The Problem with checking your own homework
Monday December 22, 2008, an environmental disaster struck in Kingston, Tennessee. Tennessee Valley Authority (TVA)’s Kingston Fossil Plant released 1.1 billion gallons of coal ash into the nearby Clinch and Emory Rivers and covered nearly 300 acres of surrounding land. The coal ash damaged numerous homes and building structures, rendering them uninhabitable, and polluted waterways. While the initial spill clean-up did not result in immediate deaths or injuries, years later, those hired by TVA to clean up the release started to develop illness such as leukemia, lung cancer, and brain cancer. Within ten years of the disaster, forty workers had died.
On April 17, 2015, the first national regulations on the disposal of coal combustion residuals (CCR) were finalized and signed into effect. The new rules under subtitle D of the Resource Conservation and Recovery Act (RCRA) address the risks from improper disposal of coal ash as they pertain to leaking into groundwater and the aerosolization of contaminants. These new regulations require coal burning facilities to establish recordkeeping and reporting habits as well as make specific information accessible to the public. Of particular interest to those affected in Tennessee were the regulations regarding groundwater monitoring. Regulations would now require owners and/or operators of a CCR unit to monitor well water. Owners or operators would need specific procedures for sampling and methods for analyzing the data collected from groundwater to detect the presence of hazardous materials, such as arsenic and other heavy metals, along with water parameters. If the levels of hazardous materials found exceeded a groundwater protection standard, or if the water parameters measured were not adequate, the owner or operator would have to implement corrective actions.
While the new RCRA rules were headed in a positive direction, a 2018 decision resulted in the roll back of these regulations. This decision could potentially lead to the leaching of coal ash containing heavy metals (e.g., arsenic, mercury, and selenium) into water supplies from coal-fired power plants. The US Environmental Protection Agency (EPA) weakened the previously listed RCRA regulations by allowing weaker standards for many hazardous contaminants and leaving the issue of groundwater monitoring, both sampling and remediation actions, up to the states. Many states have left such actions up to the coal plants themselves. While there are many of these facilities that will proactively develop these plans, the TVA disaster shows what could happen when coal plants are allowed to check their own homework. Allowing coal plants to decide whether or not their actions are harmful may lead to coal ash leaking into the surrounding groundwater and could potentially result in severe adverse health effects on those who rely on the water.
Coal ash is the waste that is left after coal is combusted, mostly in coal-fired electric power plants. Coal ash can contain particulates of volatile and semi volatile organic compounds and heavy metals. The main hazards of coal ash are the substances of which it is made. Coal ash is known to contain arsenic, lead, mercury, selenium, cobalt, cadmium, chromium, manganese, and other known hazardous substances. Elevated levels of these heavy metals can be detrimental to one’s health and well-being. The composition of coal ash is any ratio of the above-mentioned heavy metals and can vary depending on the ground source of the coal. The potential for severe harm due to coal ash exposure is endless, especially because EPA has not labeled coal ash as hazardous waste. This means there are no governmental regulations on the proper way to dispose of the substance. This has allowed for many coal powered plants to dispose of their waste product in coal ash ponds, many of which can be unregulated. A minority of these ponds found in the United States have a protective lining to impede the coal ash from seeping into the groundwater. This is a big problem because data from many coal ash ponds show that they are leeching unknown levels of coal-associated substances into groundwater, ending up in nearby rivers and lakes, potentially putting thousands of lives at risk.
A real danger comes from EPA by allowing these power plants to regulate themselves. Under the new regulations, power plants are to check the surrounding groundwater levels only if they believe their actions cause dangerous levels of hazardous materials in the water. The problem is you are asking these companies to self-determine what “dangerous levels” are. The EPA, ATSDR, and CDC have not established what dangerous or acceptable levels of coal ash are beyond identifying the ash as a hazard, so how will coal ash companies know what the appropriate thresholds are?
Ten years after the Tennessee Valley disaster, forty people who were involved in the cleanup died and over 400 residents in the neighboring communities experienced severe health effects. Residents near TVA are not the only communities affected by coal ash ponds. An investigation in August of 2013 revealed numerous inmates at the State Correctional Institution Fayette in Pennsylvania had developed thyroid disorders, respiratory illnesses, GI tract problems, and even cancers. The correctional institution is surrounded by two coal ash ponds and over 40 million tons of combustion waste.
With states no longer monitoring groundwater, there is no way to know the amount of hazardous material coal ash ponds are leeching into the ground, subsequently contaminating the water supply. There are uncertainties with coal ash and the level or risk for downstream receptors, like the inmates mentioned above. Overall, power companies self-determining if their actions are safe will, almost undoubtably, cause exposure to coal ash at unsafe levels and more devastating headlines.
References
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Drinking water and public health impacts of coal combustion waste disposal [electronic resource] : hearing before the Subcommittee on Energy and Environment of the Committee on Energy and Commerce, House of Representatives, One Hundred Eleventh Congress, first session, December 10, 2009. (2012). Washington : U.S. G.P.O., 2012.
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Deonarine, Amrika, Bartov, Gideon, Johnson, T.M., Ruhl, Laura, Vengosh, Avner, and Hsu-Kim, Heileen, 2013, Environmental impacts of the Tennessee Valley Authority Kingston coal ash spill; 2. Effect of coal ash on methylmercury in historically contaminated river sediments: Environmental Science & Technology, v. 47, no. 4
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U.S. Environmental Protection Agency, 2014a, Coal combustion residuals (CCR)―Surface impoundments with high hazard potential ratings: U.S. Environmental Protection Agency
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American Coal Ash Association, 2013, 2013 coal combustion product (CCP) production & use survey report: American Coal Ash Association