For rock music enthusiasts who have been around for a while, CCR always referred to John Fogerty’s lean, clean, and bluesy San Francisco-based band and its string of classic rock hit songs. With a new set of US EPA rules and a new set of analytical challenges pertaining to coal combustion residuals, we have a new application for that acronym. (Sorry John.)
As chemists and geoscientists working daily providing oversight on sampling and analysis of coal combustion residuals (CCRs) and associated environmental impacts, we are a lot like Discovery Channel’s MythBusters, and not just because we are geeky and cool. As is often the case with environmental hot-button issues, the truth with regard to the environmental impacts that can actually be measured lies between languid, lackadaisical dismissals of any risk and highly spun apocalyptic visions of widespread poisoning. We have been in a unique position to appreciate this because of a rich history of providing services for utilities with CCR assessment programs, including on-scene oversight of the scientific data collection, including sampling planning, sampling oversight, laboratory audits, and data validation. We have provided these services throughout the TVA Kingston Plant response and monitoring of the impacts from the 2008 1.1 billion-gallon coal ash slurry release to Tennessee’s Emory River. We also provide this service at a variety of coal power plants addressing high-profile citizen and state lawsuits.
A recent article in the American Chemical Society’s Chemical and Engineering News (A New Life for Coal Ash) presents a fascinating overview of the global scale of the CCRs that we, as a nation, have on hand. Coal ash is huge. (Yes this is the Donald Trump pronunciation.) It’s the second-largest waste material in the U.S. behind household trash. The article cites an American Coal Ash Association (ACAA) estimate that in one year alone (2014) U.S. coal power plants generated 129.7 million tons of coal ash. We marvel at the magnitude of the material being managed, having watched as more than 100 rail cars per day were loaded (a total of 39,760 rail cars) to move a mere 4 million tons of coal ash relocated from the Kingston Plant!
Spurred by this release, and in the face of strong opinions voiced for both categories of myth, US EPA performed a significant review, addressing the classification of CCR. (Unfortunately, the new CCR rule has nothing to do with listening to great music.) Using newly developed leaching test methods to evaluate impacts to groundwater and surface water, the agency established technical requirements for CCR landfills and surface impoundments under Subtitle D (Landfills) of the Resource Conservation and Recovery Act (RCRA), the nation’s primary law for regulating solid waste. With the new CCR rule in effect, hundreds of landfills and surface impoundments now must be monitored, primarily by conventional groundwater, airborne particulate, and structural integrity testing. Significantly, the enforcement provision of the CCR rule is based upon citizen lawsuits. However, we have seen that states can also sue on the basis of suspicions of unregulated releases under National Pollutant Discharge Elimination System (NPDES) regulation.
It has not been made clear how the agency used or anticipates using these Leaching Evaluation and Assessment Framework (LEAF) methods to assess potential impacts, but it is clear from our review that there are many ambiguities in the methods as published by the Office of Solid Waste (now named Office of Resource Conservation and Recovery). These ambiguities can have a significant impact on the results and validity of the testing. State and regional watershed authorities are already pushing for this expensive new testing – but with no information available on how to use the results to evaluate the level of concern.
If you have read this far, you may need someone in your corner who knows how to avoid the pitfalls of using questionable data in questionable ways. In our experience, utilities want to understand the real, science-based risks associated with their CCR facilities and are coming to understand the need for real data quality (and “MythBusters” support) to navigate the risks of the citizen lawsuit provision of the CCR rule. We can help you put the “Creedence” back into your CCR monitoring and assessment.
Contact David Thal at dthal@www.www.envstd.com or 865-376-7590, or contact Rock Vitale at rvitale@www.www.envstd.com or 610-935-5577.