plans to actually achieve net zero GHG emissions in these States by 2050. Indeed, the authors 

suggest that the coal refuse reclamation-to-energy industry should be recognized in any program for 

limiting, banking, or trading GHG emissions for its factual ability to permanently generate substantial net 

CO2e offsets. Maximum benefits to the environment warrant maximum capacity operation of such 

remediation assets for many years to come. 

 

Coal Refuse Pile Air Emissions 

Many of the environmental problems associated with coal refuse begin as a result of pyrite and sulfur 

oxidation with production of acidity. Historic refuse piles are the legacy of extraction, crushing and 

screening impurities of coal formerly existing as undisturbed solid coal seams. Coal refuse, then, is 

high in coal fragments and discarded as loose, unconsolidated waste piles that allow oxygen to interact 

easily with the high surface area of the fines discarded in the piles. One of the most well-known and 

noticeable environmental impacts of coal refuse piles is that they create acidic runoff, meaning that 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com
dioxide (NO2).

The combustion of coal refuse in piles, lacking the stoichiometric amount of air to complete combustion
therefore releases different, more polluting, and much more potent GHG intermediates such as
methane and nitrous oxide, uncontrolled mercury (which is highly controlled in CFB boilers"*), odorous
and toxic hydrogen sulfide (H2S), carbon monoxide (CO), uncontrolled fine particulate (PM10) and
others directly to the local airshed as ground-level “area sources" of air pollutants transported by the
wind. Sulfur emissions can be identified by their distinct odor, which is easily recognized near coal
refuse piles. This is important because in the alternative, coal refuse reclamation-to-energy facilities
are equipped with advanced air pollution control systems, including Government oversight, emissions
monitoring and reporting to maintain continuous regulatory compliance with stringent emission
limitations, and only emit highly controlled flue gases at elevated temperature and velocity from tall
stacks that are maintained according to USEPA Good Engineering Practice (GEP) to protect human
health and welfare via compliance with NIH and USEPA National Ambient Air Quality Standards
(NAAQS)”.

Coal refuse pile emissions on the other hand are largely forgotten, neglected and unpermitted emission
sources that naturally emit toxic and criteria air pollutants with minimal dilution at ground level, where
downwind residents of affected communities live and breathe. Being emitted at surface level, and
particularly for air pollutants that are heavier than air, they can form choking clouds of smoke-laced
pollutants that can be detected as visible haze and the odor of sulfur downgradient and downwind.
These forms of incomplete combustion, which are emitted in Virginia every hour of every day, are far
more problematic than the highly controlled combustion environment and resultant controlled emissions
of a CAA-permitted coal refuse reclamation-to-energy CFB combustion unit.

Based on these factors, the authors sought to characterize a literature-based net comparison of the GHG
and other air pollutant quantities of “forever’ air emissions continuously emitted from legacy abandoned
coal refuse piles with the documented net air emissions produced by VCHEC and other coal refuse
reclamation-to-energy facilities as they permanently remediate (destroy) abandoned coal refuse while
recovering it's useful thermal energy®®. Our comparison shows that the coal refuse reclamation-to-
energy industry throughout Appalachia prevents millions of the tons of CO2e and other partial
combustion products being otherwise emitted by abandoned coal refuse piles at ground level every
single year. The very real COze net reduction offsets will, in the future, become a necessary component
of plans to actually achieve net zero GHG emissions in these States by 2050. Indeed, the authors
suggest that the coal refuse reclamation-to-energy industry should be recognized in any program for
limiting, banking, or trading GHG emissions for its factual ability to permanently generate substantial net
CO:e offsets. Maximum benefits to the environment warrant maximum capacity operation of such
remediation assets for many years to come.

Coal Refuse Pile Air Emissions

Many of the environmental problems associated with coal refuse begin as a result of pyrite and sulfur
oxidation with production of acidity. Historic refuse piles are the legacy of extraction, crushing and
screening impurities of coal formerly existing as undisturbed solid coal seams. Coal refuse, then, is
high in coal fragments and discarded as loose, unconsolidated waste piles that allow oxygen to interact
easily with the high surface area of the fines discarded in the piles. One of the most well-known and

noticeable environmental impacts of coal refuse piles is that they create acidic runoff, meaning that
9




 

10 
 

precipitation picks up pollutants that are liberated to leach into surface and ground waters – a process 

known as Acid Mine Drainage (AMD)21. AMD entering a stream from a nearby coal refuse pile can 

cause the stream to turn orange in color due to the iron precipitating out of solution as the solid, iron 

hydroxide (Fe(OH)2). Much of the total sulfur in coal refuse is present as pyrite such as iron disulfide 

(FeS2) and other sulfides that oxidize to sulfuric acid in the presence of water and oxygen. 

 
Often overlooked is that pyrite oxidation is an exothermic, or heat-producing, reaction. Coal refuse pile 

fires typically evolve as a smoldering, oxygen starved incipient fire, producing limited necessary oxygen 

from the generation of steam from the moisture in the coal refuse itself 22. The occurrence of this 

internal combustion process within coal refuse piles is often not outwardly visible, but may be identified 

via warmer temperatures developing within the pile itself.  Clear evidence of the slowly developing  

combustion of burnable material within the pile is observed via the presence of a reddish-brown slate 

called “red dog”. Red dog has often been found within VA GOB piles upon disturbance, indicating their 

history of previous combustion. The presence of red dog, a nonvolatile combustion product of the 

oxidation of coal refuse, therefore, provides visual evidence of a history of uncontrolled spontaneous 

combustion of the GOB piles of Virginia. Gradually, as internal temperatures increase and the process 

of spontaneous combustion continues to develop, avenues for oxygen migration through the refuse 

expand as telltale steam and smoke coupled with the odor of sulfur transitions to open flame. The 

visible flames from a burning coal refuse pile are primarily fueled by the release of flammable coal gas 

in a process similar to the production of “manufactured gas” in the late 1800’s upon internal heating, 

gasification and ignition. 

 
The primary sources of polluting air emissions from coal refuse piles are a result of weathering leading 

to spontaneous combustion, eventually evolving to pyrolysis and surface emissions of products of 

incomplete combustion23. It is well documented that all coal, including coal refuse, decays in carbon 

content when left for extended periods exposed to the weather (sunlight, wind, oxygen and acid 

precipitation) and that a continuing process of slow oxidation occurs within abandoned refuse piles that 

inevitably and eventually leads to spontaneous combustion6. During low temperature gradual oxidation, 

the carbon atoms that give coal refuse its heating value as a low grade hydrocarbon fuel gradually self-

oxidize to the greenhouse gases methane and carbon dioxide, which will continue to be emitted along 

with other fuel-bound air pollutants and fine particulates as long as there is any remaining carbon left to 

be oxidized – perhaps over hundreds of years given the massive total inventory of coal refuse 

abandoned in Virginia as well as throughout Appalachia. While slow oxidation may not be noticeable to 

the naked eye, when thousands of acres of incipient and visible coal refuse in various stages of 

spontaneous combustion are exposed to the open air, abandoned coal refuse becomes a significant 

source of air and methane pollution in addition to combustion products of smoldering, and ultimately 

open flame.  These “pop-up” air emission sources continue every year for as long as abandoned coal 

refuse piles are allowed to persist. Putting out these fires (Virginia Energy estimates a potential 

lifecycle cost of over $260 Million to remediate AML GOB at all VA sites) on a “pop-up” basis does not 

break the spontaneous combustion cycle – the same piles will only reset and restart the process of 

passive combustion. 

 

The slow oxidation process known as weathering generates heat within the pile, eventually leading to the 

runaway chemical reaction of increasing temperature, unlimited hydrocarbon fuel supply and partial 

oxygen, causing the phenomenon known as spontaneous combustion. Spontaneous combustion occurs 

first within the interior of coal refuse piles themselves because formerly crushed coal refuse contains 

voids, known as interstices, between the discreet broken coal fragments whose surface area is much 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

precipitation picks up pollutants that are liberated to leach into surface and ground waters — a process
known as Acid Mine Drainage (AMD)?". AMD entering a stream from a nearby coal refuse pile can
cause the stream to turn orange in color due to the iron precipitating out of solution as the solid, iron
hydroxide (Fe(OH).). Much of the total sulfur in coal refuse is present as pyrite such as iron disulfide
(FeS:) and other sulfides that oxidize to sulfuric acid in the presence of water and oxygen.

Often overlooked is that pyrite oxidation is an exothermic, or heat-producing, reaction. Coal refuse pile
fires typically evolve as a smoldering, oxygen starved incipient fire, producing limited necessary oxygen
from the generation of steam from the moisture in the coal refuse itself. The occurrence of this
internal combustion process within coal refuse piles is often not outwardly visible, but may be identified
via warmer temperatures developing within the pile itself. Clear evidence of the slowly developing
combustion of burnable material within the pile is observed via the presence of a reddish-brown slate
called “red dog’. Red dog has often been found within VA GOB piles upon disturbance, indicating their
history of previous combustion. The presence of red dog, a nonvolatile combustion product of the
oxidation of coal refuse, therefore, provides visual evidence of a history of uncontrolled spontaneous
combustion of the GOB piles of Virginia. Gradually, as internal temperatures increase and the process
of spontaneous combustion continues to develop, avenues for oxygen migration through the refuse
expand as telltale steam and smoke coupled with the odor of sulfur transitions to open flame. The
visible flames from a burning coal refuse pile are primarily fueled by the release of flammable coal gas
in a process similar to the production of ‘manufactured gas” in the late 1800's upon internal heating,
gasification and ignition.

The primary sources of polluting air emissions from coal refuse piles are a result of weathering leading
to spontaneous combustion, eventually evolving to pyrolysis and surface emissions of products of
incomplete combustion”. It is well documented that all coal, including coal refuse, decays in carbon
content when left for extended periods exposed to the weather (sunlight, wind, oxygen and acid
precipitation) and that a continuing process of slow oxidation occurs within abandoned refuse piles that
inevitably and eventually leads to spontaneous combustion’. During low temperature gradual oxidation,
the carbon atoms that give coal refuse its heating value as a low grade hydrocarbon fuel gradually self-
oxidize to the greenhouse gases methane and carbon dioxide, which will continue to be emitted along
with other fuel-bound air pollutants and fine particulates as long as there is any remaining carbon left to
be oxidized — perhaps over hundreds of years given the massive total inventory of coal refuse
abandoned in Virginia as well as throughout Appalachia. While slow oxidation may not be noticeable to
the naked eye, when thousands of acres of incipient and visible coal refuse in various stages of
spontaneous combustion are exposed to the open air, abandoned coal refuse becomes a significant
source of air and methane pollution in addition to combustion products of smoldering, and ultimately
open flame. These “pop-up” air emission sources continue every year for as long as abandoned coal
refuse piles are allowed to persist. Putting out these fires (Virginia Energy estimates a potential
lifecycle cost of over $260 Million to remediate AML GOB at all VA sites) on a “pop-up” basis does not
break the spontaneous combustion cycle — the same piles will only reset and restart the process of
passive combustion.

The slow oxidation process known as weathering generates heat within the pile, eventually leading to the
runaway chemical reaction of increasing temperature, unlimited hydrocarbon fuel supply and partial
‘oxygen, causing the phenomenon known as spontaneous combustion. Spontaneous combustion occurs
first within the interior of coal refuse piles themselves because formerly crushed coal refuse contains
voids, known as interstices, between the discreet broken coal fragments whose surface area is much

10




 

11 
 

greater than mined deposits of coal,  are exposed to oxygen between particles24. Temperature rise is 

most pronounced in the interior of the piles since the inner layers are not subjected to radiational or 

rainwater cooling as at the surface. Thus, heat from the gradual oxidation process results in increasing 

internal temperatures, culminating in partial, incomplete combustion as evidenced by steam and/or 

smoke being emitted from a pile. Inside the pile, there is never sufficient oxygen to fully burn out all of 

the coal to CO2 and H2O – rather, once coal refuse begins to smolder within an existing coal refuse pile, 

it can continue to smolder in the absence of an ideal stoichiometric fuel to air ratio for months or years. 

The Centralia Coal Mine Fire in PA is an extreme example. Unlike the carefully controlled excess air and 

ratio combustion of a CFB boiler where the carbon and hydrocarbon content of coal refuse is efficiently 

burned out to water and CO2, smoldering coal refuse is only partially converted to CO2 with the balance 

emitted as the far more potent greenhouse gas methane (CH4). 

 
Finally, runaway temperatures within a smoldering pile will ultimately erupt into open flame where 

combustion of coal gas still occurs at far from the ideal stoichiometric air to fuel ratio. It is the gases 

generated due to pyrolysis (starved air combustion) that burn as open flame from the combustion of 

volatile hydrocarbons at the pile surface. From the heat so generated, the char (solid carbon) residue 

itself begins to burn to the extent sufficient oxygen is available. These types of higher temperature, but 

still oxygen-starved combustion not only release the greenhouse gases CO2 and methane, but other 

uncontrolled air pollutant emissions such as NOx , mercury, fine particulate (smoke), volatile organic 

compounds, oxides of nitrogen, carbon monoxide, sulfur compounds, and likely the extremely potent 

greenhouse gas nitrous oxide, at a higher rate than would otherwise be minimized in the well-controlled 

combustion conditions found at coal refuse reclamation-to-energy facilities. It is clear that the ubiquitous 

abandoned coal refuse piles and managed impoundments dotting Virginia and all of Appalachia are an 

existing and very significant existing source of uncontrolled CO2e, hazardous air pollutants and CAA 

regulated criteria air pollutants simply due to their continued existence. 

 

Various researchers have measured emissions from abandoned coal refuse piles, including US EPA.  

TRC performed an internet Literature search to identify such published emission factors for use in this 

study.  These are presented in Table 1 below.  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

greater than mined deposits of coal, are exposed to oxygen between particles”. Temperature rise is
most pronounced in the interior of the piles since the inner layers are not subjected to radiational or
rainwater cooling as at the surface. Thus, heat from the gradual oxidation process results in increasing
internal temperatures, culminating in partial, incomplete combustion as evidenced by steam and/or
smoke being emitted from a pile. Inside the pile, there is never sufficient oxygen to fully burn out all of
the coal to COz and H20 - rather, once coal refuse begins to smolder within an existing coal refuse pile,
it can continue to smolder in the absence of an ideal stoichiometric fuel to air ratio for months or years.
The Centralia Coal Mine Fire in PA is an extreme example. Unlike the carefully controlled excess air and
ratio combustion of a CFB boiler where the carbon and hydrocarbon content of coal refuse is efficiently
burned out to water and CO2, smoldering coal refuse is only partially converted to CO2 with the balance
emitted as the far more potent greenhouse gas methane (CH.).

Finally, runaway temperatures within a smoldering pile will ultimately erupt into open flame where
‘combustion of coal gas still occurs at far from the ideal stoichiometric air to fuel ratio. It is the gases
generated due to pyrolysis (starved air combustion) that burn as open flame from the combustion of
volatile hydrocarbons at the pile surface. From the heat so generated, the char (solid carbon) residue
itself begins to burn to the extent sufficient oxygen is available. These types of higher temperature, but
still oxygen-starved combustion not only release the greenhouse gases CO2 and methane, but other
uncontrolled air pollutant emissions such as NOx, mercury, fine particulate (smoke), volatile organic
‘compounds, oxides of nitrogen, carbon monoxide, sulfur compounds, and likely the extremely potent
greenhouse gas nitrous oxide, at a higher rate than would otherwise be minimized in the well-controlled
combustion conditions found at coal refuse reclamation-to-energy facilities. It is clear that the ubiquitous
abandoned coal refuse piles and managed impoundments dotting Virginia and all of Appalachia are an
existing and very significant existing source of uncontrolled CO2e, hazardous air pollutants and CAA

regulated criteria air pollutants simply due to their continued existence.
Various researchers have measured emissions from abandoned coal refuse piles, including US EPA.

TRC performed an internet Literature search to identify such published emission factors for use in this
study. These are presented in Table 1 below.

1




 

12 
 

Table 1 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
Extent and Distribution of Abandoned Coal Refuse Piles in Virginia 

The enormity of existing abandoned coal refuse sites in SW Virginia is alarming. According to publicly 

available inventory data provided by Virginia Energy, 523 total acres of pre-SMCRA abandoned coal 

refuse pile surface area is continuously exposed to the elements (Table 2-1). At a typical bulk density of 

coal refuse of 60-80 lb/ft3 (TRC has assumed an average of 80 lb/ft3 to capture the high end of the range), 

the published VA inventory accounts for up to 16 million tons of AML coal refuse abandoned in the 

Commonwealth from the legacy mining industry(32). 

It has been estimated that an additional 64 million tons of non-AML qualified coal refuse is being managed 

in surface impoundments (“non-GOB” coal refuse) for a total inventory estimate of around 80 million cubic 

yards of mining legacy waste coal (Table 2-2). In the following Tables, TRC has separately evaluated 

passive emissions from the VA AML Gob Pile inventory, as well as the estimated total 80 million total cubic 

yards of material including GOB and Non-GOB coal refuse in Virginia(32). 

 
Based on estimated pile depths, the total estimated volume of existing AML GOB coal refuse piles in 

VA is estimated to equate to almost 15 million cubic yards of material (for perspective, a typical dump 

Emission Factors for Coal Refuse Combustion 
 

Pollutant 

kg/hr per 
tonne of 
Burning 

Coal 
Refuse(1) 

lb/hr/ton 
Smoldering 

Coal 
Refuse(1) 

ton/1000 kg 
of 

Combusted 
Coal 

Refuse(2) 

lb/ton of 
Combusted 

Coal 
Refuse(2) 

lb/ton of 
Combusted 

Coal 
Refuse(33) 

kg/tonne 
of 

Combusted 
Coal 

Refuse(4) 

lb/ton of 
Combusted 

Coal 
Refuse(4) 

 

NOx 6.70E-05⁽¹⁾ 1.34E-04       3.00E-02 
6.00E-02 

 

CO 8.70E-03⁽¹⁾ 1.74E-02       9.70E+01 
1.94E+02 

 

CH4     8.00E-01 1.45E+03 3.26.E+02   
  

 

CO2     1.30E+00 2.36E+03 2.54E+03   
  

 

Total PM 3.40E-07⁽¹⁾ 6.80E-07       4.50E-01 
9.00E-01 

 

PM10 8.70E-09⁽¹⁾ 1.74E-08       4.50E-01 
9.00E-01 

 

SO2 7.40E-05⁽¹⁾ 1.48E-04     6.62E+01 8.40E-01 
1.68E+00 

 

SO3 1.80E-07⁽¹⁾ 3.60E-07         
  

 

VOC 6.70E-05⁽¹⁾ 1.34E-04         
  

 

NH3 4.30E-05⁽¹⁾ 8.60E-05         
  

 

H2S 3.00E-04⁽¹⁾ 6.00E-04       6.10E-01 
1.22E+00 

 

Hg 4.60E-09⁽¹⁾ 9.20E-09     7.89E-04   
  

 

POM 1.30E-08⁽¹⁾ 2.60E-08         
  

 

1. Coal Refuse  Piles, Abandoned Mines and Outcrops, State of the Art, EPA-600/2-78-004v, July 1978, Table 4 

2. Gielisch H, Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. Environmental Risk Assessment 
and Remediation 2017; 2(1): 5-8; 

 
https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-problem-8871.html  

3. https://www.epa.gov/sites/production/files/2015-07/documents/chapter_11_other_fuels_and_fuel_emission_factors.pdf  

4. Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste Dumps in Silesia, Poland, Fabiańska M, 
Ciesielczuk J, Nádudvari Á, Misz-Kennan M, Kowalski A, Kruszewski Ł. 
Environ Geochem Health. 2019 Apr;41(2):575-601. doi: 10.1007/s10653-018-0153-5. Epub 2018 Jul 24.  
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6510838/  

5. EPA, Emissions & Generation Resource Integrated Database (eGRID) 
 

https://www.epa.gov/egrid  

33. 
ARIPPA substituted value for CH4 reduced from 0.7625 (Gielisch) to 0.163, substituted to add conservatism and consistency 
with reported values            

nx TRC 650 Suffolk St., Suite 200 9789705600
7 4 Lowell, MA 01854 TRCcompanies.com

Table 1
Emission Factors for Coal Refuse Combustion
semeoe | myuron | 20% | wponct | monat | MM | nat
potutant | suming | SOMME | combusted | Combusted | Combusted | coompysrey | combusted
ict | naa | Shy | nse | nae | eH | ncn

a
2 Gielen trope Cal eo jor Sore of Geetase Gs oorgeten Palen Crone Rit ieament
Sed Remeiton 2017 2

4 posite ep govern He/203-0 somerset tht fe and fe smison facet

4. enivonmnta! infec ose Enso fom Sel ean Cel Weste Dumps Ses, Poor, aia
Gesna Nica tenon Mow sce
fron Geotem eat 2039 A ]S75G os 1 07/1083 01801
hon. aspmelr/°MCSS10838/

ss Tak ema a Genatn Resse grated Daas (0)

aoa sats oC es rom 0.7625 (Gels 20163, abetted tnd coseatin and consteny

Extent and Distribution of Abandoned Coal Refuse Piles in Virginia

The enormity of existing abandoned coal refuse sites in SW Virginia is alarming. According to publicly
available inventory data provided by Virginia Energy, 523 total acres of pre-SMCRA abandoned coal
refuse pile surface area is continuously exposed to the elements (Table 2-1). Ata typical bulk density of
coal refuse of 60-80 Ib/ft? (TRC has assumed an average of 80 Ib/ft° to capture the high end of the range),
the published VA inventory accounts for up to 16 million tons of AML coal refuse abandoned in the
Commonwealth from the legacy mining industry),

It has been estimated that an additional 64 million tons of non-AML qualified coal refuse is being managed
in surface impoundments (‘non-GOB" coal refuse) for a total inventory estimate of around 80 million cubic
yards of mining legacy waste coal (Table 2-2). In the following Tables, TRC has separately evaluated
passive emissions from the VA AML Gob Pile inventory, as well as the estimated total 80 million total cubic
yards of material including GOB and Non-GOB coal refuse in Virginia)

Based on estimated pile depths, the total estimated volume of existing AML GOB coal refuse piles in
VA\is estimated to equate to almost 15 milion cubic yards of material (for perspective, a typical dump
12




 

13 
 

truck holds only about 10 to 14 cubic yards). Assuming coal refuse may average up to 80 lbs/ft3, the 

total inventory of 80 million cubic yards would equate to an estimated 86,400,000 tons of total coal 

refuse identified within Virginia. Considering that abandoned legacy piles are known to cause 

continuing and significant adverse environmental and ecological impacts to soil, water, air quality, 

climate change, land use, habitat degradation, and aesthetics, these numbers are staggering. No other 

fossil fuel land disposal activity would today be allowed to remain deposited and abandoned in the U.S. 

without first requiring environmental remediation. The VA AML GOB inventory alone accounts for an 

estimated 16,153,507 tons of GOB coal refuse continually subjected to gradual internal thermal rise, 

products of incomplete combustion and potential runaway thermal oxidation. The first several feet of 

depth of this entire surface area is continuously undergoing the weathering process, also emitting 

fugitive fine particulate matter (smoke and windblown dust), otherwise regulated air pollutants, and 

greenhouse gases over a tremendous area of SWVA at a slow, but relentless rate. Tables 2-1 and 2-2 

summarize the estimated inventory of AML GOB and total coal refuse extant in Virginia.  

 

Table 2-1 

 

Commonwealth of VA Estimated Extent of AML GOB Coal Refuse 

Pre SMCRA Abandoned AML 
GOB Coal Piles 

Acres Cubic Yards 
Estimated Tons @80 

lb/ft3 

VA State Coal Refuse AML 
GOB Inventory 

523 14,956,951 16,153,507 

 

Table 2-2 

 

Commonwealth of VA Estimated Extent of GOB and Non-GOB Coal Refuse 

Total Estimated AML GOB 
+Non-GOB Coal Piles 

Acres Cubic Yards 
Estimated Tons @80 

lb/ft3 

VA State Coal Refuse AML 
GOB + Non-GOB Inventory 

2,615 80,000,000 86,400,000 

 

The magnitude of mining legacy waste material in the Commonwealth of Virgina is stunning. Any 

portions of this material that may be slowly emitting GHG’s or other pollutants, even at a very low rate, 

becomes a very significant source of total air and GHG emissions simply given that the area and 

volume data are estimated in millions of tons.  

Figure 1 below shows the locations of pre-SMCRA, AML qualified coal refuse (GOB) piles in the State 

Inventory of Virginia. 

 

 

 

 

 

 

 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

truck holds only about 10 to 14 cubic yards). Assuming coal refuse may average up to 80 Ibs/ft?, the
total inventory of 80 million cubic yards would equate to an estimated 86,400,000 tons of total coal
refuse identified within Virginia. Considering that abandoned legacy piles are known to cause
continuing and significant adverse environmental and ecological impacts to soil, water, air quality,
climate change, land use, habitat degradation, and aesthetics, these numbers are staggering. No other
fossil fuel land disposal activity would today be allowed to remain deposited and abandoned in the U.S.
without first requiring environmental remediation. The VA AML GOB inventory alone accounts for an
estimated 16,153,507 tons of GOB coal refuse continually subjected to gradual internal thermal rise,
products of incomplete combustion and potential runaway thermal oxidation. The first several feet of
depth of this entire surface area is continuously undergoing the weathering process, also emitting
fugitive fine particulate matter (smoke and windblown dust), otherwise regulated air pollutants, and
greenhouse gases over a tremendous area of SWVA at a slow, but relentless rate. Tables 2-1 and 2-2
summarize the estimated inventory of AML GOB and total coal refuse extant in Virginia

Table 2-1
‘Commonwealth of VA Estimated Extent of AML GOB Coal Refuse
Pre SMCRA Abandoned AML , Estimated Tons @80
GOB Coal Piles Acres Cubic Yards Ib/ft?
VaState Coal Refuse AML | 5) 14,956,951 16,153,507

GOB Inventory

Table 2-2

‘Commonwealth of VA Estimated Extent of GOB and Non-GOB Coal Refuse

Total Estimated AML GOB : Estimated Tons @80
+Non-GOB Coal Piles Acres Cubic Yards lb/ft?

VA State Coal Refuse AML
GOB + Non-GOB Inventory

2,615 80,000,000 86,400,000

The magnitude of mining legacy waste material in the Commonwealth of Virgina is stunning. Any
portions of this material that may be slowly emitting GHG's or other pollutants, even at a very low rate,
becomes a very significant source of total air and GHG emissions simply given that the area and
volume data are estimated in millions of tons.

Figure 1 below shows the locations of pre-SMCRA, AML qualified coal refuse (GOB) piles in the State
Inventory of Virginia.

13




 

14 
 

Figure 1  

 

 
 
 
Projected Life Cycle Air Emissions Due to Surface Weathering 

As stated previously, all coal refuse placed in piles or impoundments gradually and eventually weathers 

(oxidizes)30. This process is very slow and not dis-similar to the inevitable rusting of abandoned farm 

implements, for example. While weathering is an imperceptibly slow process, due to the extraordinary 

acreage, surface area exposure and volume of AML GOB and Non-GOB coal refuse that has been 

discarded or being managed over many years, coal refuse piles represent a virtually “forever source” of 

weathering emissions unless either sealed (impermeably capped like a landfill with active GHG gas 

collection), nitrogen blanketed or permanently remediated. Table 2-1 summarizes estimates of pre 

SMCRA abandoned coal refuse in VA at over 523 acres (22,781,880 ft2) of surface area). If we assume 

that only the first two feet of depth from the surface of every pile is exposed to continuous weathering 

(oxygen, sun damage, freeze/thaw cycles, acid rain, etc.) every hour of their “forever” life, the amount 

of AML coal refuse in the slow process of weathering in VA amounts to an estimated 45,563,760 ft3.  At 

the USEPA AP-42 bulk density range of 60-80 lb/ft3, the amount of un-remediated coal refuse material 

continuously weathering within the top two feet of AML qualified existing piles in VA is estimated to be 

on the order of 1.8 million tons (at 80 lb/ft3). This likely represents a conservative estimate because 

coal refuse piles drain readily, and it is likely that oxygen and acid rain reach more deeply into the piles. 

If we consider the entire estimated VA (GOB +Non-GOB) inventory (80 million yds3), at the same 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

Figure 4

@ idiom

GOBPILELOCATIONS = S724 ee 2 Q Enetgy

Projected Life Cycle Air Emissions Due to Surface Weathering

As stated previously, all coal refuse placed in piles or impoundments gradually and eventually weathers
(oxidizes). This process is very slow and not dis-similar to the inevitable rusting of abandoned farm
implements, for example. While weathering is an imperceptibly slow process, due to the extraordinary
acreage, surface area exposure and volume of AML GOB and Non-GOB coal refuse that has been
discarded or being managed over many years, coal refuse piles represent a virtually “forever source" of
weathering emissions unless either sealed (impermeably capped like a landfill with active GHG gas
collection), nitrogen blanketed or permanently remediated. Table 2-1 summarizes estimates of pre
SMCRA abandoned coal refuse in VA at over 523 acres (22,781,880 ft?) of surface area). If we assume
that only the first two feet of depth from the surface of every pile is exposed to continuous weathering
(oxygen, sun damage, freeze/thaw cycles, acid rain, etc.) every hour of their ‘forever’ life, the amount
of AML coal refuse in the slow process of weathering in VA amounts to an estimated 45,563,760 ft. At
the USEPA AP-42 bulk density range of 60-80 Ib/ft?, the amount of un-remediated coal refuse material
continuously weathering within the top two feet of AML qualified existing piles in VA is estimated to be
on the order of 1.8 million tons (at 80 Ib/ft?). This likely represents a conservative estimate because
coal refuse piles drain readily, and it is likely that oxygen and acid rain reach more deeply into the piles.
If we consider the entire estimated VA (GOB +Non-GOB) inventory (80 million yds"), at the same

14




 

15 
 

surface area ratio of the known AML piles, that translates to an estimated total surface area of 2,797 

acres. Assuming the top two feet of that total area is exposed to weathering, the VA total potentially 

exposed to weathering would be estimated  at over 9.7 million tons of coal refuse continuously emitting 

air pollutants due to surface weathering of coal refuse in VA.   

 

As will be discussed, the weathering of coal slowly generates heat due to oxidation which can and 

does eventually lead to spontaneous combustion. Air emissions due to spontaneous combustion dwarf 

air emissions associated only with weathering, however the Authors set out to quantify both phases of 

coal pile degradation.  The International Journal of Coal Geology (2017)23 states that in situ weathering 

of coal causes a measurable decrease in its carbon content over time, resulting in a proportional 

percentage decrease in its Gross Calorific (heating) Value (GCV). Jha (2016)27 states that in situ 

weathering of coal showed a loss of 5% in calorific value over a period of 25 years. Since the GCV of 

any hydrocarbon fuel is proportional to its hydrogen/carbon molecular content, a 5% decrease in 

calorific value can be roughly estimated to also indicate a similar loss in carbon and hydrogen content, 

which will have slowly oxidized to the Greenhouse Gases methane and CO2. According to the North 

American Combustion Handbook28, bituminous coals average about 80% carbon and from 2-5% 

hydrogen. Thus, a 5% decrease in calorific value via the weathering oxidation process may oxidize 

(reduce) the 80% carbon content of the coal portion of GOB by about 5% every 25 years, or an annual 

decay rate of about 0.2% of the carbon content of coal refuse each year that it weathers. 

 
USEPA and others have published emission factors3,8 from the in-situ combustion of coal and coal 

refuse in piles. These emissions have been reported by Gielisch and Kropp (reference 4)  during the 

process of spontaneous combustion at 2.7 tons of CO2 per metric ton of waste coal, and 0.8 tons of 

CH4 per metric ton of waste coal in some stage of spontaneous combustion (2,360 lb CO2/short ton and 

1,450 lb CH4 /short ton of coal content consumed). However, we note that coal refuse is less reactive 

than the mined coal evaluated by Gielisch and Kropp, and we turned to the Trade Association ARIPPA 

(Appalachian Region Independent Power Producers Association) for additional input. For conservatism 

and consistency, a lower methane evolution value of 326 lb CH4/short ton of coal refuse has been 

substituted based on emission factors provided by ARIPPA33.  To account for the gradual combustion 

of coal due to weathering, those values have been adapted to this much slower process of gradual 

oxidation which is an identical process but at a much lower rate. Jha (2016)27 states that weathering 

oxidizes standing coal at a rate of about 5% every 25 years. While weathering due to the entire coal 

refuse inventory alone is responsible for some lifecycle emissions of CO2e, this factor is less significant 

than the process of spontaneous combustion documented by USEPA emission factor measurements 

from smoldering coal refuse. Air Emissions from the VA Energy AML GOB inventory are (the emission 

factors from Table 2 applied to the weathering surface areas and partial volumes of coal refuse in the 

state inventory are provided in Tables 2-3 and 2-4. 

 
 

 

 

 

 

 

 

 

 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

surface area ratio of the known AML piles, that translates to an estimated total surface area of 2,797
acres. Assuming the top two feet of that total area is exposed to weathering, the VA total potentially
exposed to weathering would be estimated at over 9.7 million tons of coal refuse continuously emitting
air pollutants due to surface weathering of coal refuse in VA

As will be discussed, the weathering of coal slowly generates heat due to oxidation which can and
does eventually lead to spontaneous combustion. Air emissions due to spontaneous combustion dwarf
air emissions associated only with weathering, however the Authors set out to quantify both phases of
coal pile degradation. The International Journal of Coal Geology (2017)* states that in situ weathering
of coal causes a measurable decrease in its carbon content over time, resulting in a proportional
percentage decrease in its Gross Calorific (heating) Value (GCV). Jha (2016)” states that in situ
weathering of coal showed a loss of 5% in calorific value over a period of 25 years. Since the GCV of
any hydrocarbon fuel is proportional to its hydrogen/carbon molecular content, a 5% decrease in
calorific value can be roughly estimated to also indicate a similar loss in carbon and hydrogen content,
which will have slowly oxidized to the Greenhouse Gases methane and COz. According to the North
American Combustion Handbook”, bituminous coals average about 80% carbon and from 2-5%
hydrogen. Thus, a 5% decrease in calorific value via the weathering oxidation process may oxidize
(reduce) the 80% carbon content of the coal portion of GOB by about 5% every 25 years, or an annual
decay rate of about 0.2% of the carbon content of coal refuse each year that it weathers.

USEPA and others have published emission factors®® from the in-situ combustion of coal and coal
refuse in piles. These emissions have been reported by Gielisch and Kropp (reference 4) during the
process of spontaneous combustion at 2.7 tons of CO2 per metric ton of waste coal, and 0.8 tons of
CH; per metric ton of waste coal in some stage of spontaneous combustion (2,360 Ib CO,/short ton and
1,450 Ib CH,/short ton of coal content consumed). However, we note that coal refuse is less reactive
than the mined coal evaluated by Gielisch and Kropp, and we tuned to the Trade Association ARIPPA
(Appalachian Region Independent Power Producers Association) for additional input. For conservatism
and consistency, a lower methane evolution value of 326 Ib CH./short ton of coal refuse has been
substituted based on emission factors provided by ARIPPA®. To account for the gradual combustion
of coal due to weathering, those values have been adapted to this much slower process of gradual
oxidation which is an identical process but at a much lower rate. Jha (2016)” states that weathering
oxidizes standing coal at a rate of about 5% every 25 years. While weathering due to the entire coal
refuse inventory alone is responsible for some lifecycle emissions of COze, this factor is less significant
than the process of spontaneous combustion documented by USEPA emission factor measurements
from smoldering coal refuse. Air Emissions from the VA Energy AML GOB inventory are (the emission
factors from Table 2 applied to the weathering surface areas and partial volumes of coal refuse in the
state inventory are provided in Tables 2-3 and 2-4.

15




 

16 
 

 

 

Table 2-3 - GHG Emissions from AML GOB Coal Refuse Inventory 
Weathering Annually  

      

 Assumptions     

 

Table 2-1 AML Inventory in VA   
523 acres 

 

 

Estimated Surface Area of in-situ waste coal 
in VA, ft2 

  
22,760,141 ft² 

 

 

Times 2 ft Surface Depth of coal exposed to 
weathering 

  
2.00 ft 

 

 

Conservative Assumption that weathering 
takes place within the two feet of the 
surface exposed to sun, oxygen and acid 
rain (Ft3) 

  

45,520,283 ft³ 

 

 

Typical In-situ waste coal bulk density   80 lb/ft³ 
 

 

Amount of weathering coal refuse in 
Virginia 

  
1,820,811 tons 

 

 

In-situ weathering of coal showed a loss of 
5% in calorific value over a period of 25 
years. 

  

0.20% per yr 

 

 

Total AML GOB waste coal impacted per 
year (tons) 

  
3,642 

 

 Pollutant 
smoldering/combustion 

Emission Factor 
 (lb/ton) 

Coal Refuse 
Weathering 

In-Situ 

Annual GHG 
Emissions 

 (tons/yr), AML 
GOB Coal Refuse 

Weathering in-situ  
 CO2 2,361⁽¹⁾ 3,642 4,299 

 
 CH4 326 (33) 3,642 594 

 
 CO2e 10,511   19,138 

 
     

 
1. Gielisch H, Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. 

Environmental Risk Assessment and Remediation 2017; 2(1): 5-8; 
 

 

https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-
problem-8871.html 

    
2. The GWP of CO2 and CH4 are 1 and 25, respectively. The GWP of N20 is 298.  Although there is certainly 

some N2O emitted, we have yet to establish a published emission rate of N2O from weathering.  
 

33. ARIPPA substituted value for CH4 reduced from 0.7625 (Gielisch) to 0.163, substituted to add conservatism and 
consistency with reported values  

   

 

 

 

NX TRC 650 Suffolk St., Suite 200
vA Lowell, MA 01854

33.

Table 2-3 - GHG Emi:
Weathering Annually

ions from AML GOB Coal Refuse Inventory

Assumptions
Table 2-1 AML Inventory in VA

523 acres
Estimated Surface Area of in-situ waste coal
in VA, fe2 22,760,141 ft?
‘Times 2 ft Surface Depth of coal exposed to
weathering 2.00 ft

Conservative Assumption that weathering
takes place within the two feet of the
surface exposed to sun, oxygen and acid
rain (Ft)

45,520,283 ft?

Typical In-situ waste coal bulk density 80 Ib/ft?

“Amount of weathering coal refuse in
Virginia 1,820,811 tons

In-situ weathering of coal showed a loss of
5% in calorific value over a period of 25

0.20% per yr
years.
Total AML GOB waste coal impacted per
year (tons) 3,642
Coal Refuse ‘Annual GHG
smoldering/combustion | _ Weather Emissions
Pollutant mn Factor Ww-Steu {tons/yr), AML
(lb/ton) GOB Coal Refuse
Weathering in-situ
con 2,361" 3,642 4299
Hy 326 (33) 3,642 594
Coxe 10,511 19,138

Gilelseh H,Kropp C., Coal Fires @ Major Source of Greenhouse Gases- a Forgotten Problem,
Environmental Rsk Assessment and Remediation 2017; 21}: 58;

https://wuw aliedacademies.org/articles/coa-fires-2-major-source-of greenhouse-ga5es-2-forgotten-
‘problem 8871.hm!

The GWP of CO» and CH are 1 and 25, respectively. The GWP of N20is 298. Although there is certainly
some N20 emitted, we have yet to establish a published emission rate of N20 from weathering.

AARIPPA substituted value for CH8 reduced from 0.7625 (Gielisch) to 0.163, substituted to add conservatism and
consistency with eeported values

16

79789705600
‘TRCcompanies.com




 

17 
 

 

Table 2-4 - GHG Emissions form Entire Coal Refuse Inventory 
Weathering Annually  

      

 Assumptions     

 

Table 2-2 Total AML GOB and Non-
GOB Inventory in VA (80,000 yds3) 

  
2,615 acres 

 

 

Estimated Surface Area of in-situ waste 
coal in VA, ft2 

  
113,909,400 ft² 

 

 

Times 2 ft Surface Depth of coal 
exposed to weathering 

  
2.00 ft 

 

 

Conservative Assumption that 
weathering takes place within the two 
feet of the surface exposed to sun, 
oxygen and acid rain (Ft3) 

  

227,818,800 ft³ 

 

 

Typical In-situ waste coal bulk density   80 lb/ft³ 
 

 

Amount of weathering coal refuse in 
Virginia 

  
9,112,752 tons 

 

 

In-situ weathering of coal showed a 
loss of 5% in calorific value over a 
period of 25 years. 

  

0.20% per yr 

 

 

Total GOB + Non-GOB waste coal 
impacted per year 

  
18,226 

 

 

Pollutant 
smoldering/combustion 

Emission Factor 
 (lb/ton) 

Coal Refuse 
Weathering 

In-Situ 

Annual GHG 
Emissions 

 (tons/yr) , All Coal 
Refuse 

Weathering in-situ  

 
CO2 2,361⁽¹⁾ 18,226 21,513 

 

 
CH4 326 (33) 18,226 2,971 

 

 
CO2e 10,511   95,782 

 

 
      

1. Gielisch H, Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. 
Environmental Risk Assessment and Remediation 2017; 2(1): 5-8; 

 

 

https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-
forgotten-problem-8871.html 

    
2. The GWP of CO2 and CH4 are 1 and 25, respectively. The GWP of N20 is 298.  Although there is 

certainly some N2O emitted, we have yet to establish a published emission rate of N2O from 
weathering.   

33. ARIPPA substituted value for CH4 reduced from 0.7625 (Gielisch) to 0.163, substituted to add 
conservatism and consistency with reported values   

   

 

 

 

 

NX TRC 650 Suffolk St., Suite 200
7 4 Lowell, MA 01854

23,

Table 2-4 - GHG Emissions form Entire Coal Refuse Inventory
Weathering Annually

Assumptions

Table 2-2 Total AML GOB and Non-
GOB Inventory in VA (80,000 yds3) 2,615 acres

Estimated Surface Area of in-situ waste
coal in VA, ft? 113,909,400 ft?

Times 2 ft Surface Depth of coal
exposed to weathering 2.00 ft

Conservative Assumption that
weathering takes place within the two

feet of the surface exposed to sun, 227,818,800 fe
‘oxygen and acid rain (Ft?)
Typical In-situ waste coal bulk density 80 Ib/ft?
“Amount of weathering coal refuse in
Virginia 9,112,752 tons
In-situ weathering of coal showed @
loss of 5% in calorific value over a 0.20% per yr
period of 25 years
Total GOB + Non-GOB waste coal
impacted per year, 18,226
Coal Refuse | Annual GHG
smoldering/combustion | Weathering Emissions
Pollutant Emission Factor tsitu | (tons/yr), all Coal
(tb/ton) Refuse
Weathering in-situ
Os 2,361" 18,226 21,513
He 326 (33) 18,226 2971
cove 10511 95,782

, Coal Fires a Major Source of Greenhouse Gases: 0 Forgotten Problem,
isk Assessment and Remediation 2017; (1): 5:8;

Environmental

http://w aliedacaderies.org/aticles/coa-fies-2-major-source-of greenhouse-g250s-2
forgotten-problem-8871.htm!

‘The GWP of COs and CHs are 1 and 25, respectively. The GWP of N20is 298. Athough there is
certainly some N20 emitted, we have yet to establish a published emission rate of N2O from

‘weathering.

ARIPPA substituted value for CH4 reduced from 0.7625 (Gielisch) to 0.163, substituted to add
conservatism and consistency with reported values,

17

79789705600
‘TRCcompanies.com




 

18 
 

 

 

 

Also noteworthy is that as coal refuse weathers and the surface layers oxidize, they also become more 

friable and continue to generate new windblown fugitive dust (PM10). This dust will continue to be 

emitted from the entire surface of every pile whenever there is a sufficient wind speed to scavenge 

newly created coal dust and ash to become airborne and therefore transported offsite in ambient air 

currents that may affect local communities. This fine particulate matter, together with visible smoke 

(which is also fine particulate) is emitted at coal pile surface level where it can be transported on the 

prevailing wind to local homes, schools and sensitive receptors still residing in the former mining 

regions where it was initially deposited. 

 
Projected Annual Air Emissions Due to Spontaneous Combustion 
 

According to the EPA study (Chalekode and Blackwood3), coal refuse piles undergo a virtually 

continuous process of spontaneous combustion and maturity to open flame, depending on natural or 

anthropogenic extinguishment as they have over a century of their existence and still observed today. 

Chalekode and Blackwood defined a representative coal refuse pile as one with a volume of about 60 

million ft3 (1.7 million m3) and a typical burning pile being one with 21% of it burning (or 12.6 million 

cubic feet/pile smoldering, smoking or openly burning). At an in-situ bulk density they assumed at 60 

lb./ft3, Chalekode and Blackwood calculated a representative estimate of the amount of coal burning in 

Northern Appalachia at any time from spontaneous combustion = 12.6 million ft3 x 60 lb./ft3 x 1 ton/2000 

lbs. = 378,000 tons of coal per piles actively burning in situ. That same report identified that in 1972 

there were 116 coal refuse piles actively burning in PA and WV alone, or about 40% of all identified 

coal refuse piles extant in those states. These Authors also provided measured emission factors for 

traditional criteria air pollutants in units of Kg/hr per ton of burning refuse(4) , as well as an estimate of 

representative source emissions in units of Kg of pollutant per year.  Emission factors of GHG from 

open openly smoldering or burning coal in stationary piles have been assessed in the paper 

“Quantifying Emissions from Spontaneous Combustion”; Lesley Sloss, 201329. These emission factors 

as applied to coal refuse piles weathering is summarized in Tables 3-1 and 3-2. 

If we refer to the Virginia AML GOB Piles inventory provided by Virginia Energy, and noting that over 

100 individual piles are mapped in Figure 1, 16,153,507 tons divided by 100 piles provides an average 

pile size of SW VA GOB at about 16,535 tons per pile.  Assuming the same ratios of 40% of piles 

smoldering/burning, and 21% of coal in each actively burning, we get  an estimated 16,153,507 tons X 

.4 X .21 divided by 10 years duration = 135,689 tons of Abandoned Virginia AML GOB in some 

state of smoldering or actively burning in any given year. These are enormous numbers.  Such 

smoking or open coal fires require emergency response to dig out the source of fire to be extinguished, 

essentially re-setting the process to emerge again at some future time. Annual estimated emissions 

from just this subset of AML GOB in Virginia, are provided in Table 3-1. 

  

 

 

 

 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

Also noteworthy is that as coal refuse weathers and the surface layers oxidize, they also become more
friable and continue to generate new windblown fugitive dust (PM7o). This dust will continue to be
emitted from the entire surface of every pile whenever there is a sufficient wind speed to scavenge
newly created coal dust and ash to become airborne and therefore transported offsite in ambient air
currents that may affect local communities. This fine particulate matter, together with visible smoke
(which is also fine particulate) is emitted at coal pile surface level where it can be transported on the
prevailing wind to local homes, schools and sensitive receptors still residing in the former mining
regions where it was initially deposited

Projected Annual Air Emissions Due to Spontaneous Combustion

According to the EPA study (Chalekode and Blackwood", coal refuse piles undergo a virtually
continuous process of spontaneous combustion and maturity to open flame, depending on natural or
anthropogenic extinguishment as they have over a century of their existence and still observed today.
Chalekode and Blackwood defined a representative coal refuse pile as one with a volume of about 60
million ft? (1.7 million m9) and a typical burning pile being one with 21% of it burning (or 12.6 million
cubic feetipile smoldering, smoking or openly burning). At an in-situ bulk density they assumed at 60
Ib./f®, Chalekode and Blackwood calculated a representative estimate of the amount of coal burning in
Northern Appalachia at any time from spontaneous combustion = 12.6 million ft? x 60 Ib./ft°x 1 ton/2000
Ibs. = 378,000 tons of coal per piles actively burning in situ. That same report identified that in 1972
there were 116 coal refuse piles actively burning in PA and WV alone, or about 40% of all identified
coal refuse piles extant in those states. These Authors also provided measured emission factors for
traditional criteria air pollutants in units of Kg/hr per ton of burning refuse’, as well as an estimate of
representative source emissions in units of Kg of pollutant per year. Emission factors of GHG from
open openly smoldering or burning coal in stationary piles have been assessed in the paper
“Quantifying Emissions from Spontaneous Combustion”; Lesley Sloss, 2013”. These emission factors
‘as applied to coal refuse piles weathering is summarized in Tables 3-1 and 3-2.

If we refer to the Virginia AML GOB Piles inventory provided by Virginia Energy, and noting that over
100 individual piles are mapped in Figure 1, 16,153,507 tons divided by 100 piles provides an average
pile size of SW VA GOB at about 16,535 tons per pile. Assuming the same ratios of 40% of piles.
smoldering/burning, and 21% of coal in each actively burning, we get an estimated 16,153,507 tons X
4X .21 divided by 10 years duration = 135,689 tons of Abandoned Virginia AML GOB in some
state of smoldering or actively burning in any given year. These are enormous numbers. Such
smoking or open coal fires require emergency response to dig out the source of fire to be extinguished,
essentially re-setting the process to emerge again at some future time. Annual estimated emissions
from just this subset of AML GOB in Virginia, are provided in Table 3-1.

18




 

19 
 

 

 

Table 3-1 

    

 AML GOB Inventory Emissions due to Spontaneous Combustion 

    

 Assumptions:   

 
Amount of in-situ AML GOB (only) waste coal in VA 16,153,507 tons 

 

Referenced Ratios "as typical", 40% of all piles 
spontaneously combusting, and 21% of each combusting 
pile is actively burning18 

135,689 tons 

 
Piles spontaneously burning 40% 

 
Amount of pile that is burning 21% 

 

Estimated % of State AML GOB inventory burning at any 
one time 8% 

 

  

  
 

Table 3-1  Estimated Air Emissions from AML GOB Piles in Virginia due to 8% Continuously in 
Active Spontaneous Combustion  

    

 

Pollutant 
Emission Factor 

(lb/ton from AML GOB Piles 
Burning) 

Annual Estimated Emissions 
Assuming 8% of Inventory 

Burning  
(tons per year) 

 
NOx 0.06⁽¹⁾ 4 

 
CO 194⁽¹⁾ 13,162 

 
PM10 0.9⁽¹⁾ 61 

 
SO2 66.2⁽¹⁾ 4,491 

 
H2S 1.22⁽¹⁾ 83 

 
Hg 0.0008⁽¹⁾ 0.0535 

 
CO2 2,361⁽²⁾ 160,168 

 
CH4 326 (33) 22,117 

 
N2O     

 
CO2e 10,511⁽²⁾ 713,102 

 

(1) Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste Dumps in Silesia, Poland, 
Fabiańska M, Ciesielczuk J, Nádudvari Á, Misz-Kennan M, Kowalski A, Kruszewski Ł. Environ Geochem 
Health. 2019 Apr;41(2):575-601. doi: 10.1007/s10653-018-0153-5. Epub 2018 Jul 24. 

 
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6510838/ 

 

(2) Gielisch H., Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. 
Environmental Risk Assessment and Remediation 2017; 2(1): 5-8; 

 

https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-
problem-8871.html 

 (33)  ARIPPA substituted value for CH4 reduced from 0.7625 (Gielisch) to 0.163, substituted to add 
conservatism and consistency with reported values  

 

 

 

Application of the same assumptions to the entire estimated 80,000,000 yds3 (estimated 86,400,000 

tons at 80 lb/ft3) of total AML GOB plus Non-Gob coal refuse in VA. Assuming the same ratios of 40% 

nx TRC 650 Suffolk St., Suite 200 9789705600
7 4 Lowell, MA 01854 TRCcompanies.com

Table 3-1
AML GOB Inventory Emissions due to Spontaneous Combustion

Assumptios
"Amount of in-situ AML GOB (only) waste coalin VA 16,153,507 tons

Referenced Ratios "as typical", 40% of all piles
spontaneously combusting, and 21% of each combusting

135,689 tons
pile is actively burning}*

Piles spontaneously burning 40%

Amount of pile that is burning 21%

Estimated % of State AML GOB inventory burning at any
one time 8%

‘Table 3-1 Estimated Air Emissions from AML GOB Piles in Virginia due to 8% Continuously in
Active Spontaneous Combustion

: Tana Eainated Eins
Paant | ton om at con Assuming of ventory
jurning) {tons per year)
NOs. 0.06" 4
co. a9ai) 13,162
PMio 0.9" 61
‘SOz 66.2" 4,491
HS: 1.22 83
He 0.0008" 0.0535,
cor 2,361" 160,168
oh er) ry
wo
cOxe 10,511 713,102

{a} Environmental influence of Gaseous Emissions from Seif Heating Coal Waste Dumps Silesia, Poland,
Fablaska M, Cesilcaukl, Nadudvar A Mlse-Kennan Mi, Kowalski A, Kruszewskit. Environ Geochem
Health, 2019 Apr;41(2)'575-601. dot 10.1007/s10653-018-0153-5. Epub 2018 Jul 24

https wow nein

,oulpme/artiles/PMICE510836

(2) Gielsch #, KroppC., Coal Fires a Major Source of Greenhouse Gases- 0 Forgotten Problem.
Environmental Risk Assessment and Remediation 2017; 2(0}: 5-8;

hutps//wmwaliedacademies.org/articles/coal-fies-a-major-source-of greenhouse-gases-a-orgotten
5roblem-8871,htm!

(33) ARIPPA substituted value for CH reduced from 0.7625 (Gielisch) to 0.163, substituted to add
conservatism and consistency with reported values

Application of the same assumptions to the entire estimated 80,000,000 yds* (estimated 86,400,000
tons at 80 Ib/ft?) of total AML GOB plus Non-Gob coal refuse in VA. Assuming the same ratios of 40%

19




 

20 
 

of piles smoldering/burning, and 21% of coal in each actively burning, we get  an estimated 

86,400,000 tons X .4 X .21 divided by an assumed 10 years duration = 725,760 tons of Virginia AML 

GOB plus non-GOB in some state of smoldering or actively burning in any given year. If a 

representative subset of the estimated 86,400,000 tons of total AML eligible GOB plus managed non-

GOB coal refuse in Virginia were in some state of smoldering or actively burning at the equivalent 

rate, in any given year, that would equate to 725,760  tons of total coal refuse emitting air pollutants 

and CO2e as shown in Table 3-2.  

Table 3-2 

      
AML GOB + Non-GOB Inventory Emissions due to Spontaneous Combustion 
   

Assumptions:   
Amount of in-situ AML GOB + Non-GOB waste coal in VA 86,400,000 tons 

Referenced Ratios "as typical", 40% of all piles spontaneously combusting, and 
21% of each combusting pile is actively burning18 725,760 tons 

Assumed Duration 
 10 years 

Piles spontaneously burning 
 40% 

Amount of pile that is burning 
 

21% 

Estimated % of State AML GOB inventory burning at any one time 
8% 

Table 3-2  Estimated Air Emissions from AML GOB + Non-GOB Piles in Virginia due to 8% Continuously in Active Spontaneous 
Combustion  

   
  

Pollutant 
Emission Factor 

(lb/ton from AML GOB Piles 
Burning) 

Annual Estimated Emissions Assuming 8% of 
Inventory Burning  

(tons per year) 

 

NOx 0.06⁽¹⁾ 22  

CO 194⁽¹⁾ 70,399  

PM10 0.9⁽¹⁾ 327  

SO2 66.2⁽¹⁾ 24,021  

H2S 1.22⁽¹⁾ 443  

Hg 0.0008⁽¹⁾ 0.286  

CO2 2,361⁽¹⁾ 856,687  

CH4 326 (33) 118,299  

N2O      

CO2e 10,511⁽²⁾ 3,814,159  

(1) Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste Dumps in Silesia, Poland, Fabiańska M, Ciesielczuk J, Nádudvari Á, 
Misz-Kennan M, Kowalski A, Kruszewski Ł. Environ Geochem Health. 2019 Apr;41(2):575-601. doi: 10.1007/s10653-018-0153-5. Epub 2018 Jul 24. 

 

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6510838/ 
 

(2) Gielisch H., Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. Environmental Risk Assessment and Remediation 
2017; 2(1): 5-8; 

 

https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-problem-8871.html  

(33)  ARIPPA substituted value for CH4 reduced from 0.7625 (Gielisch) to 0.163, substituted to add conservatism and consistency with reported 
values  

 

    

   
 

Tables 3-1 and 3-2 indicate the estimated magnitude of potential annual emissions of CO2e due to the 

natural processes of smoldering and open burning of as much as 3.8 million tons (Table 3-2) of CO2e 

potentially being added to the global GHG budget every year, just due to the process of spontaneous coal 

nx TRC 650 Suffolk St., Suite 200 9789705600
7 4 Lowell, MA 01854 TRCcompanies.com

of piles smoldering/burning, and 21% of coal in each actively buming, we get an estimated
86,400,000 tons X .4 X .21 divided by an assumed 10 years duration = 725,760 tons of Virginia AML
GOB plus non-GOB in some state of smoldering or actively burning in any given year. If a
representative subset of the estimated 86,400,000 tons of total AML eligible GOB plus managed non-
GOB coal refuse in Virginia were in some state of smoldering or actively burning at the equivalent
rate, in any given year, that would equate to 725,760 tons of total coal refuse emitting air pollutants
and COze as shown in Table 3-2.

Table 3-2

AML GOB + Non-GOB Inventory Emissions due to Spontaneous Combustion

‘Assumptions:
Amount of in-situ AML GOB + Non-GO8 waste coal in VA 86,400,000 tons
Referenced Ratios "as typical’, 40% ofall piles spontaneously combusting, and
2156 of each combusting pile is actively burning?® 725,760 tons
‘Assumed Duration 10 years
Piles spontaneously burning 40%
‘Amount of pile that is burning 21%
Estimated % of State AML GOB inventory burning at any one time

8%

‘Table 3-2 Estimated Air Emissions from AML GOB + Non-GOB Piles in Virginia due to 8% Continuously in Active Spontaneous
Combustion

Emission Factor ‘Annual Estimated Emissions Assuming 8% of
Pollutant {lh/ton from AML GOB Piles Inventory Burning
Burning) (tons per year)
NO. 0.08 2
© Tea 70,398
Pie osm 327
502 662" 24021
HS Ta a3
He 0.0008" 0.286
CO; 23617 356,687
CH 326 (33), 118,289
No
Coxe Tosi 3,818,159

(a) Environmental influence of Gaseous Fmisions from Self Heating Coal Waste Dumps In Silesia, Poland, Fabianska My, Ceselezuk, Naduavar A,
'Mise-Kennan M, Kowalski , Kruszewsk &. Environ Geochem Health. 2019 Apr;41(2)575-601. doi: 10.1007/s10653-018.0153-5, Epub 2018 Jul 24

https /wwnebi.nin.sih gov/pme/artcies/PMC5510838)

(2) ielsch #, Kropp C., Coal Fires @ Major Source of Greenhouse Gases-o Forgotten Problem. Environmental Risk Assessment and Remediation
2017; 20): 58;

http://w aliedacaderies.org/aticles/coal-fies-2-major-source-of greenhouse-ga50s-2forgotten-problem-8871.htm!

(23) ARIPPA substituted value for CHA reduced from 0.7625 (Gieisch) to 0.163, substituted to add conservatism and consistency with reported
values

Tables 3-1 and 3-2 indicate the estimated magnitude of potential annual emissions of COze due to the

natural processes of smoldering and open burning of as much as 3.8 million tons (Table 3-2) of CO.e

potentially being added to the global GHG budget every year, just due to the process of spontaneous coal
20




 

21 
 

refuse combustion of an assumed 8% of the entire GOB + Non-GOB inventory in the Commonwealth of 

Virginia.  

Projected Annual Air Emissions from Un-remediated Coal Refuse Piles 

in VA due to Gradual Weathering plus Spontaneous Combustion  

Based upon the source material relied upon and the Virginia Energy inventory of the quantity of AML 

abandoned coal refuse, and  AML GOB plus Non-GOB, summing the estimated annual air emissions 

from doing nothing about these piles and impoundments suggests that left abandoned and undergoing 

weathering plus spontaneous combustion, they represent an important impediment to achieving net 

zero GHG emissions in the region, Virginia, U.S. and globally. The environmental community has 

focused on phasing out extraction and burning of fossil fuel from its long-sequestered state within the 

earth, however abandoned or impounded coal refuse has already been extracted and then discarded – 

it can never be returned to a naturally occurring underground coal seam. 

As stated, all coal continuously weathers when left exposed to the elements, generating similar 

emissions at a much slower rate – primarily as the carbon content of the coal refuse gradually 

weathers to CO2 and CH4. In this estimate, we assumed that the top 2 feet of the entire estimated 

surface area of AML GOB piles in Virginia are undergoing slow oxidation, and estimating the annual 

emissions from that many tons of coal refuse, and applying the emission factors from the Literature, we 

estimated annual emissions due to annual weathering of the top two feet of coal refuse acreage. 

 
In Table 4-1, we sum the estimated annual air emissions of weathering plus spontaneous combustion 

of the AML legacy coal refuse piles in VA, to identify the sheer magnitude of their continuous 

contribution of air pollutants to the environment, frustrating the progress being made elsewhere in 

improvements to air quality and climate change. 

 

Table 4-1 
 

Estimated Air Emissions from Existing pre SMCRA AML GOB Coal Refuse Piles in Virginia due to Weathering plus 
Spontaneous Combustion 

Pollutant 

Annual Emissions (Tons) 

Annual Air Emissions (tons/yr) 
AML GOB Coal Refuse 

Weathering In-situ  
(From Table 2-3) 

Annual Air Emissions (Tons) AML 
GOB Coal Refuse Smoldering or 
Burning In-situ (From Table 3-1) 

Total Estimated Annual Air 
Emissions, Weathering plus 
Smoldering or burning in-

situ 

NOx   4 4 

CO   13,162 13,162 

PM10   61 61 

SO2   4,491 4,491 

CO2 4,299 160,168 164,466 

CH4 594 22,117 22,711 

H2S   83 83 

Hg   0.1 0.1 

CO2e 19,138 713,102 732,241 

The researchers did not identify any information regarding formation of the ultra-potent GHG N2O from natural oxidation of coal 
refuse piles, and this represents a potential area for additional research    

 

 

 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

refuse combustion of an assumed 8% of the entire GOB + Non-GOB inventory in the Commonwealth of
Virginia.

Projected Annual Air Emissions from Un-remediated Coal Refuse Piles
in VA due to Gradual Weathering plus Spontaneous Combustion

Based upon the source material relied upon and the Virginia Energy inventory of the quantity of AML
abandoned coal refuse, and AML GOB plus Non-GOB, summing the estimated annual air emissions
from doing nothing about these piles and impoundments suggests that left abandoned and undergoing
weathering plus spontaneous combustion, they represent an important impediment to achieving net
zero GHG emissions in the region, Virginia, U.S. and globally. The environmental community has
focused on phasing out extraction and burning of fossil fuel from its long-sequestered state within the
earth, however abandoned or impounded coal refuse has already been extracted and then discarded —
it can never be returned to a naturally occurring underground coal seam.

As stated, all coal continuously weathers when left exposed to the elements, generating similar
‘emissions at a much slower rate — primarily as the carbon content of the coal refuse gradually
weathers to CO, and CH.. In this estimate, we assumed that the top 2 feet of the entire estimated
surface area of AML GOB piles in Virginia are undergoing slow oxidation, and estimating the annual
emissions from that many tons of coal refuse, and applying the emission factors from the Literature, we
estimated annual emissions due to annual weathering of the top two feet of coal refuse acreage.

In Table 4-1, we sum the estimated annual air emissions of weathering plus spontaneous combustion
of the AML legacy coal refuse piles in VA, to identify the sheer magnitude of their continuous
contribution of air pollutants to the environment, frustrating the progress being made elsewhere in
improvements to air quality and climate change.

Table 4-1

Estimated Ar Emissions from Existing pre SMCRA AML GOB Coal Refuse Piles in Virginia due to Weathering plus
Spontaneous Combustion

Annual Emissions (Tons)
“Annual Air Emissions (tons/ye) Total Estimated Annual Air
ponutant | nt GOB coal Refuse | AMRUALA Emissions (Tons) AML | sions, Weathering pls
Weathering in-situ OB coal Refuse Smeldering | 'Sreierng or uring
(From Table 2-3) ne situ
NOx a 4
73,162 13,162
Pio a 6
‘S02 4,491 4,491
©; 4299 760,168 164,466
oe 334 2,7 22711
HS 83 83
He oa oa
ie 19,138 713,102 72241

‘The researchers did nat identify any information regarding formation ofthe ultra-potent GHG N20 from natural oxidation of coal
refuse piles, and this represents a potential area for additional research

21




 

22 
 

 

In Table 4-2, we performed the same methodology to estimate the potential total GHG emissions potential 

of the entire AML GOB and Non-GOB State estimate for the sum of gradual weathering plus the process 

of spontaneous combustion. Assuming that all 80 million cubic yards of total coal refuse in PA can 

generate GHG at the same rate as abandoned AML GOB, potential annual GHG emissions due to coal 

refuse in Virginia could represent as much as 3.9 million tons of CO2e every year! 

 

Table 4-2 
 
 
Estimated Air Emissions from Total AML GOB + Non-GOB Coal Refuse in Virginia due to Weathering plus Spontaneous 

Combustion 

Pollutant 

Annual Emissions (Tons) 

Annual Air Emissions (tons/yr) 
AML GOB Coal Refuse 

Weathering In-situ (From Table 
2-4) 

Annual Air Emissions (Tons) AML GOB 
Coal Refuse Smoldering or Burning 

In-situ (From Table 3-2) 

Total Estimated Annual Air 
Emissions, Weathering plus 
Smoldering or burning in-

situ 

NOx   22 22 

CO   70,399 70,399 

PM10   327 327 

SO2   24,021 24,021 

CO2 21,513 856,687 878,200 

CH4 2,971 118,299 121,270 

H2S   443 443 

Hg   0.3 0.3 

CO2e 95,782 3,814,159 3,909,941 

The researchers did not identify any information regarding formation of the ultra-potent GHG N2O from natural oxidation of coal 
refuse piles, and this represents a potential area for additional research  

 
 

Managed impoundments may emit less air pollutants than abandoned piles subject to SMCRA, 

however even 50% of the cited emissions from impoundments would still represent millions of tons per 

year of CO2e being emitted. 

 
 

  
Beyond the magnitude of the sheer tons of pollutants being emitted every year from VA coal refuse, the 

local community impacts compared to well-controlled combustion are much greater since products of 

incomplete combustion, generation of air toxics (such as hydrogen sulfide gas) and the much more 

potent greenhouse gases methane and nitrous oxide, are effectively oxidized to more benign pollutants 

when combusted fully and treated in the VCHEC CFB boilers. Controlled oxidation CFB emissions such 

as the sulfur dioxide (SO2) product of oxidizing hydrogen sulfide, or oxides of nitrogen (NOx) from 

oxidizing the potent greenhouse gas nitrous oxide, together with fine particulate (PM10) which is also 

emitted uncontrolled from coal refuse piles as fugitive dust, are then captured and removed at high 

efficiency using USEPA mandated Best Available Control Technology (BACT) emission controls. 

Finally, CFB boilers disperse those trace residual air pollutant concentrations through EPA regulated 

emissions from engineered stacks and are shown via USEPA air dispersion models to document that 

the resulting air emissions comply with all U.S. health-based National Ambient Air Quality Standards 

(NAAQS). 

 

650 Suffolk St, Suite 200
Lowell, MA 01854

79789705600
‘TRCcompanies.com

} TRC

In Table 4-2, we performed the same methodology to estimate the potential total GHG emissions potential
of the entire AML GOB and Non-GOB State estimate for the sum of gradual weathering plus the process
of spontaneous combustion. Assuming that all 80 million cubic yards of total coal refuse in PA can
generate GHG at the same rate as abandoned AML GOB, potential annual GHG emissions due to coal
refuse in Virginia could represent as much as 3.9 million tons of COze every year!

Table 4-2

Estimated Ar Emissions from Total AML GOB + Non-GOB Coal Refuse in Virginia due to Weathering plus Spontaneous
Combustion

“Annual Emissions (Tons)
‘Annual Air Emissions (tons/¥f) Total Estimated Annual Air
potutant | aL GOB coal Refuse | ANUALAK Emissions (Tons) AML GOB | isons, Weathering Bs
Weathering In-situ (From Table "| smoldering or burning in-
In-situ (From Table 3.2) °
24) situ
NO. 2 2
ro 70,388 70,399
Pio 37 37
30; 202 24,021
oy 513 356,687 878,200
He 2971 118,298 121,270
Hs co a3
He 03 03
Cre 95,782 3,814,159 3,909,941

‘The researchers did not identify any information regarding formation of the ultra-potent GHG N20 from natural oxidation of coal
refuse ples, and tis represents a potential area for additional research

Managed impoundments may emit less air pollutants than abandoned piles subject to SMCRA,
however even 50% of the cited emissions from impoundments would still represent millions of tons per
year of CO2e being emitted.

Beyond the magnitude of the sheer tons of pollutants being emitted every year from VA coal refuse, the
local community impacts compared to well-controlled combustion are much greater since products of
incomplete combustion, generation of air toxics (such as hydrogen sulfide gas) and the much more
potent greenhouse gases methane and nitrous oxide, are effectively oxidized to more benign pollutants
when combusted fully and treated in the VCHEC CFB boilers. Controlled oxidation CFB emissions such
as the sulfur dioxide (SO2) product of oxidizing hydrogen sulfide, or oxides of nitrogen (NOx) from
oxidizing the potent greenhouse gas nitrous oxide, together with fine particulate (Mio) which is also
emitted uncontrolled from coal refuse piles as fugitive dust, are then captured and removed at high
efficiency using USEPA mandated Best Available Control Technology (BACT) emission controls.
Finally, CFB boilers disperse those trace residual air pollutant concentrations through EPA regulated
emissions from engineered stacks and are shown via USEPA air dispersion models to document that,
the resulting air emissions comply with all U.S. health-based National Ambient Air Quality Standards

(NAAQS)

22




 

23 
 

Conversely, uncontrolled air emissions from the surface of un-remediated abandoned coal refuse piles 

are emitted without the benefit of controlled oxidation, any emission control, dispersion in the atmosphere, 

regulated health-based air concentration standards, or any USEPA or state air quality oversight and 

regulation. Ground level emissions from these piles can be observed from the smoke wafting from the 

piles and the odor of sulfur compounds impacting nearby populations. Air emissions from abandoned coal 

refuse piles throughout Virginia can present clear and present impacts to local ambient air quality. 

 

Projected Net Air Emissions From Remediating (Combusting) Coal 
Refuse 

 
Based on the sheer magnitude of both CO2e and criteria air pollutants estimated to be emitted 

uncontrolled, unregulated and at ground level every year from un-remediated coal refuse piles in 

Virginia, it is then useful to compare those ongoing air impacts on an equivalent tons remediated per 

year basis with the air emission limitations required by USEPA from the VCHEC coal refuse 

reclamation-to-energy facility actively remediating them. In 2022, the VCHEC facility permanently 

remediated (and permanently neutralized) a reported 618,510 tons of abandoned coal refuse, and this 

rate is expected to continue or  increase significantly  in future years. Obviously, once the organic 

content of each ton of coal refuse is permanently removed from the legacy coal refuse inventory, that 

same amount can never again emit products of incomplete combustion. Absent permanent remediation, 

coal refuse will continue to generate air emissions well beyond 2050, as some of the oldest piles 

already have been for over one hundred years.  

 
Initially, we apportioned the actual annual emissions in calendar year 2022 from the VCHEC facility for 

that portion of total facility fuels reported as GOB and Non-GOB coal refuse. We then compared the 

allocated air emissions from combusting a total of 618,510 tons of waste coal in VA with the annual 

emissions that would have been released from the same amount of un-remediated AML GOB coal 

refuse if allowed to simply remain in situ. Since VCHEC combusts multiple fuels, including renewable 

biomass, it is difficult to assign specific emissions from the totals to that portion of fuel that is coal refuse.  

We therefore assumed the VHEC Permit Limits for criteria pollutants, emission factors for Bituminous 

coal firing reduced by % capture and control  and proportioned the heat input of total waste coal time 

published emission factors for GHG emissions from Eastern Bituminous Coal. That comparison provides 

a summary of the GHG and criteria pollutant impacts of permanent remediation of coal refuse through 

controlled energy recovery that occurred in one year (Table 5). Table 5 shows that VCHEC’s 

apportioned waste coal combustion emits somewhat more NOx in a single year than the same amount of 

coal refuse emitting nitrogen products in situ, because NOx formation is extremely combustion 

temperature dependent. However, VCHEC controls its NOx emissions generated by 80-90% prior to 

release from its stacks. It is important here to consider that both NOx and volatile organic compounds 

(VOC) contribute to downwind ozone formation and that the same factors that cause higher methane 

emissions from waste coal similarly cause higher uncontrolled emissions of VOC in the process of 

spontaneous combustion. 

 

Net GHG emissions as measured in units of CO2e from remediating an annual quantity of coal refuse 

compared to allowing that same amount of material to continue to emit air pollutants passively was the 

most compelling question for this study. As shown in the bottom row of Table 5, permanent 

remediation of existing abandoned coal refuse in SW Virginia by the coal refuse reclamation-to-energy 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com

Conversely, uncontrolled air emissions from the surface of un-remediated abandoned coal refuse piles
are emitted without the benefit of controlled oxidation, any emission control, dispersion in the atmosphere,
regulated health-based air concentration standards, or any USEPA or state air quality oversight and
regulation. Ground level emissions from these piles can be observed from the smoke wafting from the
piles and the odor of sulfur compounds impacting nearby populations. Air emissions from abandoned coal
refuse piles throughout Virginia can present clear and present impacts to local ambient air quality.

Projected Net Air Emissions From Remediating (Combusting) Coal
Refuse

Based on the sheer magnitude of both CO2e and criteria air pollutants estimated to be emitted
uncontrolled, unregulated and at ground level every year from un-remediated coal refuse piles in
Virginia, it is then useful to compare those ongoing air impacts on an equivalent tons remediated per
year basis with the air emission limitations required by USEPA from the VCHEC coal refuse
reclamation-to-energy facility actively remediating them. In 2022, the VCHEC facility permanently
remediated (and permanently neutralized) a reported 618,510 tons of abandoned coal refuse, and this,
rate is expected to continue or increase significantly in future years. Obviously, once the organic
content of each ton of coal refuse is permanently removed from the legacy coal refuse inventory, that
same amount can never again emit products of incomplete combustion. Absent permanent remediation,
coal refuse will continue to generate air emissions well beyond 2050, as some of the oldest piles
already have been for over one hundred years.

Initially, we apportioned the actual annual emissions in calendar year 2022 from the VCHEC facility for
that portion of total facility fuels reported as GOB and Non-GOB coal refuse. We then compared the
allocated air emissions from combusting a total of 618,510 tons of waste coal in VA with the annual
‘emissions that would have been released from the same amount of un-remediated AML GOB coal
refuse if allowed to simply remain in situ. Since VCHEC combusts multiple fuels, including renewable
biomass, itis difficult to assign specific emissions from the totals to that portion of fuel that is coal refuse.
We therefore assumed the VHEC Permit Limits for criteria pollutants, emission factors for Bituminous
coal firing reduced by % capture and control _and proportioned the heat input of total waste coal time
Published emission factors for GHG emissions from Eastern Bituminous Coal. That comparison provides
a summary of the GHG and criteria pollutant impacts of permanent remediation of coal refuse through
controlled energy recovery that occurred in one year (Table 5). Table 5 shows that VCHEC's
apportioned waste coal combustion emits somewhat more NOx in a single year than the same amount of
coal refuse emitting nitrogen products in situ, because NOx formation is extremely combustion
temperature dependent. However, VCHEC controls its NOx emissions generated by 80-90% prior to
release from its stacks. It is important here to consider that both NOx and volatile organic compounds
(VOC) contribute to downwind ozone formation and that the same factors that cause higher methane
emissions from waste coal similarly cause higher uncontrolled emissions of VOC in the process of
spontaneous combustion.

Net GHG emissions as measured in units of COze from remediating an annual quantity of coal refuse
compared to allowing that same amount of material to continue to emit air pollutants passively was the
most compelling question for this study. As shown in the bottom row of Table 5, permanent
remediation of existing abandoned coal refuse in SW Virginia by the coal refuse reclamation-to-energy

23




 

24 
 

2 

industry is responsible for the net reduction of at least 2,601,765 net tons of CO2e every year that they 

continue to operate as in cy 2022. 

 
Coal refuse reclamation-to-energy plants are very efficient in terms of converting nearly 100% of the 

hydrocarbon component of abandoned coal refuse to CO2. When they do so, they remove the ability of 

that amount of abandoned coal refuse to emit any carbon, ever again. The tremendous net benefit of 

the coal refuse reclamation-to-energy industry is that purposefully converting hydrocarbons efficiently to 

CO2 to produce needed energy nearly eliminates all of the emissions of methane that would otherwise 

be emitted over many more years. 

 
Since Methane reductions are far more beneficial near-term (as much as 81 times more potent than 

CO2) in frustrating climate recovery goals, and even according to USEPA’s 100-year CO2e equivalency 

standard10 methane is 25-28 times more potent of a greenhouse gas than CO2, CH4 emissions are 

much more impactful in frustrating net zero CO2e reduction goals. Elimination of existing methane 

emissions in favor of CO2 has a much more important benefit in terms of reversing climate change 

now, as it is estimated to persist in the atmosphere for only about 20 years compared with the 100-year 

life of CO2. According to the literature, in the near term (i.e., by 2050), preventing ongoing emissions of 

methane in place of the same amount of carbon as CO2, will have about 81 times the global GHG 

benefit of reducing any ton   anywhere in the U.S. of CO2 9. For conservatism in this analysis, these 

near-term “super benefits” have been ignored in favor of the 100-year lifetime convention of 25-28 

times the GHG potency of CO2 as commonly referenced in most Scope 1 GHG sustainability 

comparisons. 

 

It is important to compare the bottom row of Table 5 (also presented in the Executive Summary, Table 

1), which compares the net benefit to lifecycle GHG emissions measured in CO2e from coal refuse 

either allowed to remain in situ passively emitting pollutants or remediated forever for responsible 

energy recovery. At the current rate of coal refuse reclamation, the global GHG inventory will have 

been reduced by a quarter billion tons or more of CO2e over the next ten years for each year the 

existing Northern Appalachian coal refuse reclamation-to-energy plants alone continue operating.  

 
Table 5 Shows that in 2022 VCHEC may have reduced passive CO2e emissions to the environment 

between 2.6 million tons (based on 618,510 tons of coal refuse remediated) to as much as 32.5 

million tons accounting for a lifecycle of continuing CO2e emissions that may have been otherwise 

emitted from being abandoned in place and never remediated. 

 

Either way, permanent destruction and conversion to needed electricity by the coal refuse-to-energy 

Industry is capable of reducing millions of tons of CO2e otherwise being continuously emitted to the 

environment, while also permanently remediating substantial quantities of legacy waste coal every year  

at little to no additional costs to the Commonwealth.  As such, coal refuse to energy facilities should be 

supported and encouraged to continue and to expand their important role in the permanent remediation 

of coal refuse and also reigning in CO2e contributions from the Commonwealth of Virgina, Appalachia, 

the US and Globally.    

 

 
 

 
 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

industry is responsible for the net reduction of at least 2,601,765 net tons of CO2e every year that they
continue to operate as in cy 2022.

Coal refuse reclamation-to-energy plants are very efficient in terms of converting nearly 100% of the
hydrocarbon component of abandoned coal refuse to COz, When they do so, they remove the ability of
that amount of abandoned coal refuse to emit any carbon, ever again. The tremendous net benefit of
the coal refuse reclamation-to-energy industry is that purposefully converting hydrocarbons efficiently to
COzto produce needed energy nearly eliminates all of the emissions of methane that would otherwise
be emitted over many more years

Since Methane reductions are far more beneficial near-term (as much as 81 times more potent than
CO.) in frustrating climate recovery goals, and even according to USEPA's 100-year COze equivalency
standard"® methane is 25-28 times more potent of a greenhouse gas than CO2, CH4 emissions are
much more impactful in frustrating net zero COze reduction goals. Elimination of existing methane
emissions in favor of CO; has a much more important benefit in terms of reversing climate change
now, as it is estimated to persist in the atmosphere for only about 20 years compared with the 100-year
life of CO2, According to the literature, in the near term (i.¢., by 2050), preventing ongoing emissions of
methane in place of the same amount of carbon as Cz, will have about 81 times the global GHG
benefit of reducing any ton anywhere in the U.S. of CO». For conservatism in this analysis, these
near-term “super benefits” have been ignored in favor of the 10-year lifetime convention of 25-28
times the GHG potency of CO as commonly referenced in most Scope 1 GHG sustainability
comparisons.

Itis important to compare the bottom row of Table 5 (also presented in the Executive Summary, Table
1), which compares the net benefit to lifecycle GHG emissions measured in COze from coal refuse
either allowed to remain in situ passively emitting pollutants or remediated forever for responsible
energy recovery. At the current rate of coal refuse reclamation, the global GHG inventory will have
been reduced by a quarter billion tons or more of COze over the next ten years for each year the
existing Northern Appalachian coal refuse reclamation-to-energy plants alone continue operating.

Table 5 Shows that in 2022 VCHEC may have reduced passive COze emissions to the environment
between 2.6 n tons (based on 618,510 tons of coal refuse remediated) to as much as 32.5
million tons accounting for a lifecycle of continuing COze emissions that may have been otherwise
emitted from being abandoned in place and never remediated.

Either way, permanent destruction and conversion to needed electricity by the coal refuse-to-energy
Industry is capable of reducing millions of tons of COze otherwise being continuously emitted to the
environment, while also permanently remediating substantial quantities of legacy waste coal every year
at little to no additional costs to the Commonwealth. As such, coal refuse to energy facilities should be
supported and encouraged to continue and to expand their important role in the permanent remediation
of coal refuse and also reigning in COze contributions from the Commonwealth of Virgina, Appalachia,
the US and Globally.

24




 

25 
 

 
 

 
 
Table 5 
 

Pollutant 
Global 

Warming 
Potential(2) 

Weathering + Burning/Smoldering 
Typical GOB In-Situ 

GOB Combustion in  
VCHEC CFB Boilers - 2022 

Net Air Quality Benefit of Remediation via 
Controlled Combustion 

 (tons) 

Emission 
Factor 

 
(ton/ton 

Coal 
Refuse 

burning) 

Estimated  
Emissions 

for 618,510 
tons of 

Coal Refuse 
Weathering 

 (tons) 

Estimated  
Emissions 

for 
618,510 
tons of 

Coal 
Refuse 

Smoldering 
/ Burning 

 (tons) 

Estimated 
Total 

Annual 
Emissions 
Associated 

with  
618,510 
tons of 

GOB 
Remaining 

in-situ 
(tons) 

Potential 
10-yr 

Lifecycle 
Emissions 
Associated 

with  
618,510 
tons of 

GOB 
Remaining 

in-situ 
(tons) 

VCHEC 
Emission 

Factor 
 

(lb/MMBtu) 

Estimated 
VCHEC 

Waste Coal 
Emissions 
attributed 

to 
remediation 
of 618,510 

tons of Coal 
Refuse in 

2022 
 (tons) 

Net 
Comparison 

based on 
Estimated 
Emissions 
per ton of 

Coal Refuse 
Being 

Oxidized in 
Situ 

 (tons) 

Net 
Comparison 

based on 
Estimated 
Potential 
Lifecycle 

Emissions 
 (tons) 

Estimated 
Tons of 

Potential 
Lifecycle 

net 
Emissions 
per ton of 

Waste Coal 
Neutralized 

 

NOx 
  

0.00003   18.6 18.6 185.6 0.07000 249 230  63  0.0001 

CO 
  

0.09970   61,665 61,665.4 616,654 0.10000 356 (61,310) (616,299) (0.9964) 

PM10 
  

0.00045   278.3 278.3 2,783 0.00900 32 (246) (2,751) (0.004) 

SO2 
  

0.00084   519.5 519.5 5,195 0.02200 78 (441) (5,117) (0.01) 

CO2 
1 

1.180⁽⁴⁾ 14,602 729,842 744,443.6 7,298,418 181.5 645,506 (84,336) (6,652,912) (10.76) 

CH4 
25 

0.163 
(33) 

2,016 100,817 102,833.5 1,008,171 0.03374 120 (100,697) (1,008,051) (1.63) 

N2O 
298 

---                   

CO2e 
  

  65,010 3,250,270 3,315,280 33,152,804   648,505 (2,601,765) (32,504,299) (52.55) 

                       

1. From VCHEC 2022 

2. 40 CFR 98 Subpart A Table A-1       

3. Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste Dumps in Silesia, Poland, Fabiańska M, Ciesielczuk J, Nádudvari Á, Misz-Kennan M, 
Kowalski A, Kruszewski Ł. Environ Geochem Health. 2019 Apr;41(2):575-601. doi: 10.1007/s10653-018-0153-5. Epub 2018 Jul 24. 

4. Gielisch H, Kropp C., Coal Fires a Major Source of Greenhouse Gases- a Forgotten Problem. Environmental Risk Assessment and Remediation 2017; 2(1): 5-8; 
 

https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-problem-8871.html  

33.  ARIPPA substituted value for CH4 reduced from 0.7625 to 0.163, substituted to add conservatism and consistency with reported values   

            

Alternatives to Permanent Coal Refuse Pile Remediation 
 
Governments and environmental advocates have been seeking practical alternatives for the remediation 

of abandoned coal refuse piles for generations – yet smoking piles persist. 

 

Sporadically extinguishing individual coal refuse pile fires and/or non-impermeable capping and grading 

with re-vegetation to mitigate acid runoff and/or to improve their aesthetics does not eliminate their air 

and water quality impacts to the environment. It has been postulated that increased taxpayer funding 

could be used to plant abandoned coal refuse piles with “green” shallow root system plants, such as 

beach grass. It is important to note that naturally occurring and undisturbed seams of bituminous or 

anthracite coal prior to mining are essentially uniform prehistoric deposits of CO2 and other pollutants 

nx TRC 650 Suffolk St., Suite 200 9789705600
7 4 Lowell, MA 01854 TRCcompanies.com

Table 5
Westeing + Bring Soldering oecambustionin | NAF ust Benet Remediation via
“pies 08 Init OH C8 Boer 2022 “cor
timated | “tal | toy a ae strated
rotten | wang | Emson | esas | E™EOM | Mae | sos “emasore | B282° | compan | ret
rotensal> | Factor | Emssions | Grasso | asocates | Assoeated | OWES | serbutes | timate | “oreson | Uteeycle
foreiasi0 éision fission
tconton | “tonsor | reat | gwth | | wth | | cor £2 on | pertonor | timated | net
onion | onset | “coat | siasio | 6i8sio remediation | 222% | potensat_ | Emisions
ae, | Goatreise | getse | tomof | torsot | amamaouy | oreiesio | MP | tee | pertno
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4. GllsehH, Kopp C, Cool res Moje Source of Greenhouse Gases- Forgotten Problem. Environmental Rsk Assessment and Remediation 2017; 21} 58;

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Alternatives to Permanent Coal Refuse Pile Remediation

Governments and environmental advocates have been seeking practical alternatives for the remediation
of abandoned coal refuse piles for generations — yet smoking piles persist.

Sporadically extinguishing individual coal refuse pile fires and/or non-impermeable capping and grading
with re-vegetation to mitigate acid runoff and/or to improve their aesthetics does not eliminate their air
and water quality impacts to the environment. It has been postulated that increased taxpayer funding
could be used to plant abandoned coal refuse piles with “green” shallow root system plants, such as
beach grass. It is important to note that naturally occurring and undisturbed seams of bituminous or
anthracite coal prior to mining are essentially uniform prehistoric deposits of CO2 and other pollutants

25





 

26 
 

already sequestered within the earth and have existed there in the lack of oxygen for millions of years. 

Coal refuse piles, on the other hand, have been mined and placed in the open, and contain mechanically 

shattered remnants, fragments, and fines of coal brought to the surface that exhibit tiny voids in the 

interstices between the crushed and broken chips. These voids are open to oxidation surrounding every 

coal particle surface. They are, on a gaseous level, porous. GHG’s generated within a vegetated GOB 

pile are not permanently sealed within – gas production products that are lighter than air (such as CO2 

and methane) will find their way out. 

 
These facts draw upon our collective experience and regulations regarding municipal waste landfills. 

Municipal solid waste is largely organic (hydrocarbon) based material that has been placed and 

compacted on top of an impervious liner, typically in multiple ten-foot “lifts”. U S EPA regulations 

require such landfills to be lined and encapsulated (“capped”) with impermeable liners, to prevent 

gaseous release of continuously generated methane to the air. In fact, methane emissions are 

required to be collected and burned to CO2 in reciprocating engines or turbines to produce 

“renewable” electricity. Lessons learned from this industry indicate that unless abandoned coal 

refuse piles could also be somehow permanently capped with a “forever” impervious barrier, they 

would still generate methane gas over many years requiring an engineered methane collection 

system and then a mandate to combust that methane to the less potent GHG CO2. It is not an 

accepted or allowed practice to simply plant over municipal waste landfills with beach grass or other 

vegetation, as those plantings could not prevent the generation and emission of evolving methane 

gas. The authors believe that USEPA municipal waste landfill closure requirements hold parallels to 

the much larger problem of abandoned coal refuse piles throughout Appalachia. There are two main 

differences, however – most active municipal landfills are still managed by an existing ownership, and 

secondly are much smaller in extent than abandoned coal refuse piles shown in Figure 1. Simply, 

maintaining an oxygen free deep pile via capping and collection of methane does not represent an 

economically or logistically sustainable possibility simply due to the sheer magnitude of legacy coal 

refuse piles in Appalachia. Even just planting and/or maintaining shallow root system plantings over 

thousands of acres of abandoned coal refuse is not self-funding nor economically sustainable. While 

planting abandoned coal refuse piles may reduce impacts from wind-blown dust and rainwater runoff 

entering downstream soil and surface water, planting or reforestation would not eliminate the 

presence of oxygen, remove the hazard of spontaneous combustion beneath the shallow roots, or 

permanently prevent future emissions of the potent greenhouse gas methane. 

 

One-time and permanent removal of the root cause of CO2e emissions from abandoned coal refuse 

by the coal refuse reclamation-to-energy industry is therefore the only known forever remediation 

process that is permanent, proven over many years of operation, already in place and economically 

sustainable. While alternatives may have aesthetic and acid run-off merits, they cannot avoid the 

passive GHG emission legacy of the potent GHG methane. 

 

USEPA studies of potential alternatives to prevent spontaneous combustion of coal refuse piles3,8 

suggest that every pile would need to be permanently and anaerobically sealed from the air and that 

methane collection systems or padding with an inert gas such as nitrogen would need to be 

continuously maintained to preclude the possibility of future spontaneous combustion and surface 

emissions. A simple field of beach grass growing on top of a coal refuse pile could not materially 

eliminate the ability of the pile to spontaneously combust or vent products of incomplete combustion 

to the surface from deep within. 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

already sequestered within the earth and have existed there in the lack of oxygen for millions of years.
Coal refuse piles, on the other hand, have been mined and placed in the open, and contain mechanically
shattered remnants, fragments, and fines of coal brought to the surface that exhibit tiny voids in the
interstices between the crushed and broken chips. These voids are open to oxidation surrounding every
coal particle surface. They are, on a gaseous level, porous. GHG's generated within a vegetated GOB
pile are not permanently sealed within — gas production products that are lighter than air (such as COz
and methane) will find their way out.

These facts draw upon our collective experience and regulations regarding municipal waste landfills.
Municipal solid waste is largely organic (hydrocarbon) based material that has been placed and
compacted on top of an impervious liner, typically in multiple ten-foot ‘lifts’. US EPA regulations
require such landfills to be lined and encapsulated (“capped”) with impermeable liners, to prevent
gaseous release of continuously generated methane to the air. In fact, methane emissions are
required to be collected and burned to CO> in reciprocating engines or turbines to produce
“renewable” electricity. Lessons learned from this industry indicate that unless abandoned coal
refuse piles could also be somehow permanently capped with a “forever” impervious barrier, they
would still generate methane gas over many years requiring an engineered methane collection
system and then a mandate to combust that methane to the less potent GHG COz. It is not an
accepted or allowed practice to simply plant over municipal waste landfills with beach grass or other
vegetation, as those plantings could not prevent the generation and emission of evolving methane
gas. The authors believe that USEPA municipal waste landfill closure requirements hold parallels to
the much larger problem of abandoned coal refuse piles throughout Appalachia. There are two main
differences, however — most active municipal landfills are still managed by an existing ownership, and
secondly are much smaller in extent than abandoned coal refuse piles shown in Figure 1. Simply,
maintaining an oxygen free deep pile via capping and collection of methane does not represent an
economically or logistically sustainable possibility simply due to the sheer magnitude of legacy coal
refuse piles in Appalachia. Even just planting and/or maintaining shallow root system plantings over
thousands of acres of abandoned coal refuse is not self-funding nor economically sustainable. While
planting abandoned coal refuse piles may reduce impacts from wind-blown dust and rainwater runoff
entering downstream soil and surface water, planting or reforestation would not eliminate the
presence of oxygen, remove the hazard of spontaneous combustion beneath the shallow roots, or
permanently prevent future emissions of the potent greenhouse gas methane.

One-time and permanent removal of the root cause of COze emissions from abandoned coal refuse
by the coal refuse reclamation-to-energy industry is therefore the only known forever remediation
process that is permanent, proven over many years of operation, already in place and economically
sustainable. While alternatives may have aesthetic and acid run-off merits, they cannot avoid the
passive GHG emission legacy of the potent GHG methane.

USEPA studies of potential alternatives to prevent spontaneous combustion of coal refuse piles®®
suggest that every pile would need to be permanently and anaerobically sealed from the air and that
methane collection systems or padding with an inert gas such as nitrogen would need to be
continuously maintained to preclude the possibility of future spontaneous combustion and surface
emissions. A simple field of beach grass growing on top of a coal refuse pile could not materially
eliminate the ability of the pile to spontaneously combust or vent products of incomplete combustion
to the surface from deep within

26




 

27 
 

In the authors’ opinion, only permanent removal of the coal refuse itself, impermeable capping with 

methane collection systems , or active nitrogen blanketing is capable of eliminating forever air 

emissions of gaseous methane resulting from oxidation and incomplete combustion of coal refuse 

piles. As with municipal waste landfills, once collected the most environmentally responsible solution 

is to then reduce its global warming potential by 25-28 times by simply combusting it to CO2 in a 

highly controlled manner. Of course, this is exactly what the coal refuse reclamation-to-energy 

industry has already been doing, at a significant savings to taxpayers, for over thirty years. 

Conclusions 
 

This study seeks to provide a characterization of the role of abandoned and managed coal refuse 

piles and impoundments located in Virginia (and Appalachia in general) in terms of frustrating local, 

national and global efforts to achieve ambitious net-zero greenhouse gas emissions goals by some 

target date, as well as understanding how these existing abandoned sources of pollution are 

disproportionately impacting the local remaining residents of once thriving coal mining areas in the 

Commonwealth. It is well documented that abandoned coal refuse piles will and do gradually emit 

uncontrolled and unregulated air pollutant emissions as long as such existing piles remain 

abandoned and, in many cases, “under the air quality radar”. 

 
The region relies heavily on the coal refuse reclamation-to-energy industry, which is presently the only 

practical permanent solution to remediate this legacy environmental hazard. Having characterized the 

potential adverse air quality emissions from abandoned coal refuse piles if allowed to continue releasing 

greenhouse gases and other air pollutants unabated, it is particularly useful to compare their estimated 

lifetime air pollution impacts with the highly controlled and Government regulated emissions from 

permanently remediating them by the coal refuse reclamation-to-energy industry. A comparison of the 

air emissions from not remediating existing legacy coal refuse piles shows that this industry is providing 

very significant net air quality and CO2e benefits to the environment every year  and should be further 

encouraged to do so. The data evaluated indicates that the coal refuse reclamation-to-energy industry 

in Virginia eliminated more than 2.6 million net tons of CO2e (Scope 1) in 2022 by combusting 618,510 

tons of VA GOB and Non-GOB coal refuse that is now permanently eliminated forever from the 

environment by converting its residual energy to useful power. That same amount of “net carbon 

reduced” energy will offset the equivalent grid produced CO2e for that same amount of electricity that it 

would not have to produce in Scope 2. This added benefit to global GHG emissions will vary over time 

(as the electric grid continues to expand its reliance on renewables) and has not been quantified in this 

study.  

 

The negative impact to our environment of doing nothing to break the methane degradation cycle of 

existing coal refuse is much greater than actively remediating coal refuse by harnessing its useful 

thermal energy with CFB technology, thereby dramatically reducing (especially in the near- term) the 

global budget of CO2e emissions annually, eliminating future pollution while improving local air, water 

and soil quality. By conducting a side-by-side comparison of uncontrolled coal refuse emissions 

versus controlled emissions in coal refuse-to-energy facilities, we arrive at a compelling conclusion. 

The impactful net benefit to the environment resulting in substantial reductions in CO2e more than 

justifies maintaining and encouraging this important, environmentally friendly niche waste coal 

remediation industry. 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

In the authors’ opinion, only permanent removal of the coal refuse itself, impermeable capping with
methane collection systems , or active nitrogen blanketing is capable of eliminating forever air
emissions of gaseous methane resulting from oxidation and incomplete combustion of coal refuse
piles. As with municipal waste landfills, once collected the most environmentally responsible solution
is to then reduce its global warming potential by 25-28 times by simply combusting it to CO2 in a
highly controlled manner. Of course, this is exactly what the coal refuse reclamation-to-energy
industry has already been doing, at a significant savings to taxpayers, for over thirty years,

Conclusions

This study seeks to provide a characterization of the role of abandoned and managed coal refuse
piles and impoundments located in Virginia (and Appalachia in general) in terms of frustrating local,
national and global efforts to achieve ambitious net-zero greenhouse gas emissions goals by some
target date, as well as understanding how these existing abandoned sources of pollution are
disproportionately impacting the local remaining residents of once thriving coal mining areas in the
Commonwealth. It is well documented that abandoned coal refuse piles will and do gradually emit
uncontrolled and unregulated air pollutant emissions as long as such existing piles remain
abandoned and, in many cases, “under the air quality radar’.

The region relies heavily on the coal refuse reclamation-to-energy industry, which is presently the only
practical permanent solution to remediate this legacy environmental hazard. Having characterized the
potential adverse air quality emissions from abandoned coal refuse piles if allowed to continue releasing
greenhouse gases and other air pollutants unabated, it is particularly useful to compare their estimated
lifetime air pollution impacts with the highly controlled and Government regulated emissions from
permanently remediating them by the coal refuse reclamation-to-energy industry. A comparison of the
air emissions from not remediating existing legacy coal refuse piles shows that this industry is providing
very significant net air quality and CO. benefits to the environment every year and should be further
‘encouraged to do so. The data evaluated indicates that the coal refuse reclamation-to-energy industry
in Virginia eliminated more than 2.6 million net tons of COze (Scope 1) in 2022 by combusting 618,510
tons of VA GOB and Non-GOB coal refuse that is now permanently eliminated forever from the
environment by converting its residual energy to useful power. That same amount of “net carbon
reduced” energy will offset the equivalent grid produced CO2e for that same amount of electricity that it
would not have to produce in Scope 2. This added benefit to global GHG emissions will vary over time
(as the electric grid continues to expand its reliance on renewables) and has not been quantified in this,
study.

The negative impact to our environment of doing nothing to break the methane degradation cycle of
existing coal refuse is much greater than actively remediating coal refuse by harnessing its useful
thermal energy with CFB technology, thereby dramatically reducing (especially in the near- term) the
global budget of CO2e emissions annually, eliminating future pollution while improving local air, water
and soil quality. By conducting a side-by-side comparison of uncontrolled coal refuse emissions
versus controlled emissions in coal refuse-to-energy facilities, we arrive at a compelling conclusion.
The impactful net benefit to the environment resulting in substantial reductions in CO.e more than
justifies maintaining and encouraging this important, environmentally friendly niche waste coal
remediation industry.

27




 

28 
 

 

Bibliography and References Cited 
 

1. Trout Unlimited, (2020). The West Branch Susquehanna - A Watershed in Recovery, 
www.tu.org 

 
2. U.S. Department of the Interior, U.S. Geological Survey (2009). Fact Sheet – Emissions from 

Coal Fires and their Impact on the Environment. 
 

3. Chalekode and Blackwood - United States Environmental Protection Agency, EPA 600 2 78 
004v (1978). Source Assessment – Coal Refuse Piles, Abandoned Mines and Outcrops, 
State of the Art. Industrial Environmental Research Laboratory, Cincinnati, Ohio, Contract 
68- 02-1874. 

 
4. Hughes – Eastern PA Coalition for Abandoned Mine Reclamation (2019). Abandoned Mine 

Land Reclamation: Innovative Approaches and Economic Development Opportunities. 
Legislative Hearing, Testimony before the PA Subcommittee on Energy and Mineral 
Resources. 

 
5.  USEPA Electronic Database, EPA eGRID, U.S. Environmental Protection Agency (2021). 

https://www.epa.gov/egrid 
 

6. Gielisch H, Kropp C.,(2017). Coal Fires a Major Source of Greenhouse Gases- a Forgotten 
Problem. Environmental Risk Assessment and Remediation 2017; 2(1): 5-8. 
https://www.alliedacademies.org/articles/coal-fires-a-major-source-of-greenhouse-gases-a-forgotten-problem-  
8871.html 

 

7. Fabiańska M, Ciesielczuk J, Nádudvari Á, Misz-Kennan M, Kowalski A, Kruszewski T., 
(2019). Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste 
Dumps in Silesia, Poland. Environ Geochem Health. 2019 Apr;41(2):575-601. doi: 
10.1007/s10653-018-0153-5. Epub 2018 Jul 24. 

 
8. Chalekode and Blackwood - United States Environmental Protection Agency, EPA 600 2 78 

004v (1978)USEPA (1978). Coal Refuse Piles, Abandoned Mines and Outcrops, State of the 
Art, EPA-600/2-78-004v, July 1978, Table 4. 

 

9. Brownstein et al, 2022. A Critical Opportunity in the Climate Fight. Environmental Defense 
Fund, https://www.edf.org/climate/methane-crucial-opportunity-climate-fight. 

 

10. Global Warming Potentials Relative to CO2, IPCC Fifth Assessment Report (AR 5), 
(2014). www.ipcc.ch. 

 
11.  US Environmental Protection Agency, Office of Solid Waste (1995). Human Health And 

Environmental Damages From Mining And Mineral Processing Wastes; Technical 
Background Document. 

 

12.ICF (2020). Draft, Pennsylvania Climate Action Plan 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

Bi

ibliography and References Cited

1. Trout Unlimited, (2020). The West Branch Susquehanna - A Watershed in Recovery,
www.tu.org

2. U.S. Department of the Interior, U.S. Geological Survey (2009). Fact Sheet — Emissions from
Coal Fires and their Impact on the Environment.

3. Chalekode and Blackwood - United States Environmental Protection Agency, EPA 600 2 78
004v (1978). Source Assessment — Coal Refuse Piles, Abandoned Mines and Outcrops,
State of the Art. Industrial Environmental Research Laboratory, Cincinnati, Ohio, Contract
68- 02-1874.

4, Hughes — Eastern PA Coalition for Abandoned Mine Reclamation (2019). Abandoned Mine
Land Reclamation: Innovative Approaches and Economic Development Opportunities.
Legislative Hearing, Testimony before the PA Subcommittee on Energy and Mineral
Resources.

5. USEPA Electronic Database, EPA eGRID, U.S. Environmental Protection Agency (2021).
https:/www.epa.gov/egrid

6. Gielisch H, Kropp C.,(2017). Coal Fires a Major Source of Greenhouse Gases- a Forgotten

Problem. Environmental Risk Assessment and Remediation 2017; 2(1): 5-8.
httos://wwwalliedacademies.org/articles/coal-fires-3-major-source-of greenhouse-gases-a-forgotten-probler=
‘887 L html

7. Fabiariska M, Ciesielczuk J, Nadudvari A, Misz-Kennan M, Kowalski A, Kruszewski T.,
(2019). Environmental Influence of Gaseous Emissions from Self-Heating Coal Waste
Dumps in Silesia, Poland. Environ Geochem Health. 2019 Apr;41(2):575-601. doi:
10.1007/s10653-018-0153-5. Epub 2018 Jul 24.

8. Chalekode and Blackwood - United States Environmental Protection Agency, EPA 600 2 78
004v (1978)USEPA (1978). Coal Refuse Piles, Abandoned Mines and Outcrops, State of the
Art, EPA-600/2-78-004v, July 1978, Table 4.

9. Brownstein et al, 2022. A Critical Opportunity in the Climate Fight. Environmental Defense

Fund, https:/www.edf.org/climate/methane-crucial-opportunity-climate-fight.

10. Global Warming Potentials Relative to CO2, IPCC Fifth Assessment Report (AR 5),
(2014). www.ipce.ch.

11. US Environmental Protection Agency, Office of Solid Waste (1995). Human Health And
Environmental Damages From Mining And Mineral Processing Wastes; Technical
Background Document.

12.1CF (2020). Draft, Pennsylvania Climate Action Plan

28




 

29 
 

 
 

13. Nazar Kholod, Meredydd Evans, Raymond C. Pilcher, Volha Roschanka, Felicia Ruiz, 
Machael Cote, Ron Collings (2020). Global methane emissions from coal mining to continue 
growing even with declining coal production. 

 

14. McNay, United States Department of the Interior, Bureau of Mines Circular 8515 (1971). 
Coal Refuse Fires, An Environmental Hazard 

 

15.State of Pennsylvania (1997). Surface Mining Control and Reclamation Act (1997) 
 

16. State of Pennsylvania (2021). Funding Projections, Infrastructure Investment and Jobs Act 
https://static1.squarespace.com/static/5da75e8578e3be27cc68f60f/t/61129c779f149c7edc92 
395f/1628609655857/Est+AML_Funding_Projections+Under+Infrastructure+Investment+and 
+Jobs+Act+8.10.2021.pdf 

 

17. Kirchgessner, Piccot and Masemore; United States Environmental Protection Agency, Office 
of Research and Development and Southern Research Institute, Research Triangle Park, 
North Carolina. An Improved Inventory of Methane Emissions from Coal Mining in the United 
States 

 

18. USEPA, Mercury and Air Toxics (MATS) Rule, Federal Clean Air Act Regulations, 40 
CFR 63, Federal Register Wednesday September 9, 2020. 

 
19. Guidance Memorandum from Steven Page, Director; USEPA OFFICE OF AIR QUALITY 

PLANNING AND STANDARDS, 2010. Applicability of the Federal Prevention of 
Significant Deterioration Permit Requirements to New and Revised National Ambient Air 
Quality Standards 

 
20.Abandoned Mine Reclamation Clearinghouse. Burning Waste Coal in CFB Powerplants 

 

21. Jennings, S.R., Neuman, D.R. and Blicker, P.S. (2008). Acid Mine Drainage and Effects 
on Fish Health and Ecology: A Review. Reclamation Research Group Publication, 
Bozeman, MT. 

 
22. Zhang (2013). Gaseous emissions from coal stockpiles. IEA Clean Coal Centre, ISBN 978- 

92-9029-553-4 
 

23. Jolanta Kus, Magdelena Misz-Kennan (2016). Coal weathering and laboratory (artificial) coal 
oxidation; International Journal of Coal Geology, Volume 171, 15 January 2017 

 

24. Ellery et al, Science Direct (1989). Spontaneous Combustion (from Coal and Peat Fires: 
A Global Perspective). 

 
25. PA DEP (2021). State of PA waste coal inventory, Excel 

Spreadsheet https://amlis.osmre.gov/, 
 

26. WV DEP (2021). AMLIS Query, Unabated AML refuse/spoil/gob in WV; West Virginia 
DEP waste coal inventory, Excel Spreadsheet, Provided by Mr. Travis Parsons, Planning 
Administrator, WVDEP – Abandoned Mine Lands Department, 2021. 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

13. Nazar Kholod, Meredydd Evans, Raymond C. Pilcher, Volha Roschanka, Felicia Ruiz,
Machael Cote, Ron Collings (2020). Global methane emissions from coal mining to continue
growing even with declining coal production.

14, McNay, United States Department of the Interior, Bureau of Mines Circular 8515 (1971).
Coal Refuse Fires, An Environmental Hazard

15.State of Pennsylvania (1997). Surface Mining Control and Reclamation Act (1997)

16. State of Pennsylvania (2021). Funding Projections, Infrastructure Investment and Jobs Act
https://static1.squarespace.com/static/5da75e8578e3be27 cc68f60f/t/61129c779f149c7edc92
3951/1628609655857/Est+AML_ Funding Projections+Under+Infrastructure+Investmenttand
+Jobs+Act+8.10.2021.pdf

17. Kirchgessner, Piccot and Masemore; United States Environmental Protection Agency, Office
of Research and Development and Southern Research Institute, Research Triangle Park,
North Carolina. An Improved Inventory of Methane Emissions from Coal Mining in the United
States

18. USEPA, Mercury and Air Toxics (MATS) Rule, Federal Clean Air Act Regulations, 40
CFR 63, Federal Register Wednesday September 9, 2020.

19. Guidance Memorandum from Steven Page, Director; USEPA OFFICE OF AIR QUALITY
PLANNING AND STANDARDS, 2010. Applicability of the Federal Prevention of
Significant Deterioration Permit Requirements to New and Revised National Ambient Air
Quality Standards

20.Abandoned Mine Reclamation Clearinghouse. Burning Waste Coal in CFB Powerplants

21. Jennings, S.R., Neuman, D.R. and Blicker, P.S. (2008). Acid Mine Drainage and Effects
on Fish Health and Ecology: A Review. Reclamation Research Group Publication,
Bozeman, MT.

22. Zhang (2013). Gaseous emissions from coal stockpiles. |EA Clean Coal Centre, ISBN 978-
92-9029-553-4

23, Jolanta Kus, Magdelena Misz-Kennan (2016). Coal weathering and laboratory (artificial) coal
oxidation; International Journal of Coal Geology, Volume 171, 15 January 2017

24. Ellery et al, Science Direct (1989). Spontaneous Combustion (from Coal and Peat Fires:
A Global Perspective).

25. PA DEP (2021). State of PA waste coal inventory, Excel
Spreadsheet https://amlis.osmre.gov/,

26. WV DEP (2021). AMLIS Query, Unabated AML refuse/spoil/gob in WV; West Virginia

DEP waste coal inventory, Excel Spreadsheet, Provided by Mr. Travis Parsons, Planning
Administrator, WVDEP — Abandoned Mine Lands Department, 2021

29




 

30 
 

 
 

27. P.K.Jha, T.K Das, & A.B. Soni (2016). International Journal of Coal Preparation and 
Utilization; Study of the Effect of Weathering on Coal and Coke Quality. After LaGrange, 
(1950). 

 

28. North American Manufacturing Co., (1965), The North American Combustion 
Handbook, Chapter 2 – Fuels 

 

29.Lesley Sloss (2013). Quantifying Emissions from Spontaneous Combustion 

 
30. Parr and Hamilton, (1907). The Weathering of Coal, University of Illinois, 

Engineering Experiment Station Published in the University of Illinois Bulletin No 17, 

Urbana IL. 

 
31. EIA-923 Reports, U.S. Energy Information Administration, 

https://www.eia.gov/electricity/data/eia923 
 
32. Virgina Department of Energy, VA Coal Refuse Inventory, 2022. 

 
33. ARIPPA substituted value for CH4 reduced from 0.7625 to 0.163, substituted to add 

conservatism and consistency with reported values 

 
 

nx TRC 650 Suffolk St., Suite 200 9789705600
v4 Lowell, MA 01854 TRCcompanies.com.

27. P.K.Jha, T.K Das, & A.B. Soni (2016). International Journal of Coal Preparation and
Utilization; Study of the Effect of Weathering on Coal and Coke Quality. After LaGrange,
(1950),

28. North American Manufacturing Co., (1965), The North American Combustion
Handbook, Chapter 2 - Fuels

29.Lesley Sloss (2013). Quantifying Emissions from Spontaneous Combustion

30. Parr and Hamilton, (1907). The Weathering of Coal, University of Illinois,
Engineering Experiment Station Published in the University of Illinois Bulletin No 17,
Urbana IL.

31, EIA-923 Reports, U.S. Energy Information Administration,
https://www.eia.gov/electricity/data/eia923

32.Virgina Department of Energy, VA Coal Refuse Inventory, 2022.

33.ARIPPA substituted value for CH. reduced from 0.7625 to 0.163, substituted to add
conservatism and consistency with reported values

30




 

  

 

Draft for Review 

Task 3 – Conceptual Recommendations to Improve CO2e 

Emissions Data from Abandoned GOB Piles in VA 
December 29, 2023 

Background 

The Virginia Department of Energy agrees with US EPA and others that AML GOB Piles 

(and other impoundments) in the Commonwealth emit the Greenhouse Gases CO2, 

Methane (CH4) and potentially N2O over their lifetime due to weathering, smoldering and 

spontaneous combustion. TRC has prepared a White Paper for Virginia Department of 

Energy to characterize the magnitude of such emissions from an estimated 80 million 

cubic yards (including that identified as AML GOB) present in the Commonwealth based 

on available emission estimates extracted from the Literature.   

Based on its review of the White Paper prepared by TRC, VA Energy may wish to 

improve the accuracy of the emission estimates cited and has asked TRC what a 

program to do so might entail.   

At this stage, TRC has framed a conceptual measurements Program in an effort to 

perform additional measurement specific to VA GOB Piles using today’s state of the art 

measurement techniques.  The first Task in doing so would require a detailed sampling 

and measurements plan and protocol with a Program design to best meet the needs of 

the Commonwealth.  In general, however, TRC envisions a measurements Program that 

may consist of the following activities.  

 

1. Perform additional Literature search from the coal gasification industry to better 

characterize the split of CO2 to CH4 at various levels of sub-stoichiometric oxygen 

(as practiced in industry for the purpose of generating methane (i.e., coal gas).  

2. Identify specific coordinates of piles undergoing spontaneous combustion as 

identified by the presence of smoke, steam (visual) or thermal imagery.  This may 

involve from between a few to a dozen or more locations amid well over 100 

individual piles subject to AML stewardship.   

3. Initially, we would consider the use of Open Path Measurement Technology to 

gather data for CO, CO2, CH4 and N2O across the extent of a single coal refuse 

hot spot. These measurements, perhaps averaged over several days multiplied by 

NX TRC 650 Suffolk St, Suite 200-7 9789705600
vA Lowell, MA 01854 ‘TRCcompanies.com

Draft for Review
Task 3 — Conceptual Recommendations to Improve CO2e

Emissions Data from Abandoned GOB Piles in VA
December 29, 2023

Background

The Virginia Department of Energy agrees with US EPA and others that AML GOB Piles
(and other impoundments) in the Commonwealth emit the Greenhouse Gases CO:,
Methane (CH,) and potentially NoO over their lifetime due to weathering, smoldering and
spontaneous combustion. TRC has prepared a White Paper for Virginia Department of
Energy to characterize the magnitude of such emissions from an estimated 80 million
cubic yards (including that identified as AML GOB) present in the Commonwealth based
on available emission estimates extracted from the Literature.

Based on its review of the White Paper prepared by TRC, VA Energy may wish to
improve the accuracy of the emission estimates cited and has asked TRC what a
program to do so might entail.

At this stage, TRC has framed a conceptual measurements Program in an effort to
perform additional measurement specific to VA GOB Piles using today's state of the art
measurement techniques. The first Task in doing so would require a detailed sampling
and measurements plan and protocol with a Program design to best meet the needs of
the Commonwealth. In general, however, TRC envisions a measurements Program that
may consist of the following activities.

1. Perform additional Literature search from the coal gasification industry to better
characterize the split of CO2 to CH, at various levels of sub-stoichiometric oxygen
(as practiced in industry for the purpose of generating methane (i.e., coal gas).

2. Identify specific coordinates of piles undergoing spontaneous combustion as
identified by the presence of smoke, steam (visual) or thermal imagery. This may
involve from between a few to a dozen or more locations amid well over 100
individual piles subject to AML stewardship.

3. Initially, we would consider the use of Open Path Measurement Technology to
gather data for CO, CO2, CH; and N20 across the extent of a single coal refuse
hot spot. These measurements, perhaps averaged over several days multiplied by




 
 

 

the area of the hot spot can provide emission estimates of actively smoldering 

waste coal that can be extrapolated into units of lbs/ft2 (or acre).  

4. If that measurement series is successful, it would be useful to adapt EPA’s 

measurement scheme (Kropp) by setting up a temporary enclosure (“tent”) of at 

least 10’ by 10’ area to capture the fumes issuing from the portion of the pile (and 

by characterizing the thermal signature of the column of refuse beneath it estimate 

the volume of refuse (ft3 and tons)). Assuming a passive thermal “chimney” from 

the tent area, it would be proposed to use the same open path measurement 

device equipment to log the same CO2e emissions for a week of hourly data.   

5. It may also be useful to take periodic passivated summa canisters for offsite 

laboratory analysis for both CO2e pollutants plus targeted others such as H2S, 

HCl, PAH’s, AS and Hg. 

6. The design of the measurements Program may need to be tweaked during this 

initial pilot study.  If it is able to provide the targeted information regarding air 

emissions emanating from spontaneous combustion, we would suggest 

expanding the sampling program to another five representative smoldering piles 

to assess variability pile to pile.  

Budgetary Cost Estimate   

A precise cost estimate cannot be generated prior to finalizing a detailed test plan.  Hover 

we would budget for around $100 k of labor, expenses, instrumentation and Lab fees 

based on up to five weeks x 2 staff in the field plus senior support to design, plan and 

execute such a Program.   

 

We are pleased to offer this assistance to the Commonwealth of Virginia Department of 

Energy. Please contact either me via e-mail or at (978) 302-0104 if you would like to 

discuss any aspect of our proposal.  

For TRC; 

 

 
 
 
Robert G. Fraser, QEP      
Principal      

 

X TRC 650 Suffolk St, Suite200 9789705600
v 4 Lowell, MA 01854 TRCcompanies.com

the area of the hot spot can provide emission estimates of actively smoldering
waste coal that can be extrapolated into units of Ibs/ft? (or acre).

4. Ifthat measurement series is successful, it would be useful to adapt EPA's
measurement scheme (Kropp) by setting up a temporary enclosure ("tent") of at
least 10° by 10’ area to capture the fumes issuing from the portion of the pile (and
by characterizing the thermal signature of the column of refuse beneath it estimate
the volume of refuse (ft? and tons)). Assuming a passive thermal “chimney” from
the tent area, it would be proposed to use the same open path measurement
device equipment to log the same CO2e emissions for a week of hourly data.

5. It may also be useful to take periodic passivated summa canisters for offsite
laboratory analysis for both CO2e pollutants plus targeted others such as H.S,
HCI, PAH’s, As and Hg.

6. The design of the measurements Program may need to be tweaked during this
initial pilot study. If itis able to provide the targeted information regarding air
emissions emanating from spontaneous combustion, we would suggest
‘expanding the sampling program to another five representative smoldering piles
to assess variability pile to pile.

Budgetary Cost Estimate

A precise cost estimate cannot be generated prior to finalizing a detailed test plan. Hover
we would budget for around $100 k of labor, expenses, instrumentation and Lab fees
based on up to five weeks x 2 staff in the field plus senior support to design, plan and
‘execute such a Program.

We are pleased to offer this assistance to the Commonwealth of Virginia Department of
Energy. Please contact either me via e-mail or at (978) 302-0104 if you would like to
discuss any aspect of our proposal

For TRC;

(dg 2—

Robert G. Fraser, QEP
Principal



	SJ 258 Waste Coal Study Report_Gov Review_DO NOT SHARE.pdf
	Report Overview
	Background on Waste Coal
	What is Waste Coal?
	Environmental Impacts
	Background in Virginia – industry history, volume
	Relevant federal rules or programs
	Relevant state rules or programs
	Previous waste coal reports and Inventory
	AML program
	Pennsylvania
	Comparison of VA and PA Waste Coal Assets

	Options for addressing waste coal
	No action
	Encapsulation/remediation
	VCHEC
	New Waste Coal to Generation Facilities
	Potential Source of Rare Earth Minerals (REEs)

	TRC Report Summary
	Policy options
	Business as usual
	Incentivize remediation
	Incentivize combustion
	Further Study

	Recommendations
	Conclusion
	Appendix 1 TRC Report
	Appendix 2 TRC Conceptual Recommendations to Improve CO2e Emissions Data from Abandoned GOB Piles in VA

	eVA White Paper Rev 12.31.23 (3)
	Draft Measurements Estimate 12.27.23