Alternatives for Future Coal Waste Disposal - Coal Waste Impoundments: Risks, Responses, and Alternatives - page 146

IMPLEMENTATION
Coal waste impoundments are part of the system for mining, preparing,
and combusting coal for energy production ( Figure 1.2 ). In order to assess
alternatives thoroughly, the whole system of mining, preparation, refuse
disposal, transportation, and power generation should be explored through an in-
depth life-cycle assessment, including cost assessment, with the goal of
optimizing the system to generate less fine coal waste while maintaining the
performance and economics of the system. Only through such modeling can the
benefits of system integration be fully explored. Of course, even if there are
such benefits, they may be difficult to realize because of differences in interests
and perceptions between the mining industry and the utility industry, and the
resistance to change embedded in these mature industries.
Several types of policies can effectively promote the use of alternative
technologies. One approach is to phase out the dominant technology, providing
sufficient time for commercialization of alternatives. Such an approach can
have a significant economic impact on the industry affected. A “safety valve”
can be provided by extensions to the phase-out dates where alternative
technologies are not available and by site-specific variances. This approach was
used effectively in the Hazardous and Solid Waste Amendments of 1986 (42
U.S.C. § 6924) to phase out the landfilling of untreated hazardous waste and to
give a clear signal to the market for alternative treatment technologies. This
approach has the benefit of stimulating the market for alternatives without
necessarily promoting specific technologies. To bring on the alternatives, this
approach can be combined with other policies, such as financial incentives and
research, development, and demonstration.
A second type of policy for promoting alternative technologies is the use
of financial incentives. These can take the form of tax credits or direct
government subsidies. Such subsidies can be paid for by a fee on the activity
being discouraged, such as a few cents per ton of fine coal waste disposed of in
slurry impoundments, or through a general fee on coal mining, like the
Abandoned Mine Land program under SMRCA. Both the alternatives for refuse
disposal and increased use of finer coal products will aid in the reduction of
slurry impoundment quantity and additional and future areas required for refuse
disposal. These incentives may also be extended to companies that reprocess,
reduce, or relocate the slurry materials within an existing impounding structure
through the use of alternative technologies, techniques, or methods. If this type
of operation is utilized in abandoned or “grandfathered” slurry impoundments,
an additional incentive could be