Coal Ash/Wood Ash Analysis This analysis uses a combination of analytical microscopy techniques to definitively determine if coal, coal ash and wood ash are present in soil samples. Used by License Site Professionals (LSP’s) since 1999, this powerful and versatile method provides critical information and documentation needed to accurately make site exemption status decisions. Designed by the President of MicroVision Labs, John Knowles, this method is the only technique which positively identifies the presence of coal, coal ash, wood ash, fly ash and asphalt in soil samples as well as any “look-alike” materials. Our Coal Ash/Wood Ash analysis is composed of the following components: Preliminary Inspection Stereomicroscope Examination Polarized Light Microscopy (PLM) Scanning Electron Microscopy (SEM) Energy Dispersive X-Ray Spectroscopy (EDS) Report providing micrographs and X-ray spectra as documentation Notification Exemptions Numerous State and Federal regulations, including the Massachusetts Contingency Plan (MCP), allow for certain notification exemptions when coal, coal combustion by-products, or wood ash are present in soil or fill. Oil and Hazardous Material (OHM), hazardous and solid waste regulations, trace metals, and Polycyclic Aromatic Hydrocarbons (PAH’s) are among the areas covered by these reporting exemptions (see table below). Our Coal Ash/Wood Ash Analysis gives vital information needed to take these exemptions without “going out on a limb”.

Summary of Regulations and Exemptions *

Act or Regulation	Summary
Massachusetts Contingency Plan 310 CMR 40.0006 (definitions); 40.0317 (9); 40.0370 (1)(2); 40.0006	MA Regulations – Releases of Materials and Cleanup Requirements: Releases of OHM related to coal ash and wood ash are exempt from notification requirements. Fill related materials containing coal ash and wood ash are considered background.
Massachusetts Public Health Law M.G.L. c.111, Section 150A	MA Statute – Coal Ash Exempt as a Waste Under Certain Conditions: Ash produced from the combustion of coal (including fly ash and bottom ash) is not considered waste when used as a raw material for concrete block manufacture, aggregate, fill, base for road construction, or for other commercial or industrial purposes, or stored for such use. Coal ash may also be used as intermediate landfill cover material over rubbish at sanitary landfills, with appropriate local Board of Health and DEP approval.
RCRA Section 3001 (b)(3)(A)(1)	Bevill Amendment – Exemption for Fossil Fuel Wastes: Under the Bevill Amendment, coal combustion wastes are exempt from hazardous waste regulation under RCRA following EPA’s Report to Congress and regulatory determinations.
EPA Regulations Identification and Listing of Hazardous Wastes 40 CFR 261.4 (b)(4)	Coal/Fossil Fuel Ashes – Hazardous Waste Exemptions: Fly ash waste, bottom ash waste, slag waste, and flue gas emission control waste generated primarily from the combustion of coal or other fossil fuels.
Massachusetts Hazardous Waste Regulations 310 CMR 30.104 (9)	MA Regulations – Hazardous Waste Exceptions: Fly ash and other emission control waste generated primarily from the combustion of coal or other fossil fuels are not subject to 310 CMR 30.000
Massachusetts Solid Waste Regulations 310 CMR 19.006	MA Regulations - Solid Waste Definition: Ash produced from the combustion of coal when reused as prescribed in MGL c.111 section 150A is exempt from the definition of solid waste.

* as presented by the LSP Association’s Oct. 19th, 1999 White Paper “Methods for Evaluating Applications of the Coal Ash and Wood Ash Exemption under the Massachusetts Contingency Plan”

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